Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

As the residents property management company for the 30 freehold properties within Frederick Thatcher Place, we wish to comment on the proposed 10 property expansion north of Sunny Rise, Battle under your reference BT6 and on the proposed Almonry Place development under BT7.

Traffic Congestion and Safety on North Trade Road
North Trade Road is already at breaking point. Traffic is backed up every morning and afternoon, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of new 10 dwellings in BT6 and 80 dwellings in BT7. The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding extra volumes without significant infrastructure upgrades is negligent.

Junction Interference and "Staggered" Conflict: At a distance of around 600 metres, these two major junctions will interfere with one another and North Trade Road would inevitably be blocked by "tailback" traffic exiting or entering BT7 (80 dwellings), especially considering that in between BT6 and BT7, Claverham College is located with around 1,150 students being dropped off in the morning and picked up in the afternoon – both of which already causing congestion on North Trade Road, especially with indiscriminate parking on pavements. All this creates a high risk of collisions and accidents as drivers attempt to navigate traffic in such a short span.

The 30mph to 40mph Transition Danger: The site (BT6) sits at a critical point where the speed limit increases / decreases from 30mph to 40mph. This particulary affects the two Frederick Thatcher Place entrances/exits. We have highlighted this problem in previous planning application objections (RR/2020/1875P and RR/2019/2845P).

Adding to volumes in this zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.

2. Environmental Impact and Air Quality

Unjustified Harm to Greenfield Land and the National Landscape (AONB)
Greenfield Loss: BT6 and BT7 propose building on 0.58 and 4.80 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
National Landscape (AONB) Impact: The sites are within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 35 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major developments should only occur in exceptional circumstances (NPPF Paragraph 189).

Heritage Constraints, Ancient Woodland and Deciduous Woodland Priority Habitat:
Frederick Thatcher Place (FTP), which is Grade 2* listed, is not mentioned within the RDC policy text. A serious omission! The BT6 plans negatively impact Grade 2* listed buildings. The Sunny Rise development was designed to blend-in with FTP, as much as possible.
Both the BT6 and the BT7 proposals also threaten and affect Ancient Woodland and Deciduous Woodland Priority Habitat located adjacent to the sites. Wildlife corridors, mature trees and hedging, as well as ancient woodland would be severed by them. The BT7 proposal would have an impact on Grade 2* listed property as well as it's proximity to heritage assets including the Registered Battlefield where the 1066 Battle of Hastings was fought and Battle Conservation Area.

Flooding Risk and Surface Water (NPPF Paragraph 170): The policy texts for BT6 explicitly acknowledge that parts of the site are at risk of surface water flooding. Replacing natural drainage with impermeable surfaces (housing/roads) on land already identified as a flood risk is reckless planning that endangers existing properties, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests. The proposed expansion onto a downward sloping area does not make any sense; Kelk Wood and Beech Estate land would also be affected. FTP already suffers from North Trade Road water run-off, due to a policy of only checking and emptying A271 drainage every 6 months. Thatcher Place Estate Company already faces extra expenditure to try and stop water run-off from North Trade Road.

BT7 land would also be affected with any such development.

Conclusion

These proposals to expand development at BT6 and also BT7, with up to 90 properties on a Greenfield National Landscape site, both with Grade 2* listed buildings, risks of surface water flooding and threatening ancient buildings are unsound. They ignore statutory environmental considerations and local experience. We urge Rother District Council to remove development pressure from this area before progressing the plans further.