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

Ends on 23 March 2026 (55 days remaining)

Part 2 – Development Needs

3. Development needs in Rother

Development needs: Housing

Amount of housing needed

3.1. The Local Plan must set a positive strategy for boosting the supply of homes and meeting the housing needs of local communities. It is therefore important to be clear about how many more homes are expected to be built in the district over the plan period. The NPPF stipulates that the national ‘standard method’ should be used to assess the minimum amount of housing required in an area.[8]This takes existing housing stock estimates and applies an upward adjustment based on the affordability characteristics of the area.

3.2. At the time of the first Regulation 18 consultation on the draft Rother Local Plan in summer 2024, the standard method yielded a figure for the district of 733 net new homes per year. The NPPF was then updated in December 2024 along with changes to the standard method. It now yields a figure for the district of 912 net new homes per year. Over the 17-year plan period of 2025-2042, this amounts to a need of 15,504 net new homes. The annual housing need figure is subject to change on a yearly basis, and the Council will therefore monitor any updates to the standard method and its outputs as work on the plan progresses.[9]

3.3. To put the Government’s latest housing need figure into context, the adopted Rother Core Strategy Local Plan (2014) sets out a housing target of 335 net new homes per year. The standard method figure is roughly 3-times higher. Furthermore, monitoring records show that the Core Strategy housing target has not been met on a regular basis, with approximately 215 new homes per year having been built on average.

3.4. Notably, the figure generated by the standard method is just a starting point for determining the minimum amount of housing needed in the district. The NPPF also requires that consideration be given to any unmet housing needs arising in neighbouring authority areas, and whether they can be accommodated in Rother.[10] This is discussed further in the ‘Duty to Cooperate’ section of this chapter.

Type of housing needed

3.5. The discussion above deals with the overall number of new homes needed in Rother over the medium to long-term. We recognise that our local communities have a wide range of housing needs. This includes but is not limited to family homes, affordable housing and specialist accommodation (such as supported care for older people). These types of housing need are not addressed by the standard method. Rather, it is up to the Council to assess these needs separately as it produces the Local Plan.

3.6. We have therefore prepared a Housing and Economic Development Needs Assessment (HEDNA) jointly with Hastings Borough Council.[11] This study forms part of the Local Plan evidence base. It examines housing needs in the local area by tenure, type and size. Its key findings included: a significant need for affordable housing throughout the district including rental and open market affordable housing; a need for specialist housing for older people; and a need for all sizes of dwellings but particularly smaller dwellings to suit those looking to downsize and for first-time buyers. We intend to review the HEDNA shortly, ensuring it remains up-to-date, and will continue to use the study to inform the preparation of the Local Plan housing policies.

3.7. The focus of this current document, however, is to set out options and preferred approaches to the overall amount and distribution of housing in the district (including proposed site allocations), rather than for housing types. The first Regulation 18 draft Local Plan covered housing type extensively, including policies on affordable housing, specialist housing for older people, self-build and custom housebuilding and many others. We are now reviewing feedback received on those proposals and further details on this topic will be included in the Regulation 19 stage Proposed Submission version of the Local Plan.

Meeting identified needs and establishing the housing requirement

3.8. Through the new Local Plan, the Council must assess the extent to which identified housing needs (calculated using the standard method) can be met within the district. This assessment will be used to set a housing ‘target’ (requirement) for Rother which will be included in the Local Plan. It is not always the case that identified housing needs can be met in full, depending on the specific circumstances in a local authority area.

3.9. For Rother, there are key environmental and other constraints that limit the amount of land suitable for the future development of new housing. The presence of the High Weald National Landscape, which covers some 83 per cent of the district, is a significant constraint to major development as it is given the highest level of protection in relation to conserving and enhancing landscape and scenic beauty both by the NPPF[12] and legislation[13]. Rother also contains internationally and nationally designated habitats sites, covering roughly 7 per cent of the district, that must be conserved. Other constraints include areas at risk of flooding, many heritage assets and the highest proportion of ancient woodland (compared to land area) in South-East England. These constraints have been considered in the assessment of options for both the spatial development strategy and specific development sites, as set out later in this document.

