If in the future we finally get a dualing of the A21, what route through Flimwell is left available?

I would of clicked in the middle of Support-object TBH, but no option
Ref the area shown in Flimwell near the Crossroads, I would rather not have a load of houses behind (near) my house, I take it you have visited the area? would it not be better, not to build on the green horses field (behind the smokerery) but on the land that next to that, where a certain owner has used it for a dumping ground for unwanted vehicles & Mud!
Would also make more sense in the building Logistics roads/entrances & also right next to the other (Larger) area.
I'am guessing the green field is a easier option, I have learnt over the years that what councils choose.
Please respond, then I know this option won't just get binned......

Policy Reference FW1 Flimwell – Site Rear of Fruitfields, High Street (Union Street) Flimwell

1. The site identification that can be involved:
The Ticehurst Neighbourhood Plan as advised by the Steering Group allocated this site for 9 dwellings, not 35. This of course was subject to a vote on the overall plan by the Parish community. The Parish did indicate in the Neighbourhood Plan that it would not support any larger development than 9 dwellings and therefore why should the site now be allocated for 35 units?

2. Given the topography of the land, regardless of limitation of only 50% to be used from the southern boundary. The construction process alone will result in pollution of the ghyll system and tributaries of the River Bewl.

This ghyll system has been identified as important by the Woodland Trust and is regularly monitored by the Kent Botanical Society, being the boundary between East Sussex and Kent. Many rare plants and mosses form sphagnum bogs in several positions which will inevitably be destroyed by uncontrolled pollution from the development and run off from the occupied houses.

3. The whole of the proposed site, all 2.3 hectares is ranged over by rare bats occupying Wardsdown Woodland towards the southern boundary; these include Noctule and Natterers.

4. The existing access to the site adjacent to Wardsdown House: It is our understanding that the widened section ending just south of Copperfield Cottage is in the ownership of the developer. However, the remaining length of the track is in the ownership of Wardsdown Woodland, Title No. ESX 133909 which also indicates absolute rights over the southern end of the track as described for all vehicles at all times for any purpose. This is the forestry access and it also includes the public footpath described. Therefore its configuration cannot be changed in any way.

5. The shrubs and trees on the west boundary are not, as we see it, in the ownership of the proposed development site, given that the boundary fence is at the bottom of the bank which forms the angle of repose supporting the track and therefore whether or not it is maintained as a screen is a decision to be made by the owners of the track and Wardsdown Woodlands.

6. Viability of the site and proposed extension eastwards: This extension of the site was not indicated in the Ticehurst Neighbourhood Plan and therefore was not voted upon. To include it at this stage is to ignore the democratic process, the advice of the Steering Group and the Parish Council’s decisions.

7. In 2019 a very detailed report was prepared by The Woodland Trust for Wardsdown Woodland, Ancient Woodland Restoration, which formed part of the ongoing management plan. This was to remove progressively non-native trees and shrubs to increase and enhance biodiversity.

The final scheme in this regard has just been completed, supported by The High Weald National Landscape Partnership with detailed information provided by The Woodland Trust to remove all of the remaining non-native invasive trees and shrubs. This scheme was partly funded by us, the owners of Wardsdown Woodland and the High Weald National Landscape Partnership “Tax Payers money.”

These progressive operations have enabled significant improvement on biodiversity and habitat creation resulting in natural regeneration of woodland flora and a notable increase in the bird population, especially summer visitors including a number on the red list.

We as the owners of Wardsdown Woodlands, in reality custodians as these woodlands have been in existence for hundreds of years, since our acquisition, have spent much time and indirectly considerable expense in enhancing this important place and to put it at risk cynically, expediently and undemocratically simply to make up the numbers says to this community that RDC really do not care in preserving what little ancient woodland remains.

The proposed developments would increase the traffic through the village causing more hazards and congestion especially in the mornings and afternoons/evenings, after completion and massive disruption during the development with heavy vehicles, adding significant damage to the already fragile road surfaces.
The additional pressure on services, especially schools, and medical( with the Ticehurst surgery closed, Wadhurst medical practice could collapse under the additional number of patients). Water supply in the village is finite and will not sustain the additional demands.
Sewerage and drainage have not been highlighted enough.
No additional information on improvements to managing travel provision via local bus services. Additional pollution

Re. FW1:
The land earmarked for development at Wardsdown House should be significantly curtailed on the grounds that a 9 house development stretching all the way to the northern edge of the proposed site would violate each and every one of the Policies that Rother District itself cited in the SHLAA 2013 review with respect to the amenity land north of Hurstwood west of Old Wardsdown, referenced as F11, namely Policies CO3, EN1, EN5, RA1, RA2 OSS1, OSS2, OSS3 and OSS4. Where F11 was concerned the Council correctly argued that a SUBSTANTIAL buffer be maintained between the new development and the ancient woodland beyond. The same arguments were also propounded and upheld in the case of the amenity land at Old Wardsdown, located between the Wardsdown House proposed development site and Hurstwood. The meagre 15 metre buffer advocated by the TNP Steering group for the Wardsdown House site is totally inadequate for the purposes of protecting and safeguarding the southern fringe of the ancient woodland beyond, together with its fragile ecosystem which includes one of the main sources of the River Bewl.

The once inviolable Limits to Built Development should not be flouted in the case of Wardsdown House and arbitrarily re-drawn to 'legitimately' accommodate c.35 houses on a site for which there are literally no historic precedents for previous planning permissions granted, even for as few as 3 houses, let alone 35! Incredibly, in the TNP Site Assessment Document final version July 2018 (included in the TNP Evidence Base) it states that the SHLAA status for the site is: "No previous planning applications for this site"! This is not so.

