Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27373

Received: 22/07/2024

Respondent: Catsfield Parish Council

"Rother District will be an attractive, desirable and affordable place to live, work and visit."
Answer: Agreed, this a desirable Vision. There is however a fundamental problem with the application of this policy and other polices in the draft plan because the polices are relevant to urban areas and not to rural areas. For example, the principles of being able to walk or use public transport to access services cannot apply to rural villages other than at a very small scale. There will always be a very large percent of the Parish who are not in walking distance of services and public transport simply does not meet local needs. Large scale developments in village centres would allow more people to walk to some local services but not to most of the services needed. This will also fundamentally and negatively change the character of a Village. We see this in Hellingly where a once small village is now an urban sprawl. This cannot be accepted as a planning policy. A cap on the percentage increase in developments in Villages is needed to protect village communities from over development.

"The needs of all the local community will be met."
Answer: Yes, if true but this is not true as applied ref the proposals for Catsfield. The needs of the community do not include adding 55 houses into the centre of the Village creating a more than 100% increase in housing in the village centre, on High Weald National Landscape land, with no access to sewers, with no or limited access from roadways (decreasing road safety), with no biodiversity gain, on land that regularly floods.

"With an emphasis on enhanced health and wellbeing for now and into the future."
Answer: Yes, if true but this is not true as applied ref the proposals for Catsfield. There is no evidence in the plan that the health or wellbeing of residents in Catsfield will be enhanced. The plan proposes significantly less green field land, foul water flood risks (no sewer connections on the sites proposed require vast sewage tanks to be fitted), risk of death or injury from roads because of access issues. The access to facilities (Water – we already have low water pressure problems), Drainage – Flooding of the fields, roads and houses in the centre of the village happens every year) & Services (Schools, Doctors) both are in short supply – adding +100% capacity to the housing in the village centre will make these issues worse. The increasing in housing for Catsfield is higher than for other similar villages in Rother, and an overwhelming increase to the housing totals for the Village. This does not support enhanced wellbeing or health.

"Bold solutions will have successfully addressed the climate and biodiversity emergencies and the housing crisis while protecting the High Weald National Landscape, our designated habitats, our heritage and our flood risk areas."
Answer: Yes, if true but this is not true as applied ref the proposals for Catsfield.
• Net zero new housing is fine, but not at this scale, it overpowers the village, our social and community structure cannot cope with development on this scale. Two of the large sites proposed will reduce biodiversity. There is biodiversity net loss by building on green fields at this scale.
• 2 of the 3 sites proposed in the HEELA are within the High Weald National Landscape. (Criteria for refusing similar sites also apply to these sites but have not been applied)
• All 3 of the sites have flood risks.

Comment

Representation ID: 27374

Received: 22/07/2024

Respondent: Catsfield Parish Council

Overall Priority 1 – Green to the Core.
"Being Green to the Core means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald Area National Landscape."
Answer: Yes, if true but this is not true as applied ref the proposals for Catsfield. The proposed developments CAT0001 and CAT0016 are both large and within the High Weald Area National Landscape, these sites are highly valued by the local community, any development will have a significant negative impact on the environment and biodiversity. There should be an exceptional reason for allowing these sites in the HEELA, if not, and there is no exceptional reason, the policies stated here do not align with the HEELA.

"Contributing to the radical reduction in carbon emissions required by national planning policy through planning for sustainable transport."
Answer: Adding housing at these scales in Catsfield will not contribute to a reduction in carbon emission from transport. All residents of the village need cars to travel for work, social needs or to simply get supplies needed for living. The local bus service cannot and does not meet this need. The flexibus does not serve Catsfield. To contribute to a reduction in carbon though transport it will be necessary to either make public transport relevant to rural areas or build more houses in towns where there are multiple services that can be accessed by public transport or by cycle or on foot. The services in Catsfield that can be accessed by public transport or on foot. (Shop, Pub, School) are used locally but represent a tiny percent of the services used by residents. Residents in the Parish of Catsfield and in the Village will still have to use cars to access almost all services and work. This policy simply cannot apply to Catsfield.

"Net zero housing and renewable energy."
Answer: Agreed.

"Playing a key role in the UK’s nature recovery and carbon sequestration through enhancing our landscape and environmental assets."
Answer: This will not be achieved by digging up green fields, unless there is a proven net gain, which there is not in Catsfield. We should not therefor be including sites in the HEELLA that do not align with policy.