3.10. Housing needs in Rother district, like most other local authority areas in England, will be addressed through a combination of new housing that is delivered on 3 main categories of sites. These are: permitted sites, ‘windfall’ development sites, and sites allocated for new development in the Local Plan. This section now looks at each of these categories in turn.

Sites with planning permission

3.11. For the purposes of this Local Plan, permitted sites are defined as sites that have gained planning permission for new housing for 5 or more dwellings, at any time before 1st April 2025, where the development has not yet come forward but the planning permission remains extant (valid). This includes planning applications with a resolution to grant approval, subject to any necessary planning obligations (Section 106 agreements). It does not include planning permissions that have lapsed (expired) or permissions for less than 5 dwellings, the latter of which are captured under the ‘windfall development’ category, discussed below.

Windfall development

3.12. Housing windfalls is a term used to describe housing built on land that is not specified in the development plan (i.e., sites that are not allocated). The development plan for Rother includes the adopted Local Plan and made Neighbourhood Plans. It is normal for windfall sites to come forward; the Local Plan is generally not expected to account for all future housing development through its site allocation policies. Indeed, the NPPF allows local planning authorities to rely on windfall sites to count towards their anticipated future housing supply, where there is compelling evidence to do so.[14]

3.13. The Council has prepared an assessment of windfall development in the district.[15] This concludes that there is strong evidence of windfall sites coming forward in Rother over past years, and it is reasonable to assume that this trend will continue. Windfall development sites can therefore be relied upon as part of the district’s future housing supply. Further, the study suggests that 39 dwellings per annum is an appropriate windfall figure for small sites (those sites containing fewer than five dwellings). Large site windfalls also come forward however these are less easy to predict so are not included in the calculation (allowance).

3.14. At this point in the plan process, the Council will use this small site figure as a starting point for its windfall allowance and considerations for housing delivery within the plan period. The windfall figure will be subject to review and potential updating during the preparation of the plan, based on the latest evidence.

Housing site allocations

3.15. Housing site allocations are sites that are specifically identified in the development plan for housing development. They include land that is allocated for residential use only or land for ‘mixed-use’ development comprising residential and other uses, such as commercial or community uses. Site allocations are an important part of the Local Plan. They provide clarity on how identified housing needs will be addressed (including by setting indicative housing numbers on specific sites), as well as giving the public and other stakeholders certainty about the locations where new housing will be directed and built. This is particularly helpful for ensuring that supporting infrastructure is delivered where it is needed.

3.16. Site allocation policies for Rother are currently set out in the Council’s adopted Development and Site Allocations (DaSA) Local Plan (2019), as well as made Neighbourhood Plans. As part of the preparation of the new Local Plan we are reviewing the DaSA Local Plan and Neighbourhood Plan site allocations. This will help us to determine whether these allocations should be retained in the new Local Plan, or if they should be retained but updated with new policy requirements and development guidelines. Further, as some site allocations have now been fully delivered it will be appropriate to remove them from the development plan.

3.17. We are also considering new additional site allocations. This is in response to Government requirements and guidelines on housing delivery (i.e., updates to the standard method). The identification of new sites will also help to ensure that our local communities have access to a wide range of housing options, now and in the future. Finally, we need to plan positively to ensure new housing is well-located and makes Rother a more sustainable and affordable place, by enabling people to live well locally and reducing the need to travel by car, while also planning for the housing needs of those villages less well-served by public transport to ensure their continued vitality.

Reviewing and updating the Local Plan site allocations

3.18. We have produced a Housing and Employment Land Availability Assessment (HELAA) to inform the preparation of the Local Plan. The main aim of the assessment is to identify land that may be suitable, available and achievable for new development in Rother over the plan period, and which can be used to meet local needs. Land identified by the HELAA may be earmarked for future development in the Local Plan via a site allocation policy.

