Local Plan Response

I welcome the opportunity to comment on the Draft Local Plan. As well as addressing site specific issues regarding inadequate essential infrastructure, this response focuses on the urgent need for the Plan to recognise and respond to accelerating biodiversity loss, ecosystem degradation, and increasing environmental pressures within Wealden.

In January 2026, the UK Government’s National Security Assessment identified global biodiversity loss and ecosystem collapse as a top tier national security threat. The assessment warns that, by 2030, areas of total ecosystem collapse are anticipated, posing critical risks to food and water supplies, economic stability, and wider national security. Furthermore, a recent University of Oxford study shows that environmental degradation is projected to contract the national economy by 12%. Nature cannot and should not be reduced to GDP equivalents alone, but in a planning system that prioritises economic growth, this value must be weighted.

For rural districts like Wealden the economic impact is substantially greater, because of our reliance on natural spaces and beautiful landscapes for tourism and leisure opportunities. It is an often repeated fact that the UK is one of the most nature‑depleted countries globally. Wealden is becoming an increasingly nature-depleted landscape due to habitat loss, urbanisation, intensive agriculture, and climate change. This context places a clear responsibility on local planning authorities to treat environmental protection with the highest level of priority.

Specifically, Wealden is widely recognised as having the largest amount of ancient woodland of any district in England. The ancient woodlands of the High Weald are irreplaceable habitats, not only vital for their local ecosystems but also serve as a national treasure due to their biodiversity, cultural heritage, and contributions to environmental sustainability. Therefore, we have an essential, nationally important role in protecting their integrity for this and future generations.

The NPPF’s guiding principle is to achieve sustainable development, by balancing economic, social and environmental considerations and by “meeting the needs of the present without compromising the ability of future generations to meet their own needs.” Wealden already shows signs that existing development has exceeded environmental carrying capacity. The district is severely water‑stressed; sewage pollution in waterways is increasing; drinking‑water disruptions and boil‑water notices have become more frequent; and our most protected natural sites are in decline. Indicator species such as otters, eels, sea trout, nightingale, finches, and kingfishers are all experiencing steep or catastrophic falls in population.

These pressures have intensified during the same period in which housing targets have risen sharply – from 450 homes per annum in 2013, to 1,200 in 2023, and now 1,457. Continued escalation at this scale risks further destabilising the fragile ecosystems that remain.

To clarify, development that undermines environmental integrity will not only damage our ecosystems but will also impose severe economic and social costs on local communities. The Local Plan cannot aim to meet national housing targets that are deaf and blind to the evidence on the ground. We have a duty to listen to our residents and adopt a precautionary, evidence‑led approach that places environmental safeguarding at its core. For the reasons above, unfortunately, none of the four spatial strategy options proposed in the sustainability appraisal part 1, Reg 18(2) are acceptable. Spatial strategy 3 & 4 should not be taken forward for consideration at the next stage because they both contain the Owlsbury and the Ashdown Business Park Expansion, which would cause great harm in an environmentally sensitive area of the District (detailed arguments on each are below). Although option 2 does not include Owlsbury and the Ashdown Business Park Expansion, and in that respect would be less harmful, the amount of damage that it would inflict on the rest of the District would be unacceptable, so I agree that this and option 1 option should be rejected.

Ashdown Business Park (OEMP4)

I object to the inclusion of the Ashdown Business Park Expansion either as an allocation or as an option; it should be discounted entirely. The reasons are as follows:

