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

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.