3.19. A Draft HELAA (April 2024) was published alongside the first Regulation 18 consultation on the draft Rother Local Plan. The study helped us to inform considerations on the spatial development strategy and indicative housing growth figures. Since then, we have reviewed and updated the HELAA to support the preparation of this consultation document. As part of this review, we have:

  • Relaunched the ‘Call for Sites’ in summer 2025, which has been open since Autumn 2020 (and remains open), and assessed new sites submitted[16];
  • Reviewed representations on the first Regulation 18 consultation on the Draft Rother Local Plan (April 2024), including comments on the Draft HELAA;
  • Checked planning records to confirm the latest status of sites with planning permission (i.e., not started, under construction, built or lapsed);
  • Re-assessed Draft HELAA sites to determine whether they are suitable for development. This includes re-assessing previously rejected sites, particularly those known to be available, to determine whether development could be made acceptable in principle across all or part of the site[17];
  • Undertaken extensive site visits;
  • Engaged with landowners and developers to understand whether land identified is available for development, and if so, the expected timeframes for this; and
  • Re-assessed the development potential of suitable sites by considering density options, to ensure the optimal use of land.

3.20. The HELAA is being produced in line with national planning policy and guidance. It is a comprehensive study that reflects how the Council has ‘left no stone unturned’ in its process of identifying land in suitable locations and specific sites to meet the district’s development needs. Over 900 sites have been assessed as part of this study. All sites that have been assessed through the revised Draft HELAA (2026)[18]as suitable, available and achievable have been taken forward as proposed site allocations in the new Local Plan, as set out later in this document. Separately, the Council has also undertaken a Sustainability Appraisal of HELAA sites considered for inclusion in the Local Plan.[19] It should be noted that at this stage in the Local Plan process, a detailed trajectory, illustrating the expected rate of housing delivery over the period of the new Local Plan, has not yet been produced. This is because further work needs to be undertaken with landowners and infrastructure providers in order to determine realistic delivery rates and inform a detailed trajectory to be included at submission (Regulation 19) stage.

Summary: the emerging picture of housing need and supply

3.21. Despite this rigorous approach to identifying land for development, the latest HELAA findings suggest that there remains insufficient capacity to meet the Government’s identified housing need figure for the district (as per the standard method) over the plan period. This is because of the heavily constrained nature of the District (including that roughly 90 per cent of the district is a National Landscape or protected habitat site) meaning it is not suitable for unrestricted development. This accords with paragraph 11 (b) of the NPPF (2024) which requires Local Plans to apply a presumption in favour of sustainable development, meaning that strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, unless: (i) the application of policies in the NPPF that protect areas or assets of particular importance provide a strong reason for restricting the overall scale, type or distribution of development; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the NPPF as a whole. The policies referred to in part (i) include those relating to habitats sites, Sites of Special Scientific Interest and National Landscapes. In Rother's case these criteria are considered to be met because the application of policies in the NPPF relating to National Landscapes and habitats sites do provide a strong reason for restricting development.

3.22. While this does not preclude new development in the National Landscape, as set out in Figure 2 below, our assessment indicates a shortfall of some 7,077 dwellings up to 2042. However, it is worth emphasising that the Draft HELAA has identified a substantial amount of land and sites for new development which, when brought forward for site allocation policies, have the potential to facilitate a significant step-change in housing delivery in Rother, well above that currently provided for in the Core Strategy Local Plan.

3.23. The Council is continuing to engage with neighbouring authorities to establish whether all or part of Rother’s unmet needs can be accommodated in areas outside of the district, as discussed in the Duty to Cooperate section below. However, our understanding is that there are no neighbouring local planning authorities currently in a position to accommodate any unmet needs arising in Rother.

3.24. At this time, therefore, the Council considers that a housing target (i.e., housing requirement) for the Local Plan of 8,427 units over the 17-year plan period, or 495 units annually, is realistic and deliverable based on its evidence to-date, and therefore appropriate.

Figure 2: Current position on housing need and supply

Identified housing need (national standard method)

Dwellings

Standard method = 912 dwellings annually x 17-years (2024-2042)

15,504

Unmet need from other authorities that can be accommodated in Rother

0

Total

15,504

Sources of housing land supply

Dwellings

Housing completions

Completions 2025/2026, from 1st year of plan period

To be included from 1st April 2026

Committed sites

Planning permissions (including resolution to grant) as of 1st April 2025

Permitted site allocations

Permitted large windfall (non-allocated sites) (5+ units)

Prior approval (for change of use to residential, 5+ units)

Existing (adopted) site allocations (without planning consent)

