Sussex Wildlife Trust (SWT), which leases Marline Valley from Hastings Borough Council, has put in a strong objection to SeaChange’s plans for a new business park at North Queensway.

SWT states in its objection that

We do not believe the proposal complies with national or local biodiversity policy and are concerned about the risk to the SSSI. Therefore we object to this application in its current form.

SWT states that it ‘accepts that the principle of commercial development on this site is established through its allocation for employment land in policies FA1 and LRA6. However, policy LP2 states that ‘of principle and greater consequence for every scheme, however, will be matters which include…trees, biodiversity, green infrastructure’.

The objection points out that the proposed scheme:

  • does not ensure there will be no adverse impacts on Marline Valley SSSI;
  • includes buildings on plot 2.1, contrary to Natural England’s advice;
  • does not allow sufficient buffers to ancient woodland;
  • does not avoid impacts on bats;
  • does not deliver a net gain in biodiversity as required in the National Planning Policy Framework (NPPF).

Plot 2.1

Natural England (NE) said in a scoping opinion that there should be no development on plot 2.1, closest to Marline Valley, because of the risk of polluted water draining into the ghyll stream. Despite this, SeaChange plans three large units and 57 parking spaces on this plot. SWT expresses particular concern about the risks of chemicals such as antifreeze being used on cars parked on the site, and the risk of this ending up in the stream. It points out that Natural England’s advice was that the project should maximise greenspace in order to mimic the existing hydrological regime, but that this has not been done.

SWT says that instead of being built on, plot 2.1 should be used to create sustainable drainage features and biodiversity-rich habitat.

Ancient woodland

SWT says that NE standing advice is that the buffer between ancient woodland and new developments must be at least 15m, but that on the south east of the site, the buffer is only 5m. It raises concerns about the impacts of putting down hardstanding so close to ancient woodland, and the impact of car headlights shining directly into the woodland, and says that the project should be redesigned to allow a 15m buffer.


SWT says that whilst good practice guidance recommends one bat survey visit per season, in fact only one bat activity survey has been carried out on the site (in Oct 2020) since 2012. It says there is no information in SeaChange’s ecology statement about how bats use the site (eg whether for commuting or feeding, and where bats are feeding) and therefore the conclusion that the project will have ‘negligible significance’ for bats cannot be relied on.

It points out also that the survey found occupied bat boxes along the boundary of the ancient woodland on the south east of the site. This would mean that there were car parking spaces just 5m from roosting bats. It recommends increasing the buffer to 15m and seeking further information on how bats use the site in order to minimise impact on them.


SWT points out that the National Planning Policy Framework (para 170(d)) states that planning proposals should deliver a biodiversity net gain. According to SeaChange, this project will result in a 25% net loss of biodiversity. SWT further notes that this 25% is based on the habitat now, rather than before any development began. The site was previously woodland, contiguous with Marline Woods, until SeaChange chopped it all down in 2014:

North Queensway March 2014

Best practice, according to SWT, would be to compare the expected biodiversity if the development is built with what was there before site clearance began.

Overall, it is clear that from the point of view of Sussex Wildlife Trust, there are very serious issues with this application and it should be refused in its current form. Will the council take any notice, or will they do what they always do, and give consent to yet another damaging SeaChange project?

If you haven’t already objected, please do so now – it only takes a minute. Full instructions and draft objection here.