The evidence is all there at the Rother District Planning web site:

Planning Application Numbers A/61/451 and 452 for 100 houses refused 27/7/1961
A/70/648 for 5 pairs of houses and garages refused 02/10/1970
A73/0268 for 46 houses, a pumping station and access road refused and subsequently dismissed on appeal 31/12/1973
RR/74/0966 Demolition of Wardsdown House and widening of access refused 28/11/1974
RR/88/0613 for 3 detached houses with garages refused 26/5/1988.

Of the permissions granted for this site, we only have conditional permissions for extensions to Wardsdown House, use of the land for a mini-skip business and a solitary conditional permission for just one dwelling.

While housing needs may have increased in recent years this land has remained the same as have the objections raised for all of the above refusals which predominantly clustered around the vital concepts of protection of the AONB and ancient woodlands as well as the negative consequences, going forward, of backland development in small villages.

For decades, now, Flimwell has been an easy mark for new development in this Parish because its traditional ridge development structure invites ongoing ribbon development which precludes the establishment of a genuine village centre and accordingly a cohesive and durable community spirit.

Such houses will not satisfy OUR Parish's housing needs, they will only serve Rother District Council's needs to expediently check their own housing quotas boxes at the irrevocable expense of yet another chunk of the AONB which our Neighbourhood Plan professes to supposedly protect above and beyond all else. A developer cash contribution toward affordable housing elsewhere is no compensation for our community's loss in this respect.

To facilitate any development WHATSOEVER outside the former LBD line at Wardsdown House sets this dangerous precedent for your currently proposed development on all the open land North of Fruitfields which would be signally, ecologically irresponsible and should not be allowed to happen. Rather, the open fields North of Fruitfields should be formally designated as Green Space land in your forthcoming Plan so that there is at least some hope for the future survival of the green fields surrounding both Wardsdown Woods and its northerly neighbour, Birch Woods.

FW1 - Flimwell

This land is in the High Weald National Landscape, adjacent to Ancient woodland and a Priority Habitat and therefore should be protected under section 15 of the National Planning Policy Framework.

Facilities and services cannot be reached by cycling or walking. Public Transport is inadequate (1 per hour).
Therefore this site will increase the dependency on cars increasing the volume of traffic, increased emissions and increased danger from vehicles which currently far exceed the speed limit on the B2087 and A268.

FW1: This site is entirely unsuitable for a large development of houses. The field proposed for development is subject to frequent flooding, is a much-used habitat for a whole plethora of species of wildlife and is adjacent to protected ancient woodland which would be severely and irrevocably affected by such close development. Regardless of what remediations might be proposed to limit light emissions these would not be sufficient so as not to badly affect local wildlife, not to mention to the residents of the row of houses that backs on to the plot that would have their complete way of life ruined by the development. Our village could not possibly accept this 10% increase in population without severely affecting the lives of existing residents - this site alone would add about 10% to the population and the infrastructure is not there for such an increase. There is no safe pedestrian access to nearby shops, doctors, chemists or schools and the current bottleneck junction at the A21 cannot sustain such an increase in traffic. Much as we all appreciate the need for new houses to be built, ruining an area of green-belt and the lives of local residents is too high a price

Please see attached for full representation:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q17 Q17 - all BX sites.

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

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

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

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

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

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

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

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

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

26 CR1 to CR3

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

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

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

28 GU1 & GU2

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

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

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

30 GU4 & 5

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

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

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

31 GU6

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

32 IK1&2

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

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

34 WS1 WS2, WS3 WS4 WS5

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

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

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

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

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

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

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

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

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

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

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

38 CT1 CT2 CT3

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

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

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

39 NE1 & 2

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

40 SD10 SD11 (SD1 to SD9)

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

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

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

42 BC1 (BC2) BC3

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

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

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

43 (BR1) BR2 BR3

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

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

44 CM1 to CM3

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

45 (ID1) ID2

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

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

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

46 NR1 and NR2

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

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

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

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

47 PE1, 2 & 3 (PE4 & PE5)

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

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

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

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

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

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

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

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

50 RH1

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

53 BW1 to 4

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

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

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

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

54 BWC1 and 2

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

55 EC1 to 3

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

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

56 (HG1&2) HG3 & 4

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

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

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

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

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

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

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

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

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

58 SC1 & 2

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

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

59 FW1 to FW3

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

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

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

60 TC1 (or 2)

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

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

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

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

62 SG1 or 2

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

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

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

Q64 GYP1 to GYP6

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

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

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

Q69 Any other issues or comments?

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

Objecting to FW2. Hawkhurst Road has become much busier in the last 12 months in both directions, with traffic now REGULARLY backing up some way back from the traffic lights. Pollution levels are already poor (DAQI index 3 depending on time of day) and more static traffic will increase that. The roads are narrow, the pavements pitiful, car speeds off the scale and all make walking and driving dangerous. More people and more cars will cause further delays and issues for all of us, particularly as Hawkhurst Road, and generally that single junction in the village, are the only routes to 4 directions. And no village facilities means ppl are always on the move.

We would very much like to object to site FW1 - rear of Fruitfiels in Flmwell being considered.
The Ticehurst Neighbourhood and the Parish Coucil advised that this site was only suitable for 9 dwelling - not 35. They advised that they wouldn't support the development of land behind Fruitfields. Why has this now changed?
The plan suggested that only the southern (top section) of the land would be suitable - this is the area closest to our homes. We moved here for the view, this would be ruined.
This ancient woodland is adjacent to the site, we have a wide selection of wildlife that frequent these fields - they include rare bats, birds of prey, deer, foxes, herons just to name a few.
This site should not be considered as a suitable site to develop.