The proposed allocation of the Ashdown Business Park Expansion is unsound, unjustified, and inconsistent with national and local planning policy. This vast, regional-scale site is environmentally constrained, inaccessible, incorrectly evidenced, and fundamentally unnecessary to meet employment land needs. On this basis, the allocation must be removed from the Local Plan.
Fundamental Issues with the Evidence Base – The evidence used to justify OEMP4 is fragmented, internally inconsistent, and in several areas directly contradictory. The Sustainability Appraisal (SA), SHEELA 2026, and Employment & Economic Study 2026 fail to assess the specific OEMP4 option and instead rely on confused combinations of unrelated land parcels. Across all assessments, the proposed site (30–42 ha depending on source) is repeatedly identified as constrained, sensitive, and not deliverable or developable. Yet these findings have not been reflected in the WDLP, which seeks to allocate the land without addressing the very issues its own evidence base identifies as fundamental barriers.
PFAS Contamination Risk – The allocation cannot be considered sound. The area has had decades of the forever chemical or AFFF use at the adjacent Fire Training Facility (established in 1957). This creates a high and unquantified PFAS contamination risk on the site and surrounding land. No borehole, hydrological or contamination surveys have been undertaken. The risk to drinking water, groundwater, the adjacent streams and the River Ouse catchment and nearby sensitive ecosystems is significant and unknown. The Government’s 2026 PFAS Plan requires a coordinated national response and highlights PFAS as a significant public health and environmental threat. The Environment Agency has already raised concerns (17 May 2023). Without quantifying PFAS contamination, the site cannot be demonstrated as “suitable” or “deliverable”. The development market is likely to avoid PFAS-risk sites entirely. In conclusion, the allocation is premature, unsafe, and contrary to the Environment Act and NPPF (paras 119, 174, 180).
Transport Constraints – The site is remote from the strategic road network (A23, A21, A27, M25) and relies solely on the congested, single-carriageway A22/A272 serving rural villages. Public transport is poor and cannot support regional-scale employment uses. There are no safe, accessible and attractive active travel routes. The government’s Connectivity Tool confirms poor sustainability credentials, showing at just 22%. In short, the development would generate very high levels of car-based commuting, with no credible sustainable transport alternatives. Traffic congestion on the A22/A272 has already worsened due to recent retail development at the Park. In conclusion, the location contradicts NPPF paras 82, 88, 105, 113 and the Council’s own evidence base.
No justified need for the development – The Employment & Economic Study 2026 is relied upon as the principal justification for the allocation, but when properly scrutinised, it does not support OEMP4. The Draft Local Plan already includes enough employment land allocations to meet projected job requirements, even based on the ambitious housing assumption of 1,457 dwellings per year. Ridgewood Farm’s 12,650 m² employment allocation remains undeveloped yet is far more sustainably located. The Draft Local Plan incorrectly applies the ICENI Study’s density assumptions; the WDLP uses 60,000 m² derived from a planning application on a 30.9 ha site. But the SA and SHEELA assess a much larger composite site of 42.25 ha, implying a development potential of 105,000–169,000 m² at the Study’s 40% plot ratio. None of these vastly different figures are reconciled or justified. This lack of transparency masks the real scale of development being enabled.
The wrong location – The Study identifies district-wide needs, but not location‑specific needs, and provides no evidence that Uckfield/Maresfield requires a regional-scale employment allocation; it is not a priority growth location. There is no demonstrable need for 60,000 m² at Maresfield. The Study identifies severe shortages predominantly in Hastings, but not in the North of the district near Uckfield. It emphasises the need for employment land close to strategic transport networks, which OEMP4 is not.
Empirical evidence of poor location – While studies may point to the need for employment land, the Council itself has permitted the loss of commercial land to retail at the existing Ashdown Business Park (M&S, Home Bargains), demonstrating an absence of market pressure for employment space in this location. The distribution centre that was opened in 2016 by John Lewis was soon closed and relocated as the location of the depot was found to be underused and unsuitable.
