Outright Objectors

Environment Agency
Sport England
Sussex Wildlife Trust
Sussex Ornithological Society
Crowhurst Parish Council
Friends Of Combe Valley
Bulverhythe Protectors
90+ Individuals Commenting

Serious Concerns

County Archaeologist
Veolia (Operator Of Household Recycling And Waste Stations)
Southern Water

Hastings Borough Council’s plan to build 192 homes on the lower tier of the Bulverhythe playing fields behind Bexhill Road has encountered environmental objections throughout the four years since it was first mooted. A proposal to build extensive housing on a natural flood plain within a designated countryside park was always going to be controversial, and the various flood mitigation surveys and environmental impact assessments that the council has commissioned over that time
in efforts to vindicate it have stirred up rather than dampened opposition.

The local contest has been hitherto both technical and political. The council’s Labour-dominated cabinet has continued to insist that flood defences were capable of being devised and implemented, and that the town’s need for housing trumps all other considerations; Conservative voices, including those of the local ward councillors of West St Leonards, have been consistent in defending the park from encroachment. But the lodging of the council’s formal planning application a few weeks ago, which reveals not just the detailed layout of the prospective residential site but also the programme of extensive works alongside that are designed to prevent future flooding, including a sluice and new embankment of the river Combe Haven, has unleashed a torrent of environmental objection from both national and county-wide agencies.

Over the last week formal objections have been submitted by most of those with prime responsibilities, led by the Environment Agency (EA) and Sussex Wildlife Trust (SWT) – see above list. Sport England has also weighed in to object to the loss of playing fields, while the County Archaeologist is arguing that the pre-planning survey commissioned by the council to resolve archaeological issues arising on the building site itself fails to address the potentially far more significant consequences of excavations needed for the flood works.

Flood Risk Flaws

The objections raised by the EA are fundamental. They contend that under the National Planning Policy Framework (NPPF) residential development should not be permitted on a functional flood plain. The flood risk assessment commissioned by the council from the environmental consultancy firm, Ambiental cannot be relied upon, they argue, as it has failed to classify the site as a natural flood zone or to correlate modelled flood levels with historic events. 

It is difficult to see how a revised risk assessment which recognises the regularity of natural flooding of the site could get round this objection. But, even if it could, the EA also objects in any event to the proposed sluice, artificial embankment and other works designed to interfere with the flow of water within the river, which would impact significantly on wider nature conservation, fisheries, ecology and physical habitats. 

Sussex Ornithological Society and the SWT have each lodged similar objections to the development. The latter, like many individual objectors, argue that on principle, as the site lies within the countryside park and, more particularly, within the river’s floodplain, it should be off limits for new housing. They also express particular concern about its impact on the Combe Haven SSSI (site of special scientific interest), including the wildlife site of Filsham Reedbed which the SWT manages as a local nature reserve.

Crowhurst Parish Council are concerned about increased risk of flooding of the village from any backing up of the Powdermill stream which flows into the Combe Haven. This is again an event which they have direct experience of within the last decade.

Sport England take a different tack, objecting to the loss of a playing field area without any compensatory site being offered in substitution. The borough council has argued that the area has not in fact been used for any organised sport for many years, but aerial pictures show previous ground markings.


The adverse letter of comment from the County Archeologist on the staff of East Sussex County Council, Neil Griffin, states that the impact of the proposed development upon local heritage assets, including archaeological remains, has not been properly assessed in accordance with section 189 of the NPPF. 

The borough council has lodged a section 189 assessment in relation to the lower tier site itself. But Mr Griffin notes from drawings recently added to the planning documentation that the proposed sluice and embankment earthworks will require excavations deep below ground level. Contiguous sheet-piled seepage cut-off walls, nominally 10 to 15 metres long, are proposed to be driven down through a complex geological sequence, and some preliminary ground investigations are proposed, including a borehole up to 30m deep and electric cone penetration test holes. 

Mr Griffin had already advised in a previous letter of 3rd February that, given Bulverhythe’s history as the port of Hastings in medieval times and other features of archaeological interest, the development should only proceed subject to a programme of archaeological works on the site. But he now effectively argues that no planning permission can be lawfully granted until the full archaeological significance of the wider area has first been investigated and clarified.

The plans lodged by HBC are for 115 houses at full market value (36 with two bedrooms, 79 with three) and for 77 ‘affordable’ houses/flats – 47 to be let, 30 sold. There are to be parking spaces for 313 cars and 398 cycles.

For more on the planning contest ahead see ‘The Three Great Battles of Hastings’ here.

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