There is no infrastucture close to FW1 site in Flimwell, the FW2 site is the East of the A21. The east side of the A21 has a church, businesses, shops, 2 cafe's and a take-away. Surely this site is more suitable for development.
We live on Union Street which overlooks the FW1 site. We had planning permission refused to convert an outbuilding due to it overlooking the AONB. Why is this site now suitable to support 35 dwellings? It's only a few meters from our outbuilding.
The access track is next to Wardsdown House to Wardsdown Woods (ancient woodland) the footpath access to the site would be compromised due to the many locals who use this footpath on a daily basis.
We feel that this GREENFIELD site is wholely unsuitable to be considered a redevelopment as is against the policy to provide housing.

I wish to formally object to the proposed developments FW1, FW2 and FW3.

When these proposals were initially discussed last year, residents were informed that the developments would consist of a significantly smaller number of homes. The number now being proposed is considerably higher and represents a substantial increase in scale. This change raises serious concerns about the overall impact on the local community and environment.

The development of FW1 in particular would have a significant and detrimental impact on the surrounding landscape and community. The area is designated as an Area of Outstanding Natural Beauty, and any development should therefore be considered with the utmost care. The scale and nature of the proposed development would inevitably affect the character of the landscape, increase light pollution and negatively impact local wildlife and the well-being of residents who live in and value this protected environment.

I believe the proposals are inconsistent with the principles set out in national planning policy regarding development within Areas of Outstanding Natural Beauty (AONB). These areas are afforded the highest level of protection in relation to landscape and scenic beauty, and planning decisions should prioritise the conservation and enhancement of these environments. Large-scale residential developments such as those proposed under FW1, FW2 and FW3 risk undermining the character, tranquillity and visual quality of the landscape that the AONB designation is intended to protect.

Furthermore, the proposed developments raise concerns regarding biodiversity and habitat protection. The surrounding area supports a variety of wildlife and forms part of a wider ecological network. Development at this scale has the potential to fragment habitats, increase disturbance from noise and light pollution, and reduce the availability of natural spaces that local species depend upon. Without clear and robust environmental assessments and mitigation measures, there is a significant risk that the biodiversity of the area will be negatively impacted.

I would also like to highlight what appears to be a clear inconsistency in how planning considerations are being applied. When we previously applied for a small extension to our home, our application was initially rejected due to a window on the front elevation, which we were informed would contribute to light pollution within an AONB. We were required to amend and resubmit our plans at additional cost in order to comply with this restriction. Given this precedent, it is difficult to understand how the far greater light impact associated with a large-scale housing development can now be considered acceptable.

Traffic and road safety are also major concerns. The local roads already experience a substantial volume of traffic, resulting in congestion and frequent speeding. Unfortunately, there have been numerous accidents in recent years, some of which have been extremely serious and even fatal. Residents, myself included, have previously raised these concerns with the highways authority and requested speed reduction measures, but we have been informed that the threshold for intervention has not been met.

Introducing additional housing will inevitably lead to increased traffic, further congestion and a heightened risk of accidents. This would place additional strain on an already problematic situation and raise serious concerns regarding road safety for residents and visitors alike.

Finally, the local infrastructure is already under significant pressure. Essential services such as GP surgeries, dentists and schools are operating at or beyond capacity. Without clear and robust plans to expand these services, it is difficult to see how the area could sustainably accommodate further residential development.

For these reasons, I strongly object to the proposed developments and respectfully ask that the planning authority carefully consider the cumulative environmental, safety and infrastructure impacts before proceeding with any approval.

FW2 - An oversized development for Flimwell village which has few services within safe walking distance. Existing employment opportunities should not be jeopardised. The junction with the A21 is notorious. This site is divided from the village proper by that road.

We write on behalf of the landowners of part of FW2b (Cherry Tree Nursery and land to the rear). The land has previously been assessed as being able to provide suitable access and the landowners confirm the site's availability. The owners are happy to work with the owners of the wider FW2 site, the local authority and the local community to address the requirements of any development as outlined by the LPA. Notwithstanding that, FW2b is capable of development as a smaller site in itself.
Development at Flimwell Park taken alongside the provision of community facilities, etc at FW2 would provide a greater range of services on this side of the A21.

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.

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

I wish to formally object to the proposed developments FW1, FW2 and FW3.
When these proposals were initially discussed last year, residents were informed that the developments would consist of a significantly smaller number of homes. The number now being proposed is considerably higher and represents a substantial increase in scale. This change raises serious concerns about the overall impact on the local community and environment.
The development of FW1 in particular would have a significant and detrimental impact on the surrounding landscape and community. The area is designated as an Area of Outstanding Natural Beauty, and any development should therefore be considered with the utmost care. The scale and nature of the proposed development would inevitably affect the character of the landscape, increase light pollution and negatively impact local wildlife and the well-being of residents who live in and value this protected environment.
I believe the proposals are inconsistent with the principles set out in national planning policy regarding development within Areas of Outstanding Natural Beauty (AONB). These areas are afforded the highest level of protection in relation to landscape and scenic beauty, and planning decisions should prioritise the conservation and enhancement of these environments. Large-scale residential developments such as those proposed under FW1, FW2 and FW3 risk undermining the character, tranquillity and visual quality of the landscape that the AONB designation is intended to protect.
Furthermore, the proposed developments raise concerns regarding biodiversity and habitat protection. The surrounding area supports a variety of wildlife and forms part of a wider ecological network. Development at this scale has the potential to fragment habitats, increase disturbance from noise and light pollution, and reduce the availability of natural spaces that local species depend upon. Without clear and robust environmental assessments and mitigation measures, there is a significant risk that the biodiversity of the area will be negatively impacted.
I would also like to highlight what appears to be a clear inconsistency in how planning considerations are being applied. When we previously applied for a small extension to our home, our application was initially rejected due to a window on the front elevation, which we were informed would contribute to light pollution within an AONB. We were required to amend and resubmit our plans at additional cost in order to comply with this restriction. Given this precedent, it is difficult to understand how the far greater light impact associated with a large-scale housing development can now be considered acceptable.
Traffic and road safety are also major concerns. The local roads already experience a substantial volume of traffic, resulting in congestion and frequent speeding. Unfortunately, there have been numerous accidents in recent years, some of which have been extremely serious and even fatal. Residents, myself included, have previously raised these concerns with the highways authority and requested speed reduction measures, but we have been informed that the threshold for intervention has not been met.
Introducing additional housing will inevitably lead to increased traffic, further congestion and a heightened risk of accidents. This would place additional strain on an already problematic situation and raise serious concerns regarding road safety for residents and visitors alike.
Finally, the local infrastructure is already under significant pressure. Essential services such as GP surgeries, dentists and schools are operating at or beyond capacity. Without clear and robust plans to expand these services, it is difficult to see how the area could sustainably accommodate further residential development.
For these reasons, I strongly object to the proposed developments and respectfully ask that the planning authority carefully consider the cumulative environmental, safety and infrastructure impacts before proceeding with any approval.

