Comments following the Public Forum

1. What is the basis for requiring Etchingham to provide 70 new dwellings?
2. Is the assumption that there is a lack of housing in the locality for local people or that there are work/business needs that are the generators or is it assumed that new residents would be using the local train station to access work? If the latter it should be noted that Etchingham station car parks are almost completely full now on every week day. Given that there is a very large number of new houses proposed for Burwash and Hurst Green this just exacerbates the problem.
3. Was the 2017 Neighbourhood Plan study on which I served as an architect on the Sub-Committee properly reviewed with its recommendations for housing layouts on the various sites?
4. If, and we say if, the figure of 70 is non negotiable what research was undertaken in advance to check on the following:
- Availability of brownfield as opposed to greenfield sites
- Topography
- Capacity of schools
- Capacity of Doctors surgeries and local dispensing pharmacies.
- Adequacy of existing drainage, water supplies, electricity; were local utilities consulted?
- Traffic and access points onto the main A265
- Etchingham only has a very small general store/post office and no other shops
5. Why has the Lambing Shed site not been considered as our study showed it to be a logical brownfield site for 10 starter homes always a much needed requirement? This should be included and should be either Local Authority or Local Housing Association not developer provided.
6. Why has the Crane site not been considered? Our suggested layout addressed the flood plain
7. We do not want the usual costly pastiche designs provided by developers; there is far too much locally. It should be a requirement that architects with considerable housing experience are used.

Response to HELAA Assessment - Site TIC0039, Land at Broom Hill, Flimwell

Please find attached my representation regarding Site TIC0039 – Land at Broom Hill, Flimwell, submitted in response to the conclusions reached within the Northern Housing and Employment Land Availability Assessment (HELAA).

Having reviewed the HELAA assessment alongside the treatment of other sites within Flimwell, I remain concerned that the conclusions reached in relation to TIC0039 do not appear to reflect the revised and significantly reduced proposal that has been submitted, nor do they appear to have been applied consistently when compared with the assessment of other potential development sites in the same settlement.

As set out in the attached representation, the proposal now relates only to a small parcel of land capable of delivering approximately six dwellings, positioned immediately adjacent to existing residential development at Bewl Bridge Close. The scheme has been deliberately reduced in scale in order to respond to earlier concerns and to ensure that development would represent a modest rounding-off of the existing settlement edge, rather than an extension into open countryside.

The representation also highlights that Site TIC0039 performs favourably when compared with other Flimwell HELAA sites, particularly in relation to its settlement relationship, its separation from ancient woodland, and its ability to deliver a modest and early contribution to housing supply.

Given the requirement for the emerging Local Plan to demonstrate that site selection has been undertaken on a consistent and transparent basis when compared with reasonable alternatives, I would respectfully request that the Council review the conclusions reached in relation to TIC0039 and ensure that the site is assessed alongside other Flimwell sites on an equivalent basis.

Executive Summary:

• Site TIC0039 represents a small and contained extension to the existing settlement at Bewl
Bridge Close, forming a logical rounding off of the village edge rather than an intrusion into open
countryside.
• The revised proposal relates to a significantly reduced developable area and a modest scheme
of approximately six dwellings, materially reducing any landscape or environmental impact
previously associated with the wider landholding.
• The site is located approximately 90 metres from the nearest ancient woodland, significantly
exceeding Natural England's recommended 15 metre buffer and therefore presenting no direct
constraint to development.
• Compared with other Flimwell sites assessed in the HELAA (including TIC0027, TIC0029 and
TIC0097), TIC0039 demonstrates a stronger relationship with the existing settlement and fewer
landscape and deliverability constraints.
• The site is available and deliverable and could contribute to the early years of the housing
supply, helping the Council demonstrate that the Local Plan strategy is justified and capable of
meeting housing needs.

Introduction:

This representation responds to the Council's conclusion within the Northern Housing and
Employment Land Availability Assessment (HELAA) that Site TIC0039 - Land at Broom Hill,
Flimwell is unsuitable for development.

The conclusions reached in the HELAA appear inconsistent with both the evidence submitted in
support of the site and the assessment of comparable sites within Flimwell. When assessed against national planning policy and the Local Plan's obligation to identify the most appropriate and deliverable sites, the rejection of TIC0039 cannot reasonably be justified.

1. Logical and contained extension to the existing settlement:

The land at Broom Hill sits directly adjacent to existing residential development at Bewl Bridge Close and therefore forms a continuation of the village edge. The revised proposal relates only to the eastern portion of the wider landholding and represents a rounding off of the settlement rather than an extension into open countryside.

The concept scheme indicates approximately six low-density dwellings designed to minimise visual impact and maintain the existing ridgeline when viewed from the wider landscape.

2. Revised site submission
The HELAA assessment appears to rely on the earlier submission of approximately 2.9 hectares.
The revised proposal significantly reduces the developable area.

A scheme of approximately six dwellings has materially different impacts and allows landscape
buffering, vegetation retention and biodiversity enhancement while integrating with the existing
settlement edge.

3. Landscape considerations:

The design approach has been informed by the sensitivity of the High Weald National Landscape. Building heights are limited, existing vegetation is retained and new structural planting can be introduced. Additional land under the same ownership can provide further landscape buffering and Biodiversity Net Gain enhancements.