Flawed assumptions – A number of assumptions that were used in the modelling of the employment study were unsubstantiated and took a different approach to neighbouring authorities. These resulted in an inflated figure for employment land need. For example, the projections were based on past take-up models rather than labour supply or labour demand. Because historical patterns of development have driven ecological collapse and because our employment patterns are entirely different from previous decades, past take-up is the least secure of all models. Yet this is the basis used for WDCs calculations, unlike neighbouring authorities.
Unsustainable location – This over-allocation would drive trans-regional commuting, worsening congestion and increasing GHG emissions. The Government’s sectoral priorities (high-tech, logistics hubs, clusters) do not apply to Uckfield or this rural site. The site is not close to an area of expertise or academic research that would be required to support such a use. Any claims that this is an appropriate use are fanciful and unsubstantiated. Therefore, the allocation is unnecessary and conflicts with sound plan-making principles.
Severe Environmental Harm – The site is less than 3 km from the Ashdown Forest SAC, where atmospheric nitrogen, hydrological change, public access and recreational pressures are already key threats. The WDC Authority Monitoring Report 2024/2025 states that the proportion of SSSIs in the District that are in a favourable or unfavourable recovering is at 84% – which means that the 95% target has been missed. Mapping shows that the SSSIs adjacent to the Ashdown Business Park are in an unfavourable condition, with some sections in decline. The OEMP4 site contains and adjoins irreplaceable habitats including Ancient Woodland, ghyll woodland and sensitive watercourses (Shortbridge Stream, Batts Bridge Stream), and sits within the High Weald Ouse Catchment. The area forms part of the proposed Nature Recovery Network and Biodiversity Opportunity Area, supported by Natural England’s 2024 Geodiversity and Nature Recovery report.
The Development would cause habitat fragmentation, loss of ecological resilience, pollution risk, dark skies impacts, increased flood risk, and loss of carbon storage. In summary, the allocation would undermine national policy on biodiversity net gain, nature recovery and protection of irreplaceable habitats (NPPF paras 174, 180).
Harm to Uckfield Town Centre – The Town Centres Study (2026) shows declining in‑centre market share since the out‑of‑centre M&S opened at the Business Park. Further retail creep or diversion of trade will damage the long-term vitality and viability of Uckfield High Street. No retail impact assessment or vitality assessment has been undertaken. Marginal comparisons with other UK high streets using obscure metrics provides weak evidence as we know that nationally, the high street is in sharp decline. Previous change of use from employment to retail, allowed by WDC, demonstrates how the allocation would allow for out-of-town retail and undermine a town centre-first policy.
Planning Application Evidence Demonstrates Non‑Deliverability – The recent planning application WD/2022/3319/MAO highlights: the lack of Environmental Impact Assessment, despite being legally required; the absence of a contamination or hydrological assessment; and lack of transport modelling for total daily vehicle movements or downstream impacts. The application is in conflict with a wide array of Core Strategy and Saved Policies. Therefore the evidence for deliverability is absent and the allocation cannot be justified.
Water shortages in the north – the Local Plan acknowledges that Wealden is a severely water stressed district, yet makes no further comment or offer of mitigation. The drinking water contamination and outages have been particularly acute in the north of the district. Therefore, placing additional burden with the allocation of a vast employment land site is ill-considered until these fundamental issues have been resolved.
Heritage – Park Wood, which is adjacent to the site, is situated within the historic landscape of the High Weald, and is part of the former mediaeval deer park of the Ashdown Forest. Mapping confirms this and there is evidence of the boundary pale, a 13th-century earthen bank and ditch, which secured the forest for hunting. This woodland would be detrimentally impacted by hydrological changes, noise, light and air pollution, disturbance and litter.
Conclusion & Requested Action – Based on the extensive environmental constraints, unquantified but significant PFAS risk, lack of transport capacity, unsustainable location, and absence of proven need, the Ashdown Business Park Expansion fails the tests of soundness. Allocating this site would pre-determine major strategic decisions outside the proper plan-making process and would expose the Council to serious environmental, legal, and reputational risks. The site should be removed from the Local Plan. A full evidence-led strategic review of employment land that properly considers contemporary employment needs, biodiversity loss and infrastructure capacity should be completed before any new allocations are considered.