INTRODUCTION
I welcome the opportunity to submit my comments on the proposed site allocations in Flimwell: FW1 (Land to rear of Fruitfields), FW2 (Hawkhurst Road), and FW3 (Cedar Farm, London Road) included within the Draft Rother Local Plan.

This consultation portal requires me to pick a binary option of ‘object’ or support’ which is neither necessary nor helpful. I trust it will be apparent from my response below, that my position is more nuanced. However, I have opted for ‘object’ given the scale of development proposed for Flimwell.

I recognise the national and district‑level need for new homes, and I support the principle of providing appropriately scaled housing to meet local needs, including affordable opportunities for young people wishing to remain in the community they grew up in, and suitably sized homes for older residents wishing to downsize.

A successful Local Plan must not focus solely on housing numbers. It is crucial that we create thriving communities where residents can have access to good quality facilities such as shops, medical facilities, schools, jobs, good transport links (including public transport) as well as the infrastructure to support our communities, including electricity (sufficient to enable charging of electric vehicles), water, sewerage and broadband.

I broadly support Rother District Council’s vision, overall priorities and objectives for the Local Plan. As explained in more detail below, Flimwell is a small village within the High Weald National Landscape with very limited facilities to support significant new development.
The scale of development proposed for Flimwell is disproportionate to the size, capacity, and infrastructure of the village. Flimwell lacks the necessary transport, social, and community infrastructure to support the level of development proposed under FW1 and FW2. In addition, the density of housing is far too heavy at 35 dwellings per hectare.

These sites lie within the High Weald National Landscape, a nationally protected landscape and are all greenfield rather than brownfield sites. The National Planning Policy Framework (NPPF) s.189 states:
“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas… “The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.”

There are significantly more appropriate opportunities in Rother’s larger settlements - Bexhill, Battle, and Rye - where transport, education, healthcare, retail, and utilities infrastructure already exist. It is neither fair nor sustainable for small rural villages in the High Weald National Landscape to absorb sizeable housing allocations while national policy trends reduce pressure on larger urban areas.


OVERARCHING CONCERNS: SCALE, SUSTAINABILITY, AND INFRASTRUCTURE CAPACITY
The combined proposals for FW1 and FW2 would represent a substantial expansion of a small rural settlement with extremely limited services. Flimwell has:
• No GP surgery
• No everyday convenience retail
• No safe pedestrian or cycle routes across the A21 and A268
• Limited public transport provision


FW1 – LAND TO REAR OF FRUITFIELDS
The Ticehurst Neighbourhood Plan (2018–2028) allocates only nine dwellings on part of this site (Wardsdown House) and explicitly states that any expansion beyond this area is not supported.

The NPPF (introduction, paragraph 2) confirms that: “Planning law requires that applications for planning permission be determined in accordance with the development plan… This includes local and neighbourhood plans that have been brought into force.”
The Ticehurst Parish Council assessment identifies several significant constraints affecting the wider FW1 area, including:
• Severe landscape impacts arising from steep level changes
• Historic field boundaries that require protection
• Potential biodiversity impacts
• Privacy and overlooking concerns affecting existing Fruitfields properties

Taken together, these constraints clearly demonstrate that the larger FW1 allocation, proposing 32 new dwellings, is inappropriate and unsuitable beyond the nine homes already supported by the adopted Neighbourhood Plan.

Given the site’s environmental sensitivity, restricted access, and direct conflict with established local policy, FW1 should not be allocated for development beyond the nine dwellings already endorsed through the Neighbourhood Plan.


FW2 – HAWKHURST ROAD
FW2 proposes 114 dwellings, employment space, retail, and community uses. This scale represents a disproportionate expansion for a village of Flimwell’s size and character. This site has been identified as a result of a council search, and it is unclear whether any of the pockets of land have been put forward for consideration by any of the landowners.

It is an extensive area of land and therefore, as noted in the site assessment in the Housing and Economic Land Availability Assessment (HELAA) carried out in 2024, this is likely to constitute a “major development” within the High Weald National Landscape, which the National Planning Policy Framework (NPPF) s.190 states:
“When considering applications for development within National Parks, the Broads and National Landscapes, 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.”

Development on these sites would have significant impacts on landscape character and views. The fields in FW2b (Hawkhurst Road, Flimwell – east) have historic significance as they link Sunnybank Cottages, which are former cottages for workers of Bedgebury Forest dating back to the 1850s, with the forest itself. The properties have views of the forest which would be obscured by housing or other development and should maintain a significant buffer zone to protect the forest and ancient woodland.

The sites identified in FW2 are located adjacent to the A268, which has poor sightlines, narrow footways, and no safe or attractive routes for pedestrians or cyclists. Bus services are limited, and residents would be overwhelmingly car‑dependent.

It is unclear where the access/egress to the land identified in FW2 would be. Both the A21 and A268 are busy roads with a significant accident history. A pedestrian fatality occurred on the A21 in November 2023 between the former Royal Oak pub and the A268 crossroads highlighting ongoing safety concerns. The footpath along the A268 is narrow and does not provide a safe walking or cycling experience against fast moving traffic. Whilst there is a bus route passing through Flimwell, the vast majority of residents are reliant on private cars.

