Q25.

Local housing needs necessitate that some development will be required within the High Weald National Landscape area and it is appropriate that any such development within this area is well-related to existing built-up areas and services. References to 'major development' within the policy are not well defined and lack the additional context provided within footnote 64 of the NPPF and could therefore mislead decision-makers into thinking this should apply to any 'major applications'. The policy as worded is therefore contrary to paragraph 16 of the NPPF which requires that policies are "clearly written and unambiguous, so it is evident how a decision maker should react to development proposals".

Reference to the High Weald Design Guide is supported and the proposed development concept at the Wild Meadows site has been considered in line with this Design Guide.

The proposed development reflects the positive characteristics of the built environment throughout the High Weald and makes effective and efficient use of the development site. The key principles that have determined the overall design and layout include:

• Prioritising walking and cycling routes within the site and ensuring permeability for those walking past, through and around the site, including improved access to both local facilities in Guestling Green (and those within the proposed development) and the surrounding countryside;
• Incorporating a central green public space that is addressed by the buildings around it;
• Meaningful public realm throughout the rest of the site with soft edges to streets, new tree planting and a rural character that reflects the character of the wider area;
• Residential layout that defines the streets within the site and provides strong street frontages offering both discernible building lines and architectural variety;
• An appropriate unit mix that reflects the local housing need for smaller dwellings and affordable housing;
• Parking integrated into the design and layout, with a mix of parking solutions to ensure that parking is discretely located where possible and not overly dominant at street level

Q51, 53

The Council's authority monitoring reports show that the Council have delivered between 98- 283 homes a year since 2011/12. Although completions have been rising over time, the scale of delivery falls significantly short of identified local housing needs (733 homes a year), as well as the agreed housing trajectory within the adopted Core Strategy (335 homes a year) and the proposed spatial development strategy for the Rother Local Plan 2020 - 2050 (258 to 364 homes a year).

The Council's existing housing policies and allocations are therefore significantly under-delivering on the agreed minimum housing requirements for the District and local need has grown since the adoption of the previous Core Strategy. Housing delivery will only improve consistently through the adoption of a new Local Plan with additional housing allocations and a revised policy framework that provides a more aspirational framework for housing delivery.
Without deliberate policy interventions to improve delivery, local supply and affordability issues will continue to worsen.

We therefore welcome the Council's intention to allocate additional sites for development and adopted a new Local Plan. It is essential that the new Plan does not impose constraints to development that suppress housing delivery unnecessarily. It is therefore essential that the local planning authority scrutinise its own evidence on supply and capacity to determine whether these figures are robust and whether there are further sources of supply that could
be relied upon or identified sites are capable of delivery additional housing.

It is noted that the housing requirement identified in the draft Plan currently is a supply-led figure that would not come close to meeting the identified local housing needs of the area and therefore all efforts must be made to find additional sources of supply.

The Wild Meadows site is one such location where the identified capacity of the site is being unnecessarily suppress within the Regulation 18 Plan. The site has been assessed as capable of delivering 14 new dwellings, but the Council's own minimum density target (25 dwellings per hectare (dph) in village locations) suggests that any allocation of this site should be seeking to
achieve a minimum of 28 new homes.

We have previously submitted a development concept that shows 29 new homes within the site alongside new community infrastructure including public greenspace and equipped playspace, and have provided a copy of this concept plan as part of this consultation response.

As mandatory housing targets have been re-established by central Government and national policy is likely to shift in favour of housing delivery (particularly on sites that can be delivered within the first five years of the Plan), there is a clear policy shift towards additional housing delivery. The delivery of at least 28 new homes on the Wild Meadows site would not only
deliver additional housing overall in the short term, but would also double the number of affordable homes that would be delivered on this site compared to the 14 unit estimate currently shown.

Q 59, 60, 61

We support the strategy for sustainable villages within this area and the concept plans for the proposed residential development at Wild Meadows already seek to enhance the public realm and provide new community facilities in Guestling Green, in accordance with this vision.

Guestling Green is an appropriate location for new housing growth and the allocation of the Wild Meadows site would deliver an appropriate scale of development that is commensurate to the size of the settlement. We believe that additional homes could be delivered on the Wild Meadows site in accordance with the Council's own minimum density target.

Q76

We welcome the recognition of Guestling as an appropriate location for growth.

Guestling Green provides an important local Primary School that serves the wider rural area, and the village also provides opportunities for development that can deliver new family housing, affordable homes and community infrastructure that will ultimately improve the overall sustainability of the settlement.

As set out in our response to other questions, the Wild Meadows site has the capacity to deliver new community infrastructure, including public amenity greenspace and equipped playspace that would provide a benefit to the entire settlement. The Wild Meadows site can also deliver 29 new homes at the Council's minimum density target (25 dwellings per hectare), which would
deliver a wide range of market and affordable homes and new family housing within walking distance of the Primary School.

The development can therefore improve the sustainability and viability of the settlement through appropriate growth and a gentle residential density. The settlement has been identified as a potential growth location in the past but the tightly drawn development boundary has prevented new development from coming forward and therefore the new Local Plan needs to be proactive in allocating the Wild Meadows site to ensure that the appropriate scale of growth and delivery of new community infrastructure can be achieved.

The scale of development proposed at Wild Meadows is commensurate to the size of the settlement and provides an excellent opportunity to sustain the settlement and address local
housing needs over the Plan period.