Subtotal

2,830

Housing windfalls

Small site allowance of 39 units annually, starting Year 4 of plan period

546

New/updated site allocations[20]

Existing (adopted) site allocations (without planning consent) with revised capacity (residual figure)[21]

New site allocations (without planning consent, as of 1st April 2025)

Subtotal

5,051

Unmet need accommodated outside Rother

Unmet need agreed to be accommodated in other authority areas

0

Total

8,427

2. Do you have any comments on the Council’s proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually? Comment

Development needs: Economy

Employment uses

3.25. The Government wants the planning system to play a key role in building a strong and competitive economy, both nationally and in local areas. The NPPF makes clear that planning policies should help to create the conditions in which businesses can invest, expand and adapt. It also sets requirements for the preparation of local plans, including that they should identify sites to meet anticipated needs for economic development.[22] National planning guidance provides details on how economic needs assessments should be undertaken.

3.26. Rother and Hastings comprise part of a larger ‘Functional Economic Market Area’ (FEMA). While there are commuting links between Rother, Hastings and other neighbouring authorities (namely Eastbourne, Wealden and Tunbridge Wells), the links within and between Rother and Hastings are significantly stronger and create a largely self-contained economic market area. The Council has therefore jointly commissioned a Housing and Economic Development Needs Assessment with Hastings Borough Council. The HEDNA (2024) includes an assessment of need for employment land and floorspace across the FEMA. It identifies future employment requirements for Rother up to 2040, as set out in Figure 3 below, based on a forecast of 3,800 new jobs across all sectors.[23] As set out previously, the HEDNA will be updated in 2026 following this Regulation 18 consultation to provide an up-to-date position and assess needs over the revised Local Plan period 2025 - 2042.

Figure 3Rother employment requirement (2020-2040)[24]

Measure

Office

Industrial

Storage and

Distribution

Total

Land (ha)

7.6

6.3

10.8

24.7

Floorspace (sqm)

22,776

18,991

32,422

74,189

3.27. In reviewing Rother’s pipeline of employment land supply (i.e., extant planning permissions and adopted site allocations), the HEDNA indicates that there is sufficient capacity in Rother to meet identified needs in full. However, there are variations between sectors, with a sufficient supply (oversupply) expected for office and industrial uses in the district but a shortfall for storage and distribution. Consideration may need to be given to a targeted restructuring of the employment land stock to meet these needs, subject to the findings of the updated HEDNA in 2026.

3.28. Since the HEDNA was produced, the Council has published an Employment Land Supply Position Statement (December 2024). This identifies that 3 large sites in Rother, with outline planning permission for employment uses, have dropped out of the supply pipeline for various reasons. Therefore, the Council can no longer rely on these sites to contribute towards meeting the district’s employment needs. As a result, the Council has looked for additional capacity whilst updating the HELAA as the new Local Plan will need to ensure a sufficient supply of employment land, and new site allocations for employment uses are included within this Regulation 18 document.

3.29. Notably, recent revisions to the NPPF have placed a greater emphasis on new and emerging economic sectors and activities, and the need for planning policies to respond positively to the modern economy. This includes the knowledge economy together with its requirements for advanced digital infrastructure, as well as activities associated with the transport and handling of goods (including freight, logistics and warehousing). The HEDNA update will examine this matter in greater detail.

3.30. The Council recognises that the rural economy plays an integral role in Rother. This includes but is not limited to agricultural, equestrian and tourism activities. Approaches to managing development associated with the rural economy are set out in the Draft Rother Local Plan published for the first Regulation 18 consultation.

Retail and main town centre uses

3.31. The NPPF states that planning policies should “support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation”.[25] It goes on to set criteria for local planning authorities to consider during the preparation of Local Plans. This includes the allocation of a range of suitable sites in town centres to meet the scale and type of development likely to be needed, looking at least ten years ahead.

3.32. The Council has produced the Rother Retail and Town Centre Uses Study (2023) to inform the preparation of the Local Plan. This study includes a needs (capacity) assessment for retail floorspace within the District over a 10-year period, in line with the direction of the NPPF, looking at both ‘convenience’ and ‘comparison’ goods. Overall, the assessment concludes that there is no need at the district-level for new retail floorspace over 10 years.[26] Based on this evidence, the Council is not seeking to allocate land for new retail floorspace to meet identified need (as the need is negligible), other than as part of mixed-use developments (for example neighbourhood shops within large residential sites). However, this does not preclude new retail uses coming forward through the development management process, where such proposals are compliant with national and local planning policy.