Such a large development is also likely to have a significant congestion impact on the junction of the A268 with the A21 at the Flimwell crossroads. The traffic lights on the crossroads are controlled by National Highways and are timed to favour traffic flows on the A21. This leads to lengthy queues, particularly at peak travel times. It is reasonable that the traffic on the Strategic Road Network is prioritised over local roads and therefore it is unclear how any additional road capacity on the local road network could be delivered at this location.

One of the parcels of land contained within FW2 is Cherry Tree Nursery. This site has been subject to various planning applications for housing and caravans. All of these applications have been rejected. The most recent appeal decision, issued by the Planning Inspectorate in September 2021, concluded that the appeal should be dismissed. The reasons in the appeal notice for dismissal should be considered as reasons to reject this site as potentially suitable for development in the RDC Local Plan:
• The site is located in the High Weald Area of Outstanding Natural Beauty (AONB), now called National Landscapes (NL). “The harm identified above to the High Weald AONB provides a clear reason for opposing the development. The presumption in favour of sustainable development contained within paragraph 11 of the Framework is therefore not applicable to this appeal.”
• The site is located outside of the development boundary of the village. “Policy H1 of the Ticehurst Neighbourhood Plan 2018-2028 (the ‘Neighbourhood Plan’) states that the overall spatial strategy is to focus residential development in existing villages, and that no residential development will be allowed outside the villages’ development boundaries unless it requires a countryside location. Policy H1 is consistent with the overall spatial strategy set out in Policy OSS2 of the Rother Local Plan Core Strategy 2014 (the ‘Core Strategy’). The site lies outside any village boundary as defined in the Neighbourhood Plan, and the proposed development does not fall within any of the limited categories of development considered to be appropriate in the countryside in Core Strategy Policies RA2 and RA3. Policy RA3 does support rural exception sites but the proposed development does not fall within the criteria for such sites as set out in Core Strategy Policy LHN3 and the appellant has not sought to argue that it should be considered within this category. The proposal therefore conflicts with the local spatial strategy for the location of development as set out in the development plan.

FW2 should be rejected as a potential development site for the reasons outlined above. It would constitute a major development, which the NPPF resists in National Landscapes. Flimwell does not have the amenities to support a development of this scale. And as outlined in the Planning Inspectorate’s report on Cherry Tree Nursery, it would create harm to the High Weald National Landscape and is situated outside the development boundary of the village.


FW3 - CEDAR FARM, LONDON ROAD
I support the proposed allocation of FW3 (Cedar Farm, London Road) for employment use. This is an appropriate and proportionate form of development for Flimwell and differs materially from the residential allocations proposed for FW1 and FW2.

The site comprises existing agricultural buildings and areas of hardstanding, which the draft Local Plan correctly identifies as suitable for accommodating up to 1,500 sqm of employment floorspace. The approach taken in the draft policy – restricting development to the area currently occupied by buildings, requiring design to reflect the agricultural character of the site, and mandating generous buffers to Ancient Woodland – is justified and appropriate given the site’s rural setting and environmental characteristics.

The supporting text identifies that the site is well contained in the landscape due to surrounding Ancient Woodland, a dense tree belt along the A21, mature trees around the pond, and existing farmstead structures, all of which help to visually screen new development. The Ticehurst Parish Council assessment similarly notes that the land is relatively flat, has no surface water flooding issues, and benefits from an existing access onto the A21, subject to National Highways approval. These characteristics make the site more suitable for development than unconstrained greenfield parcels elsewhere in Flimwell.

While the site is not within walking distance of a settlement, national planning policy recognises that employment development in rural areas may need to be located beyond existing settlements where appropriate. FW3 aligns with this principle by providing an opportunity for small‑scale, landscape‑sensitive rural employment growth in a location already in established agricultural/commercial use. The required ecological safeguards – including a 15‑metre buffer to Ancient Woodland and protection of the pond and trees – ensure that development can proceed without harming the site’s environmental assets.

For these reasons, FW3 represents a sustainable, environmentally responsible, and economically beneficial allocation for rural employment development, while maintaining the character and environmental integrity of the surrounding High Weald National Landscape.

FW2: The proposed density of occupation is completely unacceptable in such a small community, we do not have the infrastructure to support such a large increase in population. Additionally the proposal would see closure of The Nursery, a recently established and much desired local amenity, one of only about 3 retail outlets we have access to. Further the current bane of resident's lives - the traffic light junction with the A21 - could not sustain the additional volume of traffic without some sort of major bypass...which would itself need to go through the proposed new housing sites. In fact developing the sites would preclude future improvements to traffic flow along this major artery.

See attached.

Flimwell is a small linear village straddling the A21 having approx. 250 residential homes. It is in an area of outstanding natural beauty with large areas of ancient woodland and a haven for wild life habitat. The current plan has identified 3 sites and proposes the building of 146 new homes. My understanding is that planning for residential development in rural communities has to be proportionate! While we all have to accept modest and sympathetic development to the natural surroundings an increase in houses of over 50% is wholly disproportionate. Then there is the problem of infrastructure; the village has no school, no doctors surgery and virtually no shops. The potholed roads are already over congested with the lights at Flimwell crossroads a notorious bottle neck. As regards the proposed sites; Fruitfields has already accepted a modest development of 10 houses. The designated area proposed for new development is on a steeply sloping site with access on to a very busy road and is wholly unsuitable. The other proposed two sites to the east of the traffic lights have in the past been undeveloped to allow for the A21 to benefit from a much needed upgrade. No upgrade with the development of a further 40 plus houses would just exacerbate an already congested situation.

I object to the proposed allocation of Site FW1 at Flimwell.