"In tandem with the Climate Emergency, there is a biodiversity crisis. The Environment Act 2021 includes a target to halt the decline of nature by 2030, and mandates Biodiversity Net Gain for developments."
Answer: This will not be achieved by digging up green fields, unless there is a proven net gain, which there is not in Catsfield. We should not therefor be including sites in the HEELLA that do not align with policy.

"Rother’s rural landscape and coastal environment can play a key role in the nation’s nature recovery. It also makes a strong contribution to carbon sequestration."
Answer: Reduce the development scale, to minimise the impact on the environment. There are brown field sites that have been rejected.

Overall Priority 2 – Live Well Locally
"The Live Well Locally concept means considering, when making all planning decisions, the goal of creating: Healthy, sustainable and inclusive communities that support residents across the age spectrum in terms of housing, access to jobs, services and facilities. ‘Connected and compact
neighbourhoods’ in our towns with ‘village clusters’ in our rural locations, where people can meet most of their daily needs within a reasonable distance of their home, with the option to walk, wheel, cycle (active travel) or use public transport. New development that creates places that are not just visually appealing, but also inspire and foster a sense of belonging, identity, and shared experience."
Answer: We can create Healthy, sustainable and inclusive communities that support residents across the age spectrum if the required development does not overwhelm the exiting community, and IF developments and investment do deliver improved Healthy, sustainable and inclusive communities. The proposals in the local plan will not achieve this aim, the scale is too high for our Village to provide for improvements across the community. The scale of development for Catsfield is far higher than for other Villages in Rother of our size. The strategic driver should be for the stated sustainability but appears to be driven by allocating the available land only to achieve a housing quota.
Answer: Access to jobs, services and facilities as priority is fine if its relevant. The local plan states that no jobs will be created in Catsfield by building these houses.
Anyone living here will still need to travel to a job, by car. Services and Facilities as noted above are not available locally and will still be accessed by car.
“Village Clusters” may look practical with achievable net gains on paper but where is the evidence that “clustering” is a proven strategy and not just a trending idea? The assumption is that by clustering with a town or large village in the local mapped area there will be a net gain where “where people can meet most of their daily needs within a reasonable distance of their home, with the option to walk, wheel, cycle (active travel) or use public transport”. This is simply not true when applied to Catsfield. Most of the daily needs of most people in the Parish of Catsfield require the use of a car. Most of the needs of the residents in the Village of Catsfield require the use of a car. (The availability of a local Shop & Pub and School do not meet the needs of most people). Most of the shop customers arrive by Car. Most school children arrive by car, most pub users arrive by car.
Wheeling or Cycling require safe road spaces to wheel or cycle on. The roads around Catsfield are not safe. Cycling to Battle for example is dangerous, there are no cycle lanes and fast-moving traffic. Using public transport is simply not viable. (Too infrequent, only in the daytime, expensive, slow, only destinations are Battle and Bexhill) note no Flexibus service in Catsfield. The number of passengers (other than the school bus) using local transport will show how unpractical this option is.

Live well locally is fine ambition but the local plan will not deliver this for Catsfield, and the stated goal does not support the need for development that will destroy our environment without upside gains.

Comment

Representation ID: 27375

Received: 22/07/2024

Respondent: Catsfield Parish Council

Answer: Access to jobs, services and facilities as priority is fine if its relevant. The local plan states that no jobs will be created in Catsfield by building these houses.
Anyone living here will still need to travel to a job, by car. Services and Facilities as noted above are not available locally and will still be accessed by car.
“Village Clusters” may look practical with achievable net gains on paper but where is the evidence that “clustering” is a proven strategy and not just a trending idea? The assumption is that by clustering with a town or large village in the local mapped area there will be a net gain where “where people can meet most of their daily needs within a reasonable distance of their home, with the option to walk, wheel, cycle (active travel) or use public transport”. This is simply not true when applied to Catsfield. Most of the daily needs of most people in the Parish of Catsfield require the use of a car. Most of the needs of the residents in the Village of Catsfield require the use of a car. (The availability of a local Shop & Pub and School do not meet the needs of most people). Most of the shop customers arrive by Car. Most school children arrive by car, most pub users arrive by car.
Wheeling or Cycling require safe road spaces to wheel or cycle on. The roads around Catsfield are not safe. Cycling to Battle for example is dangerous, there are no cycle lanes and fast-moving traffic. Using public transport is simply not viable. (Too infrequent, only in the daytime, expensive, slow, only destinations are Battle and Bexhill) note no Flexibus service in Catsfield. The number of passengers (other than the school bus) using local transport will show how unpractical this option is.

Live well locally is fine ambition but the local plan will not deliver this for Catsfield, and the stated goal does not support the need for development that will destroy our environment without upside gains.