3.33. The Rother Retail and Town Centre Uses Study also looks at a wider range of main town centre uses. These are broadly captured under the term ‘commercial leisure’ uses. These include business uses commonly seen on the high street such as hairdressers, cafes and takeaways/restaurants, pubs, gyms and fitness studios, cinemas and other cultural activities. The study shows that capacity and market demand for commercial leisure uses are varied in the district, depending on the location and type of use. It also signposts challenges within the sector such as competition from centres in other areas and changes in consumer behaviour (particularly post-Covid), including growth in online shopping. In short, it is a dynamic and rapidly evolving sector that is difficult to forecast for over the long-term.

3.34. Whilst identified future retail needs for Rother are very limited, we are nonetheless taking a positive and proactive approach to supporting town centres through the new Local Plan. For example, by refreshing approaches to managing new development in town centres and reviewing town centre boundaries. This will ensure the plan is informed by the latest evidence and responds to changes in planning policy and legislation since the Core Strategy and DaSA Local Plans were adopted. Proposals dealing with town centres are set out in the first Regulation 18 consultation on the draft Rother Local Plan, which should be referred for further information.

3. Do you have any comments on the identified employment needs, or needs for retail and main town centre uses? Comment

Development needs: Gypsies, travellers & travelling showpeople

3.35. The national Planning Policy for Traveller Sites (PPTS, updated 2024) sets out the Government’s planning policy. Paragraphs 4 and 9 of the PPTS confirm that local planning authorities (LPAs) should make their own assessments of accommodation needs and, through Local Plans, set pitch targets for gypsies and travellers, and plot targets for travelling showpeople, which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring LPAs. Paragraph 10 requires LPAs to identify, and update annually, a supply of specific, deliverable sites sufficient to provide 5 years’ worth of sites against their locally set targets; and a supply of specific, developable sites or broad locations for years 6-10, and where possible, for years 11-15.

3.36. Paragraph 11 confirms that local plan policy should include criteria to guide land supply allocations where there is identified need. Where there is no identified need, criteria-based policies should be included in local plans to provide a basis for decisions in case applications nevertheless come forward.

3.37. We have worked with the other East Sussex LPAs to commission a joint Gypsy, Traveller and Travelling Showpeople Accommodation Needs Assessment (GTAA) (2022). This study provides a summary of permanent and transit accommodation needs for gypsies, travellers and travelling showpeople across the county, and also across each district and borough, over the period 2021 to 2040. An update to the East Sussex GTAA is in progress and will be completed in 2026 following this Regulation 18 consultation, to give an up-to-date picture of need to the end of the plan period (2042). The GTAA (2022) identifies a need[27] in Rother for permanent pitches as follows in Figure 4.

Figure 4: Rother gypsy and traveller pitches requirement (2020-2040)[28]

2021-2026

2026-2031

2031-2036

2036-2041

Total

Permanent pitch need (number of pitches)

14

4

5

5

28

3.38. Ten new pitches with permanent permission have been approved since the base date of the GTAA[29]. Deducting this from the GTAA pitch requirement, and adjusting the year brackets to account for the plan period, means that the overall outstanding requirement to 2040, which the Local Plan must provide for, is as follows in Figure 5:

Figure 5: Rother gypsy and traveller pitches outstanding requirement (2025-2040)[30]

2025-2030

2030-2035

2035-2040

Total

Permanent pitch need (number of pitches)

7

(4 left over from 21-26, +3 from previous 26-31)

5

(1 from 26-31, +4 from 31-36)

6

(1 from 31-36, +5 from previous 36-40 figure)

18

3.39. The Development Strategy and Site Allocations chapters of this document sets out how the Local Plan will plan to meet this need.