The site lies adjacent to ancient woodland at Wardsdown Wood, an irreplaceable habitat protected under the National Planning Policy Framework. Development here would result in unacceptable indirect impacts, including recreational pressure, lighting, and hydrological change. No wholly exceptional circumstances have been demonstrated to justify such harm.

The site is also within the High Weald AONB, where great weight must be given to conserving landscape character. The proposal would erode the rural, woodland-edge setting and extend development beyond the established settlement boundary in an unsustainable form.

Furthermore, the allocation conflicts with local and neighbourhood plan objectives and is inconsistent with previous refusals in this location.

For these reasons, Site FW1 should not be included in the Local Plan.

W1: This site is unsuitable for a large development of houses. The field proposed for development is a habitat for wildlife and is adjacent to an area of protected ancient woodland.
The proposed ideas to limit light emissions would be insufficient and therefore affect local wildlife.
There are limited footpaths to schools,shops etc; thus resulting in more cars having to be used. The time waiting at the A21 junction for the lights to be in Flimwell/Ticehurst favour can be more than 10 minutes already. Further development on such a scale is not sustainable.
The doctor’s surgery in Ticehurst has been closed which means anyone requiring a Doctor would need to travel to Hawkhurst, Wadhurst or Lamberhurst. All of which are already under strain.
Public transport comprises of one bus an hour.

The Local Plan should not be fixated on house numbers alone, it needs to consider the size of the community within the vicinity and the infrastructure within the area.
This development, along with the development proposed for FW2, is disproportionate and in conflict with national policy protecting ANOB

I object to the proposed allocation of Site FW1 at Flimwell.
The site lies adjacent to ancient woodland at Wardsdown Wood, an irreplaceable habitat protected under the National Planning Policy Framework. Development here would result in unacceptable indirect impacts, including recreational pressure, lighting, and hydrological change. No wholly exceptional circumstances have been demonstrated to justify such harm.
The site is also within the High Weald AONB, where great weight must be given to conserving landscape character. The proposal would erode the rural, woodland-edge setting and extend development beyond the established settlement boundary in an unsustainable form.
Furthermore, the allocation conflicts with local and neighbourhood plan objectives and is inconsistent with previous refusals in this location.
For these reasons, Site FW1 should not be included in the Local Plan.

I object to the proposed allocation of Site FW1 at Flimwell.

The site lies adjacent to ancient woodland at Wardsdown Wood, an irreplaceable habitat protected under the National Planning Policy Framework. Development here would result in unacceptable indirect impacts, including recreational pressure, lighting, and hydrological change. No wholly exceptional circumstances have been demonstrated to justify such harm.

The site is also within the High Weald AONB, where great weight must be given to conserving landscape character. The proposal would erode the rural, woodland-edge setting and extend development beyond the established settlement boundary in an unsustainable form.

Furthermore, the allocation conflicts with local and neighbourhood plan objectives and is inconsistent with previous refusals in this location.

For these reasons, Site FW1 should not be included in the Local Plan.

Summary
I object to the proposed allocation of Site FW1 at Flimwell.
The site lies adjacent to ancient woodland at Wardsdown Wood, an irreplaceable habitat protected under the National Planning Policy Framework. Development here would result in unacceptable indirect impacts, including recreational pressure, lighting, and hydrological change. No wholly exceptional circumstances have been demonstrated to justify such harm.
The site is also within the High Weald AONB, where great weight must be given to conserving landscape character. The proposal would erode the rural, woodland-edge setting and extend development beyond the established settlement boundary in an unsustainable form.
Furthermore, the allocation conflicts with local and neighbourhood plan objectives and is inconsistent with previous refusals in this location.
For these reasons, Site FW1 should not be included in the Local Plan.