Owlsbury Farm; Housing and Mixed Use Site Allocation.

I object to the inclusion of LH1 – Land at Owlsbury Farm, Lewes Road in the Draft Local Plan for the following reasons:

The proposed allocation of Owlsbury Farm is unsound and must be deleted from the Local Plan. The site fails every test of soundness under NPPF para 35. It is not justified, not effective, not consistent with national policy, and not positively prepared. The evidence base, including statutory consultee responses, recent site‑specific assessments, and Wealden District Council’s own sustainability tools, demonstrates that Owlsbury is fundamentally unsuitable for development.
Irreplaceable Habitats and Ancient Woodland – Owlsbury contains ten separate parcels of Ancient Woodland, forming a highly sensitive and irreplaceable mosaic of wet woodland, water-meadows, ponds, riparian habitats, hedgerows and other species‑rich habitat. The standing Advice of Natural England and the Forestry Commission states that deterioration of Ancient Woodland can only be permitted for “wholly exceptional reasons” and housing targets do not constitute an exceptional reason (APP/C1435/W/23/3321978, p9). The magnitude of development would create unavoidable edge effects, habitat fragmentation and deterioration of irreplaceable habitats. Development would encircle multiple ancient woodland blocks, exposing them to light, noise and air pollution, predation, hydrological disruption and invasive species. These impacts cannot be mitigated with buffers, which statutory consultees have already stated are inadequate. The result would be irreversible loss of ancient and wet woodland ecology, including species dependent on saturated soils such as willow tit, invertebrates and specialist plants. The proposal directly conflicts with NPPF paras 180–188 on irreplaceable habitats.
WDCs Ecology Report (10/10/2025) – which refers to the existing application (WD/2025/0933/MEA) objects to the application and identifies major problems with the site, that are not specific to the application, but apply more generally. The report finds likely deterioration of the Ancient Woodland and wet woodland – which are both irreplaceable habitats and is unacceptable according to the NPPF. There was insufficient evidence on bats, dormice, birds, reptiles, amphibians, and invertebrates. There is incomplete baseline data and flawed BNG assumptions; based on over-claims of improving ancient woodland and wet woodland that is more likely to deteriorate. More evidence of biodiversity baselines would be required before allocating such a large scale site for development.
Rights for Rivers – In 2025, Wealden District Council declared Rights for Rivers, including: the right to flow; to be free from pollution; and to feed and to be fed by sustainable aquifers. In other jurisdictions, these Rights for Rivers have resulted in improved river health. For example, Paris City Council granted the River Seine the right of legal personhood (as is afforded to corporations and ships). As a result, significant sewage pollution was stopped and water quality was dramatically improved. Wealden District Council’s Rights for Rivers motion is a democratically significant declaration that can and should have implications for local planning policy. Lewes District Council separately adopted a Rights for Rivers charter for the wider Ouse catchment.
Hydrological harm – Much of the Owlsbury site comprises of the flood plain and water meadows that serve the River Uck. Urbanisation will have a profound and wide-reaching detrimental impact on the drainage system and consequently on ground water, drinking water supplies and ecology. The points 6,7,8 & 9 below are some of the mechanisms of harm.
Water severance – The urbanisation that is proposed will surround and essentially cauterise ecologically sensitive areas from the rainwater that sustains them. For example, the irreplaceable habitat that is the wet woodland (especially at Stroodland Wood) will almost entirely be surrounded by urbanisation and be cut off its natural streams (or hydrological exceedance paths, as shown in the exceedance map). As a result, the water table will be lowered and this will lead to habitat fragmentation and ecological degradation; turning a functioning ecosystem into an isolated island of degraded nature. The wet woodland’s resilience will be lost and it will result in a drier, less diverse, and more polluted environment. This directly conflicts with the Council’s own Rights for Rivers declaration. The hydrological severance alone makes the site undeliverable under the Council’s adopted principles.
Flood Risk – The Owlsbury site faces multiple flood risk challenges. The site has been identified as being in an area of groundwater flood risk concern, and groundwater monitoring conducted over the winter of 2023/24 confirms that the site is at risk of groundwater flooding (page 33 ES Vol 4 Appendix 7.1). Additionally, the Environment Agency designates the site as being located in Flood Zone 3 and identifies it as an area at high risk of surface water flooding. Photographic documentation of repeated winter flooding in 2025/26 shows the site being cut the site in half. Due to the consistent sewage spills, there is a high risk of dangerous contamination in the flood water.