3.40. The GTAA (2022) also assessed needs for transit sites, which provide temporary accommodation for gypsy and traveller households travelling through the area. The assessment found that while there may be a need for additional transit provision in the county, there is currently insufficient evidence to determine the number of additional transit pitches required. Consequently, the draft Local Plan published for the first Regulation 18 consultation includes a criteria-based policy to assess any proposals that come forward for transit sites (draft Policy HOU11).

3.41. The GTAA (2022) found there are no travelling showpeople yards in the district, and just 1 yard in the county, in Wealden district. While there is expected to be a demand for a small number of additional plots for travelling showpeople to 2040, this is expected to arise from natural population growth and should be met close to the existing yard in Wealden. There is no specific evidence of travelling showpeople accommodation need within Rother, but a criteria-based policy (HOU11 in the draft Local Plan published for the first regulation 18 consultation) will deal within any proposals for windfall sites (either permanent or transit) that do come forward.

3.42. The GTAA also considered the accommodation needs of boat-dwellers but found that there is a lack of navigable waterways within East Sussex and few suitable locations for moorings, and a lack of evidence to quantify any accommodation need. There is very little history of proposals for boat dwellers’ accommodation in the district and as such, a specific Local Plan policy is not necessary. Any proposals would be determined in accordance with the Local Plan as a whole.

4. Do you have any comments on the identified accommodation needs of gypsies, travellers and travelling showpeople? Comment

Duty to Cooperate and meeting local needs

3.43. The Council has a statutory Duty to Cooperate constructively, actively and on an ongoing basis with neighbouring authorities, county councils and other prescribed bodies in planning for strategic cross boundary matters.[31] A local plan can only be adopted and brought into force if the Duty to Cooperate has been met during its preparation, and this is tested at the plan’s examination. The Council has been engaging with the relevant prescribed bodies during the preparation of the new Local Plan. Further details of activities to-date are set out in the Duty to Cooperate: Interim Statement.

3.44. The following section focusses on some of the key considerations for the Council with respect to planning for identified development needs, as part of the Duty to Cooperate. Please note this is not a list of all such strategic matters for the Council and other prescribed bodies, the details of which are provided within the Duty to Cooperate Interim Statement.

Housing needs

3.45. From the early stages of the plan process, Rother District Council has identified housing need and delivery as a key strategic issue. This is particularly given the significant step change from the Core Strategy housing target to the Government’s housing need figure (i.e., standard method). In June 2024, in association with the publication of the Regulation 18 version of the Draft Rother Local Plan, the Council wrote to seven neighbouring and other close-by authorities to formally request that they consider accommodating potential unmet housing needs arising in Rother. These authorities confirmed that were unable to, or not anticipating being able to, take on housing needs from Rother due to either not being able to meet their own needs in full, or not having any additional capacity. This matter continues to be discussed through the duty to cooperate process. At this time, the Council cannot rely on other authorities to accommodate any unmet housing needs arising in Rother.

3.46. As set out earlier in this document, the Council does not anticipate being able to meet its identified housing need in full through the new Local Plan. Therefore, it is not currently in a position to take on any unmet need from neighbouring or other authority areas. This situation is not unique to Rother. There are many other authorities in South-East England that are experiencing challenges in meeting identified housing needs in full.

Economic development needs

3.47. In terms of commercial needs across the Functional Economic Market Area, the Council will continue to engage with Hastings Borough Council through the duty to cooperate. This will help it to understand whether there are likely to be any unmet needs for employment land and floorspace arising in Hastings. To ensure up-to-date evidence of need, the Councils will jointly commission a further update to the HEDNA, the findings of which will be considered as work on their respective Local Plans progress.

Accommodation needs of gypsies, travellers and travelling showpeople

3.48. The Council is currently working with all the other local authorities in East Sussex to identify and plan for the accommodation needs of gypsies, travellers and travelling showpeople. This is through a working group with an emerging Memorandum of Understanding, and also through shared working including the launch of a county-wide “Call for Sites” and commissioning an update to the East Sussex GTAA. It is also engaging with other neighbouring local authorities (outside East Sussex) through the duty to cooperate, and through this process endeavouring to understand their position on provision for this group.

Infrastructure

3.49. We are continuing to engage with infrastructure providers and other key stakeholders to plan for and secure the timely delivery of infrastructure required to support growth and new development in the district. Further details on infrastructure provision are set out later in this document.