Representation – Site FW1: Land rear of Fruitfields, High Street, Flimwell
1. Introduction
This representation relates to Site FW1. While commenting on this site specifically, it is essential that it is assessed cumulatively alongside other proposed allocations in Flimwell and Ticehurst (FW1, FW2, FW3, TC1 and TC2).
The objection is not to development in principle, but to the scale, form and cumulative impact of development proposed in this location.
________________________________________
2. Cumulative Impact and Justification
The proposed allocation of approximately 32 dwellings on this site must be considered in the context of multiple allocations within Flimwell and nearby Ticehurst.
When assessed cumulatively, the scale of development proposed in this locality is not justified and risks placing disproportionate pressure on rural infrastructure and the local road network. The Sustainability Appraisal does not appear to adequately assess these cumulative impacts across the combined allocations.
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3. Highway Safety and Access
The proposed access onto Union Street raises significant highway safety concerns.
• Although subject to a 30mph limit, actual vehicle speeds are frequently higher.
• There are known periods, particularly during morning peak hours, where low sun significantly reduces visibility along this east–west route.
• The addition of traffic associated with 32 dwellings would materially increase movements at a location where visibility and driver behaviour are already constrained.
In addition:
• Pedestrian connectivity is poor, with limited safe walking routes and a lack of continuous footways.
• Crossing the nearby A21 presents a significant barrier and safety concern, with a recent fatality highlighting the risks.
The Sustainability Appraisal appears to rely on theoretical accessibility measures and does not adequately reflect real-world highway conditions, including speed, visibility and pedestrian safety. This conflicts with national policy requiring safe and suitable access for all users.
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4. Sustainability of Location
The site is not well located in relation to services and employment.
• There are very limited local facilities within Flimwell, with most day-to-day needs requiring travel to Ticehurst or beyond.
• There is a high likelihood that future residents would be dependent on private vehicles for employment, shopping and services.
Pedestrian access to nearby settlements is constrained by:
• High traffic speeds
• Lack of pavements
• Unsafe walking conditions along key routes
This raises concerns that the development would result in car-dependent patterns of living, which is inconsistent with the principles of sustainable development.
________________________________________
5. Character, Density and Landscape Impact
The site lies within the High Weald National Landscape, where great weight should be given to conserving and enhancing landscape character.
• The proposal represents a form of backland development, which is not characteristic of the existing settlement pattern.
• The developable area is constrained to the southern portion of the site, yet the allocation proposes approximately 32 dwellings, raising concerns about overdevelopment and density.
In addition, the topography of the site is a significant constraint:
• The land falls away from the crest at the road frontage.
• Development on higher ground would likely result in overlooking of existing properties to the south.
• Conversely, new dwellings on lower ground would themselves experience reduced privacy and enclosure.
This raises concerns that it will not be possible to achieve a form of development that:
• Protects residential amenity
• Respects landscape character
• Avoids an urbanising effect in a sensitive rural setting
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6. Biodiversity and Environmental Sensitivity
The site is adjacent to ancient woodland and priority habitat, and is already recognised as environmentally sensitive.
In addition:
• The area is known locally to support rare mosses and lichens, which have been identified by botanists.
• Such species are typically highly sensitive to:
o Changes in light levels
o Air quality
o Disturbance
o Hydrological changes
While the policy refers to buffers and protection, there is insufficient evidence that:
• These sensitive ecological features have been fully assessed
• Development can proceed without harm to biodiversity
This raises concerns regarding compliance with policies relating to biodiversity conservation and enhancement.
________________________________________
7. Loss of Informal Green Space and Recreational Use
The site currently provides informal recreational value, including a well-used track providing access to woodland beyond.
• This route is regularly used by local residents, including dog walkers.
• The development would result in the loss or significant alteration of this valued green space and its accessibility.
While public opinion alone is not a material planning consideration, the loss of accessible informal green space and recreational routes is relevant in planning terms and contributes to the character and function of the area.
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8. Flood Risk and Drainage
The site includes areas vulnerable to surface water flooding, particularly toward the north and northeast.
While Sustainable Drainage Systems (SuDS) are proposed, there is limited evidence that:
• These measures can effectively mitigate risk in combination with development
• Downstream impacts, including toward the River Bewl, have been fully assessed
This is particularly important when considered cumulatively with other proposed developments.
________________________________________
9. Suggested Approach
A more appropriate approach would be:
• A reduction in the number of dwellings on this site
• Development that is more responsive to site constraints, including:
o Lower density
o Greater separation distances
o Retention of meaningful green space
• Consideration of housing that better reflects local needs
In addition, any development should be supported by:
• Traffic calming measures
• Improved pedestrian safety and connectivity
________________________________________
10. Conclusion
While limited development on this site may be acceptable in principle, the proposed scale of approximately 32 dwellings is not justified given the constraints of the site and its wider context.
The proposal raises significant concerns in relation to:
• Highway safety
• Sustainability
• Landscape impact
• Residential amenity
• Biodiversity
• Loss of informal green space
Accordingly, the allocation should be reduced in scale, and the cumulative level of development proposed in this area should be reconsidered.