Drainage Failure – Sustainable Drainage Systems (SUDs) – For SUDs to function properly, they must have good water quality, otherwise they can concentrate toxins and become a source of pollution. The ponds often act as sinks for urban runoff, receiving heavy metals, microplastics, toxic chemicals and litter from surrounding roads and buildings. These concentrated pollutants then contaminate ground water supplies. At Owlsbury, the proximity of the proposed SUDs to the major road network means that they will likely concentrate and transfer pollutants from road runoff (benzines, oils, heavy metals etc) directly into groundwater, potentially contaminating drinking water sources. There is particular concern around the proposed NE, E and SE ponds, which are immediately adjacent to the A22. According to the Rivers Trust, in 2024, 26% of England’s river stretches failed water quality checks due to urbanisation and transport pollutants. The proposed urbanisation will decrease the ability of the land to absorb, attenuate and retain storm water run-off, hence the need for SUDs. However, the SUDs are problematic for the reasons stated above and do not entirely mitigate the increased flood risk.
Unsafe SANG – while the SANG in theory may be a water compatible use, that is not the case if the water is fast flowing, is overly deep or precludes access. Because the river bisects the residential areas from the SANG, during times of flood, the standing water is deep enough to overtop wellies, such as in the recent January 2026 floods. It was also noted that there was a strong current in the middle and the flood entirely cut off access to the SANG. Not only that, but at times of heavy rainfall, we know that the combined sewage overflows start discharging raw sewage into the rivers, making the water extremely hazardous. Furthermore, when the steep clay banks of the river are submerged, by murky water, you could unwittingly find yourself in very deep and fast flowing water. This is all in public access land. In the proposed application, multiple play areas or NEAPs (Neighbourhood Equipped Area for Play) were sited in the flood zone, which is contrary to national policy.
Ineffective SANG – The SANG is a proposed mitigation to address recreational pressure on the Ashdown Forest SAC. However, there is no evidence that it is effective. The Inspector for APP/C1435/W/23/3321978 found insufficient evidence that SANGs mitigate recreational pressure on the Ashdown Forest SAC. Uckfield lies well within the 7km buffer zone and has long been constrained by this issue. Nothing has changed to justify reversing this position. The WDC’s ecology report states that the cumulative impacts of air quality on the Ashdown Forest have not been adequately considered, particularly because of the scale of the development and the fact the Ridgewood has not yet been built out. Natural England raises concerns that development at the site could “have potential significant effects” on the Ashdown Forest SAC and SPA. Furthermore, in times of heavy rainfall, when the SANG is cut off from the urban development, residents will have to get into their cars, drive all the way through Uckfield and around to a Buckham Hill entrance to use the SANG, or just head off to the Ashdown Forest, adding further recreation and air quality pressures. Buckham Hill is not a suitable access point for visitors of the SANG.
Unreliable Habitats Regulations Assessment (HRA) – Natural England points out the HRA should be produced by WDC and not by the applicant. There is a clear conflict of interest in the applicant carrying this out. Natural England states that WDC is failing in its duty and as a competent authority, it is WDCs responsibility to produce and be accountable for the conclusions of the HRA. For such a large allocation, the absence of this work is unacceptable and possibly unlawful.
Not a 20 minute neighbourhood – Owlsbury scores just 22% on the Government Connectivity Tool. By way of comparison, the nearby site at Downlands scored around 58%, but was dismissed at appeal for being too remote and car‑dependent. Downlands was on the town side of the bypass, and closer to the town centre, secondary school, health services and leisure provision. Owlsbury is sited in a more remote and inconvenient location, outside of the bypass and more than 20 minutes from the town centre (according to the Applicant’s own Highways report); with significantly greater hurdles to active travel options. The proposal would hamper Uckfield’s potential to become a compact 20‑minute neighbourhood – a policy ambition that is well supported.