4. Infrastructure Needs

Securing the timely delivery of infrastructure

4.1. It is vital that growth and new development in Rother is appropriately supported by infrastructure. We need to ensure there is a clear framework in place to not only identify the different types of infrastructure required now and over the long-term, but also to facilitate the delivery of this where and when it is needed. The Local Plan will play a key coordinating role in this respect, ensuring new investment in infrastructure is aligned with the Development Strategy for the district. This will help to ensure we achieve the key principles of Live Well Locally and Green to the Core, which sit at the heart of the Local Plan.

4.2. The Council acknowledges the feedback received in relation to infrastructure during the first Regulation 18 consultation on the draft Rother Local Plan (2024). As the new Local Plan is proposing a significant step-change in housing development across the District, we understand the concerns raised by residents and others about existing and future levels of infrastructure provision - such as for community facilities and services, transport and water/wastewater. In response to this, we are reviewing the Infrastructure Delivery Plan (IDP) to ensure it is up-to-date and can be reliably used to both inform and support the implementation of the Local Plan.

4.3. Infrastructure falls within a range of categories, as shown in Figure 6 below.

Figure 6: Infrastructure categories

Category

Type

Transport and movement

Cycling and Walking

Public transport

Strategic and local road network

Community and cultural facilities

Sports and recreation facilities, including playing pitches

Libraries

Arts, and cultural facilities

Youth and community facilities

Places of worship

Education

Early years and childcare

Primary and secondary schools

Further and higher education

Health & social care

Primary care: GP surgeries, health centres

Secondary care: hospitals, diagnostic hubs

Community care: mental health, social care, care homes

Green and blue infrastructure, and flood defence

Parks, open space and play areas

Biodiversity and nature conservation

Allotments

Cemeteries and burial space

Flood defences, sustainable drainage, riverside improvements

Utility and energy

Water supply and wastewater infrastructure

Waste and recycling infrastructure

Energy infrastructure

Digital infrastructure

Emergency and security services

Police service

Fire service

Ambulance service

The role of the Infrastructure Delivery Plan

4.4. The IDP is a key evidence base document that is prepared by the Council working together with infrastructure providers and other key stakeholders. It sets out the different types and amount of infrastructure required to support the growth and development expected to be delivered by the Local Plan. It is an important tool that provides the Council, infrastructure providers, developers and others (including the wider public) with a clear understanding of existing infrastructure provision as well as any gaps (deficits) that need to be addressed during the plan period.

4.5. For each main category of infrastructure, the IDP includes a schedule of infrastructure schemes along with information on their anticipated phasing, indicative costs and delivery mechanisms. It also sets out a priority ranking for infrastructure schemes, considering their relative importance in supporting the main objectives and outcomes sought by the Local Plan.

4.6. It is important to note that the IDP focusses on strategic and other critical infrastructure necessary to support the levels of growth being planned for in Rother. It does not, nor is it expected to, cover all infrastructure schemes that may be planned for or might come forward, such as smaller-scale or community-based projects. There are opportunities for Parish and Town Councils to set out objectives and priorities for local infrastructure through their own plans and strategies, including Neighbourhood Plans.

How the IDP is being prepared

4.7. The IDP is considered a ‘living’ document in that it is regularly reviewed and updated over the course of the Local Plan. An IDP has been in place to support the adopted Core Strategy and DaSA Local Plans. We have drawn on this document to prepare the latest IDP for the new Local Plan to build on work-to-date. A Draft Infrastructure Delivery Plan[32] was published as part of the evidence base for the first Regulation 18 consultation on the draft Rother Local Plan (2024).

4.8. The Council is preparing the new IDP with input from a wide range of key stakeholders. This includes infrastructure and service providers, government bodies (such as East Sussex County Council, the Environment Agency, and National Highways) and other delivery partners. These stakeholders are well placed to provide information on their plans and strategies, infrastructure projects or schemes (including timing or phasing of these), costs and funding sources, and delivery leads or partners. The involvement of key stakeholders is vital to the accuracy of information in the IDP and transparency in the process of preparing it. As well, it provides clarity on the responsibilities for the planning and delivery of infrastructure.