Representation – Site FW2: Hawkhurst Road, Flimwell (FW2a & FW2b)
1. Introduction
This representation relates to Site FW2 (FW2a and FW2b). While commenting on this site specifically, it is essential that it is assessed cumulatively alongside other proposed allocations in Flimwell and Ticehurst (FW1, FW2, FW3, TC1 and TC2).
The objection is not to development in principle, but to the scale, distribution and cumulative impact of development proposed in this location.
________________________________________
2. Scale and Strategic Nature of the Allocation
FW2 represents a substantial, strategic allocation comprising:
• Approximately 114 dwellings
• Employment floorspace
• Retail and community uses
• Associated infrastructure
This scale is disproportionate to the role and function of Flimwell as a small rural settlement. When considered cumulatively with other allocations, the level of growth is excessive and not justified by the evidence base.
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3. Separation by the A21 and Lack of Integration
The site is physically separated from the main part of Flimwell by the A21 trunk road, creating a significant barrier to movement.
• Crossing the A21 is difficult and presents safety concerns
• The site is not well integrated with existing community facilities
• Residents are likely to rely on vehicles even for short trips
The proposed mixed-use approach does not overcome this fundamental constraint and risks creating a detached, car-dependent development.
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4. Highway Safety and Junction Capacity
The proposed access arrangements raise serious concerns.
• Access onto Hawkhurst Road is located close to a busy, signal-controlled A21 junction
• Hawkhurst Road is subject to a 50mph speed limit, creating a challenging environment for vehicles entering and exiting the site
Specific concerns include:
• Unsafe right-turn movements into fast-moving traffic
• Difficulty for vehicles exiting the site, particularly during peak periods
• Risk of queuing and obstruction of the highway
The scale of development, including residential and employment uses, would significantly increase traffic flows and place additional pressure on an already constrained junction.
The requirement for future assessments does not overcome the absence of clear evidence that safe and suitable access can be achieved.
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5. Pedestrian Safety and Connectivity
Pedestrian infrastructure in this location is currently inadequate:
• Footways along Hawkhurst Road are narrow and poorly separated from high-speed traffic
• The road environment is not conducive to safe walking or cycling
• Key local destinations, including the church, are difficult and unsafe to access on foot
Any development of this scale would require:
• Significant widening of footways
• Physical separation from the carriageway
• Provision of safe crossing points, particularly in relation to Hawkhurst Road and connections toward the A21
Without these improvements, the development would fail to provide safe and convenient movement for pedestrians, contrary to policy requirements.
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6. Internal Layout and Severance
The division of the site across Hawkhurst Road creates inherent design and safety issues.
• Residential areas, play space and community uses are split across a busy road
• This requires regular crossing movements, including by children accessing recreational space (LEAP)
Without high-quality, safe crossing infrastructure, this layout:
• Creates safety risks
• Reduces usability of community facilities
• Fails to deliver a coherent and well-integrated development
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7. Lack of Evidence for Retail and Community Need
The proposal includes provision for a new community facility and retail use. However, there is no clear evidence of need or viability.
• A recently constructed village/community hall already exists at Corner Farm Close
• A retail unit delivered as part of that development has struggled to attract or retain a viable occupier
This reflects the reality that:
• The local population is relatively small
• The area is highly car-dependent
• There is insufficient footfall to support additional retail provision
As such:
• Additional retail and community space risks being redundant or unviable
• The mixed-use justification for the site is weakened
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8. Loss of Existing Employment Use and Viability Concerns
The site currently accommodates an existing business (including the smokery), which contributes to local employment and is viable in its current form.
This viability is dependent on:
• Direct and highly visible access from Hawkhurst Road
• The availability of substantial on-site parking
• Its ability to attract passing vehicular trade in a car-dependent area
The proposed mixed-use development does not provide any assurance that these critical characteristics can be retained.
In practice:
• Higher-density development is likely to constrain parking provision
• Internalisation of uses within the site may reduce visibility and accessibility
• Replacement employment or retail uses may not be viable without equivalent frontage and access
As a result, there is a significant risk that:
• A viable existing business is lost
• Replacement uses fail to establish or remain viable
Any meaningful retention or replacement of employment or retail uses would require:
• Low-density development
• Direct frontage and visibility onto Hawkhurst Road
• Adequate parking provision
These requirements appear incompatible with the scale and density currently proposed.
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9. Landscape and Environmental Constraints
The site lies within the High Weald National Landscape and is subject to multiple constraints:
• Proximity to ancient woodland
• Presence of historic field boundaries and mature trees
• Sloping topography and sensitivity of long-distance views
While mitigation measures are proposed, the scale and density of development raise concerns that:
• The character of the landscape will be eroded
• The development will appear suburban in form
Great weight should be given to conserving and enhancing landscape character, which this proposal risks undermining.
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10. Loss of Strategic Opportunity
It is understood that this land has previously been considered in the context of potential transport improvements, including a bypass to alleviate traffic through Flimwell.
Development of this site could:
• Prevent or constrain future infrastructure solutions
• Lock in existing traffic and congestion issues
This represents a significant long-term consideration that does not appear to have been fully assessed.
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11. Cumulative Impact
When considered alongside FW1, FW3 and the TC allocations:
• Traffic impacts are compounded
• Pressure on the A21 junction increases
• Infrastructure demands increase
• The rural character of the area is significantly altered
The Sustainability Appraisal does not adequately assess these combined impacts, representing a key weakness in the plan.
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12. Suggested Approach
A more appropriate approach would be:
• Removal of FW2b from the allocation
• A substantial reduction in the scale of FW2a, focused on:
o Smaller-scale, locally appropriate housing
o Affordable housing aligned with local needs
In addition:
• Access should be located as far as possible from the A21 junction
• Hawkhurst Road should be subject to:
o Reduced speed limits
o Improved pedestrian infrastructure and safe crossings
• Stronger safeguards should ensure:
o Retention of viable employment uses with appropriate access and parking
o Avoidance of unviable retail/community provision
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13. Conclusion
FW2 represents a large-scale and poorly integrated allocation in a constrained rural location.
The proposal raises significant concerns in relation to:
• Highway safety and junction capacity
• Pedestrian safety and connectivity
• Lack of demonstrated need and viability for retail and community uses
• Loss of existing viable employment
• Landscape impact
• Cumulative effects with other allocations
Accordingly, the allocation should be significantly reduced, with FW2b removed and FW2a reconsidered in scale and form.

I wish to register my strong objection to the proposed FW1 construction of 32 dwellings on this site.
The land is surrounded by Ancient Woodland that supports abundant wildlife, including rare bat species.
The Woodland Trust has worked with the landowners to restore the area using traditional tree varieties, and this development would undermine years of environmental stewardship.
The site also lies on a flood plain, raising serious concerns about run‑off, pollution, and long‑term ecological damage.

Flimwell has no adequate infrastructure to support all this or any other development of this scale. There is limited access to doctors, school places, and public transport. There is limited access to this proposed site.
The existing homes in Fruitfields would directly overlook the entire development, causing significant loss of privacy in the development.

Given the environmental sensitivity and infrastructure constraints, more suitable sites should be considered.

I object to the proposed allocation of Site FW1 at Flimwell.
The site lies adjacent to ancient woodland at Wardsdown Wood, an irreplaceable habitat protected under the National Planning Policy Framework. Development here would result in unacceptable indirect impacts, including recreational pressure, lighting, and hydrological change. No wholly exceptional circumstances have been demonstrated to justify such harm.

The site is also within the High Weald AONB, where great weight must be given to conserving landscape character. The proposal would erode the rural, woodland-edge setting and extend development beyond the established settlement boundary in an unsustainable form.

Furthermore, the allocation conflicts with local and neighbourhood plan objectives and is inconsistent with previous refusals in this location.

For these reasons, Site FW1 should not be included in the Local Plan.

I object to the proposed allocation of Site FW1 at Flimwell.

The site is located adjacent to ancient woodland at Wardsdown Wood, which is an irreplaceable habitat protected under the National Planning Policy Framework. Development in this location would lead to unacceptable indirect impacts, including increased recreational pressure, light pollution, and potential changes to local hydrology. No wholly exceptional circumstances have been demonstrated that would justify this level of harm.

In addition, the site lies within the High Weald AONB, where significant weight must be given to conserving and enhancing the landscape. The proposed development would harm the rural character of the area, particularly the sensitive woodland-edge setting, and would extend the settlement beyond its established boundary in an unsustainable manner.

The allocation conflicts with local and neighbourhood plan policies and is inconsistent with previous planning decisions at this location.
Site FW1 should not be included in the Local Plan.