Unsustainable and Isolated Location – Any walking or cycling routes would require crossing the A22 bypass (with a speed limit of 50 miles per hour). Suggested routeways do not provide a safe, suitable or attractive option. With active travel paths running alongside major roads, pedestrians would be subjected to road traffic accident risks, air pollution, headlight glare and road spray. Estimated walk to school times are up to 50 minutes. The situation would be made worse once the charging station is operational, as cars will be turning off the roundabout across the pedestrian route. Once over the bypass, cyclists would enter the main arterial road which also connects the industrial estate and would be subjected to associated articulated lorry movements. Cycling along the A22 is not realistic even with speed reductions. Given the significant gradients within Uckfield, cycling would be precluded for all but the fittest of cyclists on unassisted bicycles. Another walking route is proposed via Ridgewood, but infrastructure for this is currently undelivered and still requires crossing the A22. Underpasses are prone to flooding and are unsafe. It is unrealistic to anticipate that such unsafe and unpleasant journeys will be undertaken by the majority of residents. They will instead resort to private car journeys.
The A22 presents a fundamental flaw with the proposal, and the severance would be exacerbated by the proposed dualling of the A22, as supported in LTP4 and other transport strategies. If the speed limit on the A22 was reduced to improve the safety of Owlsbury residents, it would present a major problem for traffic flows. These facts of geography are not particular to any one application but are associated with the site and cannot be mitigated.
Infrastructure Deficits – A development of this scale could not be expected to provide all of the neighbourhoods daily needs internally. Therefore residents will travel into Uckfield for services such as secondary schools. Uckfield Community College is already operating at capacity and is over-subscribed. There is a shortage of existing GP and dental provision.
Unsubstantiated claims that a development at Owlsbury would internalise daily travel is not evidenced or credible. Even a generous provision of facilities within the development could not meet all daily activities such as: employment and training; secondary and further education; social support; leisure and night life; religious or sporting activities; and visits to family and friends who live outside of the neighbourhood. The concept of a ten minute neighbourhood might be great in theory, but the reality is that design cannot negate or mitigate the substantial impact of the residents of 1,550 new houses on the road network. Given the location and lack of attractive active travel options, residents would overwhelmingly rely on private cars. Any pedestrian or active travel routes would be severed by the A22 bypass. Walking routes are indirect, unsafe and severed by the A22. Some are dependent on undelivered Ridgewood infrastructure, that may take decades to be realised at current build-out rates.
Highways – The East Sussex County Council Highways report (30/09/2025) objects to the current application (WD/2025/0922/MEA) for multiple reasons that are not specific only to the application, but apply to the site more generally. The Statutory Consultee highlights fundamental unresolved constraints including: serious concerns about scale, location, and impact on the A22; non‑compliant junctions and uncertain crossing deliverability; lack of evidence for safe access; weak active‑travel and public transport provision; conflict with safeguarded former railway line; no demonstration of sustainable movement patterns. These objections demonstrate the undeliverability not just of the application, but of the site.
Lack of adequate sewage capacity – Southern Water is a statutory consultee. In their response (02/06/2025) they did not commit to adoption. There has been no whole‑network capacity modelling or resilience testing. The nearest sewage facility is Uckfield Waste Water Treatment Works (WWTW), located on the A22 directly opposite the Owlsbury site. Uckfield WWTW demonstrates serious operational deficiencies that directly impact the receiving watercourse. According to Rivers Trust data, this facility (permit number A00534) spilled 19 times in 2024 alone, totalling 178 hours of discharge into Ridgewood Stream, a tributary of the River Uck. These permitted spills likely underestimate actual pollution events, as Southern Water self-reports. There are no secure upgrade programmes in place. The area has become infamous for its sewage flies problem; with regular stories in local media of biblical, plague-like fly infestations. Southern Water has responded by using insecticides. These insecticides are highly toxic to aquatic life with long lasting effects. Many common treatments, particularly those containing synthetic pyrethroids, pose significant risks to aquatic organisms such as fish, crustaceans, and aquatic insects when they enter water systems through drains or sewage treatment effluent. The sewage pollution problem extends beyond the immediate facility. Multiple upstream WWTWs also discharge into the River Uck system, creating cumulative environmental impacts that the application fails to adequately assess.
Water Framework Directive Compliance – Despite Brexit, the UK remains bound by Water Framework Directive (WFD) principles through the Water Environment (Water Framework Directive) (England and Wales) Regulations 2017. These retained regulations mandate protection and improvement of the water environment, with a target of 75% of rivers achieving good ecological health by 2027. The River Uck at the application site currently fails to meet these standards, being classified as in bad ecological health according to Rivers Trust data. Given this degraded baseline condition, the river cannot sustain additional pollution loading from the proposed development.