4.9. In addition, the Council has and will continue to engage with the development industry, special interest groups, Parish Councils and local communities on infrastructure planning through the Local Plan process and, where appropriate, on the IDP. This will help to ensure that local knowledge and understanding of local areas and community needs is fed into the IDP.

4.10. An updated Draft Infrastructure Delivery Plan has been prepared in support of this Regulation 18 consultation. It has been informed by new technical evidence and ongoing engagement with key stakeholders. The Council will continue to work with infrastructure providers and others to update and refine the IDP as work on the Local Plan progresses. This will ensure they can take account of the latest demographic projections as well as the Council’s current position on the Local Plan housing requirement, spatial development strategy and portfolio of site allocations, to ensure that new development is served by the right level of infrastructure in the right places. A final Draft IDP will be published at the Regulation 19 stage consultation.

4.11. The IDP will also consider how infrastructure will be funded, to ensure that it can be delivered to support development in the plan period. Generally, infrastructure will be funded through a combination of sources including the Community Infrastructure Levy, planning obligations attached to planning permissions and external funding sources.

5. Do you have any comments on infrastructure needs or priorities to support the proposed Development Strategy? Comment


[8] NPPF, December 2024, paragraph 61. Further details on the standard method are set out in the Government’s Planning Practice Guidance.

[9] Inputs factored by standard method are expected to be updated annually by the Government (including ‘housing stock estimates’ and ‘affordability ratios’ for the district) and are likely to result in the calculation of a revised local housing need figure.

[10] NPPF, December 2024, paragraph 62.

[11] This study has been prepared jointly as evidence indicates Rother and Hastings comprise a self-contained housing market area and functional economic market area, mainly based on the strong commuting links and migration flows between the authority areas.

[12] NPPF, December 2024, paragraph 189.

[13] Under the Protected Landscapes duty, as set out in Section 245 of the Levelling-Up and Regeneration Act 2023, the Council must seek to further the purposes of protected landscapes.

[14] NPPF (December 2024), paragraph 75.

[15] Rother Draft Housing and Economic Land Availability Assessment (April 2024), Appendix 2.

[16] The Call for Sites provides the public with an opportunity to submit sites for consideration as potential development sites for inclusion in the Local Plan.

[17] Further details are set out in the local plan evidence base, including the HELAA.

[18] This is the latest version of the HELAA and comprises an update to the Draft HELAA 2024. This should be referred for further information on the site selection and assessment process.

[19] The assessment of sites is being undertaken iteratively through the SA process. The Council’s Regulation 18 stage Sustainability Appraisal Reports should be referred for further information.

[20] Existing (adopted) site allocations (with planning consent) are included in the permitted development category

[21] The residual figure (additional capacity) arises from an expanded site area and/or a higher density assumption, than set out in the adopted site allocation policy.

[22] NPPF (December 2024), paragraph 86.

[23] The employment requirement is based on the ‘labour demand growth’ scenario. This takes account of past employment trends and market signals to derive a jobs forecast, which is then converted into a land and floorspace requirement.

[24] A HEDNA update will be prepared and will identify requirements up to 2042 to cover the revised plan period.

[25] NPPF (December 2024), paragraph 90.

[26] The study identifies that, at the lower centre-level, there is a need of circa 500 sqm convenience goods floorspace over the medium-term (10 to 15 years); however, it indicates that this need is limited in scale and can be accommodated by the reoccupation of existing vacant units.

[27] The GTAA (2022) pre-dates changes to the definition of “gypsies and travellers” in national planning policy although the “ethnic definition” used in the Assessment aligns with the current government definition (i.e. based on the ethnic identity of gypsies and travellers, not taking into account whether they have permanently ceased to travel or not). The need figures detailed here are those of the “ethnic” definition.

[28] East Sussex Gypsy and Traveller Accommodation Needs Assessment (GTAA) (2022).

[29] 1 April 2021

[30] Taking account of pitches delivered/ permitted between 1 April 2021 and October 2025.

[31] The Duty to Cooperate is a legal requirement introduced through Section 33A of the Planning and Compulsory Purchase Act 2004, as inserted by Section 110 of the Localism Act 2011.

[32] Rother Infrastructure Delivery Plan – Draft (Regulation 18) Version (April 2024).

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