Comment

Representation ID: 27376

Received: 22/07/2024

Respondent: Catsfield Parish Council

"Delivering carbon reduction and adaptation to climate change, and responding to the locally declared ‘Climate Emergency’."
"meeting the overall local demand and need for housing (including affordable and specialist need) and associated growth – taking a landscape and sustainability led approach across the district."
Answer: Fine if true but not true for Catsfield. We need more affordable housing in small plots not new housing estates that do not fit with the character of our village and of a scale that will overwhelm our community. We could build market value housing in small scale developments and use small exception sites to build high quality affordable housing in partnership with the Parish Council. This would meet the need for housing, be deliverable and meet the carbon reduction ambition.

"Providing better access to jobs, services and facilities across the district, and specifically supporting rural economies and communities, making them more sustainable, through meeting the needs of residents and visitors."
Answer: Fine if true but not true for Catsfield. Where in the local plan will I find this support and access to jobs?

"Conserving and enhancing the significant landscape and environmental quality across the district, particularly the High Weald National Landscape (AONB)."
Answer: The local plan for Catsfield does the exact opposite, we lose two important and valued green spaces and gain over scaled housing estates that risk polluting the water tables and destroying local wildlife!

"Delivering district-wide and neighbourhood infrastructure to support growth and strengthening the sustainability of settlements and communities."
Answer: Fine if true but not true for Catsfield. Where in the local plan will I find how this will be delivered? New Schools? New access to medical care? Capacity increasing for water supply and drainage? Improved power supply? Improved fast broadband?

"Planning for physical and mental health and wellbeing by supporting strong, safe and sustainable communities, with a community-led focus, promoting healthier lifestyles, reducing inequality and deprivation."
Answer: Fine if true but not true for Catsfield. Where in the local plan will I find how this will be planned How can the scales of the increase in housing in our village be sustainable?

"Planning for an ageing population, responding to the needs for adaptable homes and a range of accommodation needs."
Answer: If sustainable development in our village achieves this, then all good.

"Providing better facilities for sports, leisure, culture and tourism to meet the needs of the local community and those visiting the area."
Answer: Where in the local plan will I find how this will be planned & delivered? Sounds good but make no sense for our village and other villages. We still need to travel to these if they are available, or we could use CiL funding (our own plus contributions from the central pot) to improve our village facilities.

"Managing uncertainties and contingency planning, including long-term climate change resilience."
Answer: OK.

Comment

Representation ID: 27377

Received: 22/07/2024

Respondent: Catsfield Parish Council

Answer: The 10 Objectives are laudable. The challenge as always is how to implement plans to achieve these objectives. Achieving such aims in larger communities or Towns, particularly for Hasting and Bexhill is probably directly relevant and these objectives could easily apply where scales and connectivity between larger groups of people exist, but for smaller rural communities and villages
much of this is just corporate gobbledygook, even if well intentioned. If applied fairly and with context to smaller communities these objectives would be fine but given the draft HEELA sites in the plan for Catsfield, it is clear these objectives have not been considered in context and will be made to fit, even where it is clear they do not. Example
Objective 2 - The words do not fit the reality for our community. The HEELA has allocated large green plots in the centre of a village, WHNL, doubling the housing numbers and expect a net gain? This is directly the opposite of the stated objective.
Objective 5 - There is inconsistency in the notes to the sites that have been rejected and those agreed or under consideration for Catsfield. Some areas appear to have been agreed or are being considered even though they don’t fit with these objectives.
Objective 8 - There is no effective local transport that serves Villages. If you count the number of passenger journeys by any transport means and the number by public transport this will give an indication of the practical use of public transport. This is not to say increasing public transport is a bad idea, but it does not work for villages at a scale that can used as a supporting factor or strategy to support housing development in villages.

Comment

Representation ID: 27378

Received: 22/07/2024

Respondent: Catsfield Parish Council

Objective 4 needs to be re-drafted to include “limiting new sustainable developments so that these do not overwhelm existing communities”

Comment

Representation ID: 27379

Received: 22/07/2024

Respondent: Catsfield Parish Council

Broadly agree

Comment

Representation ID: 27380

Received: 22/07/2024

Respondent: Catsfield Parish Council

It is important. Broadly agree

Comment

Representation ID: 27381

Received: 22/07/2024

Respondent: Catsfield Parish Council

See Q5 and opening comments about the policies not being relevant to rural areas.

Comment

Representation ID: 27382

Received: 22/07/2024

Respondent: Catsfield Parish Council

No comment. Not enough info to understand what this means in practical terms.