Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

Please see attached representation, existing and proposed sites plans.

Please see attached:

- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan

SWT supports the inclusion of this policy.

Please see comments raised previously, under section 2, if you are truly green to the core all development should meet this criteria and not just developments over 10

Very supportive, especially of the emphasis on whole life carbon, and setting clear targets and limits.

This document should acknowledge the historically poor energy standards and poor build quality in the UK and make this the basis of its ambition to raise the standard of both including the intention to include solar energy in all new-build residential property.

The principles and targets for delivering net zero standards set out in the draft policy are supported by the landowner/clients and they will strive to incorporate standards into the development of the sites where reasonable and appropriate, should the sites be allocated for development.

We support the general principle of ensuring that new development contributes to climate change mitigation by reducing emissions through energy efficiency and the way that fossil fuels are used, as well as addressing the ways in which developments are designed, constructed and operate over their lifetime. However, draft policy GTC1 seeks to set ambitious net-zero carbon standards for new development that go beyond the minimum standards provided by the Building Regulations.

On 13 December 2023, a Written Ministerial Statement advised that while some local authorities' plans exceed national efficiency standards, the Government aims to balance improving home efficiency with ensuring sufficient housing is built. The Statement also notes that multiple local standards can increase costs and complexity, undermining economies of scale. Thus, the Government does not expect plan-makers to set local energy efficiency standards beyond current or planned building regulations. It advises that:
“any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures:
• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework.
• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).”

The Draft Plan recognises that this policy does not currently meet these criteria. Moreover, the detailed requirements do not reflect the evolving nature of zero carbon building policy, where standards inevitably will change in response to technological and market advancement and more stringent nationally set standards. Policy GTC1 contains little flexibility to allow for such changes and provides a high degree of certainty about the standards that will be applied over the lifetime of the Plan. This brings into question whether the evidence that supports the standards justifies the approach as a sound one.

Moreover, this needs to be justified by viability testing at the plan making stage and sufficiently flexible to ensure that it does not threaten the ability of individual sites to be developed viably, nor the Council’s ability to achieve its other identified Main Priorities. Alternatively, we recommend that the Local Plan supports low-carbon and gas-free development more generally, rather than necessitating explicit net-zero compliance.

It's all good. Not everybody knows what an "energy hieracrchy" is, though it is explained in a footnote. It's really important though, so please consider spelling out the order of the priorities (fabric first to reduce demand, renewable supply, and on-site energy supply). Disappointing that on-site storage of surpluses isn't mentioned anywhere.

I don't agree that non-residential and industrial premises (3.12) should have easier targets. Their emissions count just the same.

I will start off by commenting that it is a very detailed ambitious plan covering many aspects of life in Rother. I am not sure whether many parts of it will come to fruition due to the cost and I understand that Rother is putting aside a huge sum of money to repair our dreadful roads. The roads suffer from the amount of lorries and industrial vehicles which thunder through our towns and villages.

Due to the incompetence of the Council the Plan which should have been out on 2024 is now due in 2026.

Our local plan which was worked on for 3 years and is very detailed was supposed to take us to 2039. That has now been changed without consultation to 2028. Why?

My comments of course mainly relate to Peasmarsh where I live but I have made comments on other parts of the Plan

In section 1.9 Peasmarsh has been missed out as one of the Villages which have a Local Adopted Plan so it should state 8 Villages – not 7.

In Fig. 35 on Page 173 it does state that Peasmarsh has a Local Adopted Plan.

Our Village, Peasmarsh suffers from flooding, sewerage problems and electricity failures.

The warden assisted development in the Maltings was closed – people were relocated away and a large new development built on the site ( the only 3 storey development in Peasmarsh). The grassed area was built on and now properties in Farm Gardens below this development have flooding problems as no measure was put in place to cope with the problems caused by concreting this entire area. Also the roads were left in a poor state from all the heavy equipment and vehicles used to erect this development.

I agree with high standards for building (though no mention was made of fire safety).

The very old listed Church, at the highest point of the Village, suffered from flooding last year and this year so half of the Graves and the path were under water. Not much hope for the Village which is lower down!

No mention is made of the specific needs of children and the facilities required to enable them to do well in this area.

Farmland should be protected which will help food security and fits well with your Green to the Core and Live Well Locally emphasis in the Plan

Our farmers need all the help they can get and their produce and livestock means we can buy locally (less food and transport miles)

8.94 I agree that it is not appropriate to make provision for higher levels of care beds.

Mention was made in the Plan of Roads and Streets but none about Lanes – which you find in most Villages.

Public Rights of Way should be upheld though a proviso should be added regarding dogs being kept on leads on fields containing livestock. Again a sheep owned by our local farmer was savaged by a dog allowed to run loose.

I agree that Ancient Woodlands, SSSI’s should be protected and Dungeness which is a unique site in itself.

I agree that Habitats and Dark Skies should be protected. I hope we never have street lighting in Peasmarsh.

Brownfield sites and disused buildings should be identified and used for any new development NOT Greenfield sites

In principle I agree with ENVI – Coastal Water and Flood Risk Management and EC07.

Please see attached comments from Burwash Parish Council.

Full representation attached.

Full representation attached.

Please see attached submission.

Please see attached full submission from Nexus Planning on behalf of their client Devine Homes regarding the Local Plan and HELAA Site SAL0012: Land at Bishops Lane, Robertsbridge

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Catesby Strategic Land Ltd and Rurban Estates Limited.

See attached documents containing from Wates Developments containing:
1) The Consultation Response;
2) A Vision Document for HELAA Site BAT0014: Land at
Almonry Farm, North Trade Road, Battle; and
3) A Transport Note for HELAA Site BAT0014.

Q2 I agree in principle that houses should be built in places with services but existing infrastructure needs to be taken into account, eg in Robertsbridge, key roads are too narrow to accommodate more traffic even if more people walk or cycle.
Q6 Agree Rother should require more than the minimum energy efficiency standards.
Q11 Good
Q13 Rainwater harvesting should always be required- I cannot see how you met the 110l pp pd target without it.
Q19 Encourage solar arrays above supermarket car parks before any greenfield sites.
Q33 "Short trips of up to 3 miles can be easily made on foot or bicycle...." Rather depends on your fitness and the gradients, not easily for many people.
Q44 This should also include designing to keep houses cool.
Q120 I would like a more robust attitude towards developers who say it is not viable to include houses for rent. Instead of just caving in , the choice should either be comply with the rules or offer the site to someone who will.
Q127 If anything, increase size standards.

Please see attached comments by Historic England on the Rother draft Local Plan 2020-2040 (Regulation 18), including representations on:

Policy GTC1
Policy GTC2
Policy GTC6
Policy LWL1
Policy HER1
Policy HER2

Requirement for Development Management policies

Draft Local Plan evidence base documents

See attached.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

Please see attached document for the full submission from Westfield Parish Council.

See attached representations regarding:

- Proposed Vision - Chapter 2 of the draft Local Plan
- Proposed Development Strategy - Chapter 5 of the draft Local Plan
- Proposed Policy GTC1: Net Zero Building Standards
- Proposed Policy GTC5: Heat Networks
- Proposed Policy GTC8: Biodiversity Net Gain
- Proposed Policy LWL1: Compact Development
- Proposed Policy HOU2: Affordable Housing
- Proposed Policy HOU2: HOU12: Self-Build and Custom Housebuilding

Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.

Please see the attached full submission from the Home Builders Federation.

See attached document for the representation.