4. Ancient woodland relationship:

The nearest ancient woodland lies approximately 90 metres from the proposed development area, significantly exceeding the 15 metre buffer recommended by Natural England guidance. This separation ensures development can occur without harm to woodland assets.

5. Green Gap considerations:

The Ticehurst-Flimwell Green Gap originates from the Ticehurst Neighbourhood Plan and aims to prevent ribbon development between settlements. The proposal does not extend development toward Ticehurst nor reduce the separation between settlements and instead represents a modest rounding off of the existing village edge.

6. Consistency in site selection:

When compared with other Flimwell sites such as TIC0027, TIC0029 and TIC0097, TIC0039
demonstrates a stronger relationship with the existing settlement and fewer landscape concerns while delivering a modest housing contribution.

7. Deliverability:

Rother District faces a significant housing shortfall. TIC0039 is available, accessible from Broom Hilland capable of delivering a modest housing scheme within the early part of the plan period, including potential self-build opportunities.

Conclusion:

In light of the points set out above, it is respectfully requested that the Council reconsider the
conclusions reached in the HELAA assessment of Site TIC0039. The site represents a modest and deliverable opportunity for housing that performs favourably when compared with other potential sites in Flimwell.

Reconsideration of the site will assist the Council in demonstrating that the emerging Local Plan has been prepared in a manner that is positively prepared, justified and consistent with national planning policy, ensuring that the strategy can withstand scrutiny at the forthcoming Local Plan Examination.

Question 63 - Other Possible Sites in the Northern Rother Sub-Area
Position
The Parish Council does not propose any additional sites for allocation in Hurst Green. The sites
already committed - HG1 and HG2, totalling 54 dwellings - adequately meet the locally evidenced
level of housing need. The principle of HG3 is supported subject to modification. HG4 should be
deleted.
Why No Additional Sites Are Proposed
It would be inconsistent for HGPC to argue that the proposed scale of growth at Hurst Green is
unjustified and then propose additional sites that would increase growth further. The Council's case is
that housing provision should be evidence-led.
The constraints that apply to HG4 apply equally to any other significant greenfield site at the edge of
Hurst Green:
• The entire village and its surroundings lie within the High Weald National Landscape, where
major development requires exceptional circumstances.
• The A21 presents a documented and serious pedestrian safety constraint that limits the ability of
any significant site to the north of the village to function sustainably.
• Car dependency exceeds 90% and there are no realistic prospects for material improvement in
public transport or active travel within the plan period.
• The Hurst Green Neighbourhood Plan, recently made following community referendum,
establishes a clear framework for appropriate development in the village. That framework should
be the starting point for any assessment of additional sites.
Employment Land Must Not Be Treated as a Housing Alternative
HGPC notes that some representations may suggest that protected employment sites within the
village should be considered for housing on the grounds that they represent brownfield or previously
developed land. The Parish Council strongly resists this. The Hurst Green Neighbourhood Plan
protects employment sites specifically to preserve local employment opportunities, consistent with the
community’s Neighbourhood Plan Vision which commits to “strongly support local prosperity and will
create a thriving village community, that supports existing and new local businesses.” Releasing
protected employment land for housing would contradict that vision, require overriding the
Neighbourhood Plan, and remove the very limited employment land the village possesses.
Conclusion on Question 63
No additional sites are proposed. HGPC requests that the Council reduces the housing requirement
for Hurst Green to a level justified by local evidence, retains HG1 and HG2, supports HG3 with
modification, and deletes HG4 entirely.

Proposed Vision and development strategy for Northern Rother and site allocations for this area

We feel that land at Station Road, Robertsbridge TN32 5DG should be included in the plan. A map showing the land is attached

We would like to make the following comments:

1. We refer to Strategic Spatial Objective number 11 in the Draft Local Plan: “Deliver sustainable development by making the optimal use of land, including by prioritising the use of brownfield land”
This site is a Brownfield site and meets this criteria of prioritised land

2. The site is approximately .37 hectare and has potential for example for 12 dwellings similar to the existing 4 dwellings at the front of the site

3. There is an existing tarmac road into the site from Station Road and it has existing connected services

4. The site has never been subject to flooding

5. We refer to Part 2 of the Local Plan, Section 3.27 which says: “ In reviewing Rother’s pipeline of employment land supply (i.e., extant planning permissions and adopted site allocations), the HEDNA indicates that there is sufficient capacity in Rother to meet identified needs in full. However, there are variations between sectors, with a sufficient supply (oversupply) expected for office and industrial uses in the district but a shortfall for storage and distribution. Consideration may need to be given to a targeted restructuring of the employment land stock to meet these needs, subject to the findings of the updated HEDNA in 2026.”
Our proposed site has a light industrial unit on it. Given the current supply and expected oversupply of this type of unit, as stated in the Plan, it is likely that within the next 17 years this site will no longer be viable for this purpose and therefore should be included within the Plan as a prospective site for housing

Given the length of time the plan covers and the criteria above we think that this site should be included in the Plan for future potential residential development

See attachments

Please see attached:

- Representations: HUG0016, HUG0019
- Appendix 1 - Committee Report RR/2023/2540/P
- Appendix 2 - Decision Notice RR/2023/2540/P
- Appendix 3 - Appeal 3361707 Decision
- Appendix 4 - Hurst Green Neighbourhood Plan Reg 14

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

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

We object to the omission of the Lambing shed site

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