Water shortages in the north – the Local Plan acknowledges that Wealden is a severely water stressed district, yet makes no further comment or offer of mitigation. The drinking water contamination and outages have been particularly acute in the north of the district. Therefore, placing additional burden with the allocation of the largest application that Wealden has ever had in this site is ill-considered until these fundamental issues have been resolved.
Arboriculture – The Arboricultural report (27/10/2024) identifies concerns regarding the encirclement and fragmentation of Ancient Woodland, loss of priority hedgerows and failure to follow national policy or best practice.
Landscape, Settlement Pattern and Coalescence – The development would: breach the long‑established, defensible A22 settlement boundary; create a new, detached settlement rather than an extension of Uckfield; accelerate coalescence with Little Horsted; harm the Uckfield–Hailsham Wooded Clay Vale landscape character area; destroy medieval assart field patterns, dark skies, and tranquillity. This scale of landscape harm conflicts with national and local policies protecting countryside and settlement identity.
Food Security and Loss of Agricultural Land – The Owlsbury site consists of Best and Most Versatile (BMV) agricultural land, yet the applicant has failed to provide the required Agricultural Land Classification survey. This omission violates NPPF 187b, which explicitly mandates the conservation of BMV land. In an era of climate breakdown, growing geopolitical instability and evident supply chain vulnerability, taking productive farmland out of use represents a strategic error. Productive farmland contributes to local food resilience. The development would: permanently remove significant agricultural capacity; increase reliance on imported goods that often accelerate deforestation; destroy purposeful, land-based jobs; reduce carbon sequestration; contradict national concerns highlighted in the UK’s National Security Assessment on ecosystem collapse and food security.
Impact on Public Rights of Way – The site benefits from a highly valued network of Public Rights of Way, characterised by their rural and tranquil nature. The Ramblers’ objection to this application highlights significant concerns. The proposed development would substantially and adversely impact the experience of walking these paths in several ways. The development would deteriorate the landscape quality that makes these paths valuable. Additionally, the proposal requires converting existing footpaths to bridleways to accommodate cycle tracks, fundamentally altering their character and use. Several public footpaths currently run along quiet tracks. The development would inevitably transform these into rat-runs due to increased traffic, compromising both safety and the peaceful nature of these routes. The proposal contravenes national policy under NPPF 105, which requires the protection and enhancement of Public Rights of Way. Furthermore, footpath number LIT/2/1 presents a particular concern. It currently passes through ancient woodland with minimal damage due to disturbance. However, surrounding this ancient woodland with residential development, as proposed, would alter the footpath beyond recognition.This creates an unacceptable choice: either close the footpath entirely or cause profound and irreversible damage to the ancient woodland. Both outcomes directly contradict NPPF 193d, which requires development to “enhance public access to nature where this is appropriate.” The proposal fails to meet this fundamental requirement and instead would diminish public access to this valuable natural resource.
Heritage – The Grade II listed Owlsbury Farmhouse is also of special architectural and historic interest. The application would erase the building’s historical connection to the land and likely condemn the property. I note that the heritage building in the centre of the adjacent and comparable Ridgewood development, has been the subject of multiple arson attacks.

Conclusion – The allocation of Owlsbury Farm is fundamentally unsound, unjustified, ineffective, inconsistent with national and local policy and not positively prepared. It ignores statutory objections and contradicts SHEELA 2024 findings. It is environmentally damaging and fails to assess alternatives or nature recovery evidence (Natural England, 2024). It is deficient in essential, basic infrastructure, such as: public transport, highways, flood, wastewater, water supply and SANG. There is no deliverable transport of infrastructure strategy. It is unsafe in flood terms. It is isolated, and wholly inconsistent with national and local planning policy. It conflicts with the NPPF on sustainable transport, flood risk, irreplaceable habitats and biodiversity. It represents one of the least sustainable locations possible for such a major development. It is not positively prepared and creates a car‑dependent, disconnected settlement that does not support sustainable patterns of growth. Owlsbury must be removed from the Local Plan.