Full text:
This representation concerns the omission of the reduced eastern parcel of TIC0039, land at
Broom Hill, west of Bewl Bridge Close, Flimwell. It challenges Policy SS2, the proposed Flimwell
development boundary and the Chapter 14 site-selection strategy insofar as they exclude that
parcel. The principal soundness objection is that the Plan is not justified. No separate
legal-compliance objection is made (Question 2 boxes left unticked).
The original promotion covered approximately 2.9 hectares. The revised proposal concerns only
the eastern parcel adjoining housing at Bewl Bridge Close, for approximately six dwellings as
illustrated by the indicative concept plan. A lower number would be considered where justified by technical assessment. The detailed layout and design remain subject to assessment. The concept uses single-storey and 1.5-storey forms and retains the wider holding for proposed environmental mitigation. These characteristics warrant assessment as a reasonable alternative; not every promoted site must be so assessed.
Appendix 6 of the Regulation 19 Sustainability Appraisal lists TIC0039 among excluded HELAA
sites and separately lists TIC0088 as an extension site. These entries do not establish which
boundary, dwelling number and layout were assessed for the reduced proposal. Please identify
that assessment and distinguish it from the wider site and any separate extension promotion.
FW1 allocates 27 homes with woodland buffering, green infrastructure and drainage safeguards
(paragraphs 14.147-14.153). FW3 allocates 35 homes subject to safeguards for woodland, field
boundaries, highways and infrastructure (paragraphs 14.160-14.168). The comparison should
address residual impacts after mitigation and explain any material differences that justify excluding TIC0039.
Map 16 on page 73 of the adopted Ticehurst Neighbourhood Plan 2019, compared with the
Regulation 19 allocation plans, shows FW3 outside the adopted Flimwell development boundary and the enlarged FW1 extending beyond it. Part of FW1 was already included through the neighbourhood plan. Being outside the current boundary cannot, by itself, justify exclusion of TIC0039; its settlement relationship and site-specific impacts require assessment.
Paragraphs 2.8-2.13 identify need for 15,215 homes but provision for 8,671, leaving 6,544 unmet. I acknowledge the constraints and that Policy SS6 says the Ticehurst-area target of 134 homes is met. Nevertheless, the unmet district need makes justified site selection important.
Landscape sensitivity is acknowledged. The earlier representation reports approximately 90 metres to ancient woodland and avoidance of the wider site's material surface-water issue. These claims require testing against the reduced boundary and evidence. Woodland distance alone does not establish acceptability. Landscape, ecology, drainage, access and rights, Green Gap objectives and delivery timing require proportionate assessment.
The published material reviewed does not clearly identify an assessment of the reduced scheme; this is the basis of my objection. Omission alone is not alleged to establish a legal breach. See the access evidence on pages 11-15.
I seek an additional residential allocation for approximately six dwellings, on the reduced eastern parcel of TIC0039, land at Broom Hill, west of Bewl Bridge Close, Flimwell, with a corresponding amendment to the development boundary and Policies Map.
The reduced eastern parcel is proposed for approximately six dwellings, as illustrated by the
submitted indicative concept plan. A lower number would be considered where justified by
technical assessment. The detailed layout and design would remain subject to that assessment.
The Council should:
1. Assess the reduced parcel as a reasonable alternative, clearly identifying its boundary and
development assumptions. Explain its treatment compared with FW1 and FW3 and update the HELAA, site-selection evidence and Sustainability Appraisal as necessary.
2. Include a site-specific allocation requiring low-rise, landscape-led development, retention and enhancement of vegetation, appropriate ecological buffers, biodiversity provision, safe access and sustainable drainage. The proposed allocation would retain the balance of the holding outside the residential allocation for environmental purposes.
3. Amend the development boundary and Policies Map to include the residential parcel and update housing totals and the trajectory, subject to assessment of any reduction in dwelling number and delivery timing.
Suggested allocation wording, subject to technical assessment and the defined reduced parcel:
"The reduced eastern parcel of TIC0039, land at Broom Hill, west of Bewl Bridge Close, Flimwell, is allocated for approximately six dwellings. A lower number would be considered where justified by technical assessment. The detailed layout and design remain subject to that assessment. Development must follow a low-rise, landscape-led approach, informed by technical assessments; retain and enhance important vegetation; provide appropriate habitat buffers and biodiversity measures; and secure safe access and sustainable drainage. The balance of the holding is excluded from the residential allocation and retained for proposed landscape and ecological purposes."
The existing boundary is not treated as fixed for FW1 and FW3. The modification would apply the same assessment principle to TIC0039 while addressing its particular constraints. The comparison alone does not establish suitability. If exclusion is maintained, please identify why the reduced scheme remains unacceptable after mitigation and explain the material differences from the selected Flimwell sites.
Supporting plan: drawing BH.S02, Proposed Site Plan, dated October 2024, is appended at page
10. Its red outline identifies the reduced parcel and its six-dwelling layout is indicative. A lower
number would be considered where justified by technical assessment. No extension of the
reduced parcel is proposed.
Access evidence and limitations are set out on page 11. The proposed access drawings and two
existing topographical survey sheets follow on pages 12-15. They identify a potential access
option and measured existing conditions; residential suitability remains subject to highways
assessment and coordination with the concept plan.
Please see attached supporting evidence document.