Q77.

We have serious concerns that the Council's intention to build a stepped housing trajectory into their strategy reflects a lack of aspiration to urgently address the under-delivery occurring within the District.

If delivery rates do not improve in the short term then the scale of unmet need will only worsen and the challenge to improve delivery at a later date will be potentially unachievable.

We are concerned that the Council is over-optimistic about its ability to achieve higher rates of delivery without immediate interventions and a step-change in the approach to housing delivery within this Local Plan.

One way to ensure that housing delivery if maximised throughout the Plan period is to review the potential capacity of sites identified as suitable for development and to ensure that the recommended minimum density targets are achieved on all these future allocations.

Building above retail units and redeveloping retail parks to include housing is a win-win. So long as the delivery bays are not overlooked by residential windows, the hustle and bustle of retail happens during the day and it's quiet at night (unlike High St flats above shops where there's a nightlife).

For an exemplar, see the Horton Retail Centre near Epsom in Surrey which provides a small supermarket, pharmacy, chip shop and cafe as well as a mix of apartments and houses. In this area, the Dunelm site, the area opposite Ravenside and the area next to Sussex Exchange (that's already earmarked and cleared for retail) are all possible sites for such a development.

Rother District Council’s current development strategy heavily focuses on greenfield sites such as BAT0014, BAT0026 & CAT0001. I believe to ensure our air and food security we need to solely focus on brownfield development. Specifically, the redevelopment of Ravenside presents a unique and valuable opportunity to meet our housing needs while aligning with our commitment to being “Green to the Core.”
Advantages of Redeveloping Ravenside
Utilizing Brownfield Land:
Sustainability: Redeveloping Ravenside aligns with sustainable development practices by making use of existing brownfield land, thus preserving our valuable green spaces.
Environmental Impact: Minimizing the disturbance to wildlife and natural habitats by focusing on already developed areas.
Access to Amenities and Employment:
Proximity to Jobs: Ravenside offers direct access to a range of employment opportunities in the local shops and restaurants based there, reducing the need for long commutes and supporting a more sustainable lifestyle.
Shops and Restaurants: The site’s proximity to shops, restaurants, and other amenities makes it an ideal location for new housing, ensuring residents have everything they need within walking distance.
Appealing to Diverse Demographics:
Younger Residents: Affordable housing options can attract younger residents who seek proximity to jobs and a vibrant community.
Older Generation: Well-appointed apartments with sea views can cater to the older generation, providing comfortable and scenic living spaces.
Economic and Community Benefits:
Revitalization: Redeveloping Ravenside can revitalize the area, attracting investment and boosting the local economy.
Community Integration: Creating a mixed-use development fosters a sense of community and integration, benefiting all age groups.
Proposed Development Plan
Mixed-Use Development:
Residential Units: Build a mix of affordable and market-rate housing, including family homes, apartments for young professionals, and senior living accommodations.
Retain the commercial Spaces: Integrate commercial spaces for shops, restaurants, and offices to maintain the area’s economic vitality.
Infrastructure and Accessibility:
Public Transport: Enhance public transport links to connect Ravenside with other parts of Rother, reducing reliance on cars and promoting greener travel options.
Pedestrian and Cycle Paths: Develop pedestrian and cycle paths to run along the beach and encourage active transportation and improve accessibility.
Community Spaces and Amenities:
By focusing on the redevelopment of Ravenside, Rother District Council can create a thriving, sustainable community that meets the housing needs of our residents while preserving our greenfield sites. This approach not only aligns with our environmental commitments but also promotes economic growth and enhances the quality of life for all.

Sites which have been identified and agreed must be developed before seeking new sites.
It is unacceptable that sites which have already been agreed are not developed.
In addition, changes of development type should be considered where the original purpose is no longer required. For example, in Westfield a former residential care site only has permission for a similar development purpose but with the residential care home being granted permission to extend the original site could now be considered for an alternative development type

Serious concerns that you have identified flood risk areas and intend to build housing within a very high risk flood area. On land searches Pages Lane currently falls within a high flood risk area-in the last 3 years Westcourt drive has flooded more than I have ever known it to in the 40 years I have lived in the area. The end of our garden now floods and we have very real concerns that 25 houses at the end of our road will add further to this flooding and put our properties at risk. If Rother continue with this building despite the flood risk, if current houses are impacted would we be able to claim compensation from Rother council for negligence?

There are many brownfield sites ripe for re-development. Perhaps a new planning approval and tendering process, to ‘fast track’ such development proposals and planning applications. Others have mentioned opportunities at Ravenside, Sussex Exchange, plus land at Battle Station. The land at John’s Cross is an option although not suitable for non-drivers unless transport links to the town. It would suit car drivers commuting to work in either Hastings or Tunbridge Wells, all of whom have the means to use Battle town too.

Please see our full representations and response to Q51

Please see attached comments from Burwash Parish Council.

Please see attached submission.

See attachments for full submission comprising:
- Homes England - Draft Reps R18 plan and Hodson's Mill Robertsbridge (which also contains Appendices A and B);
- Appendix C - Landscape Statement; and
- Appendix D - Site Boundary

The submission contains general comments on the Local Plan and HELAA sites SAL0003 and SAL0024, as well as answers to specific questions as set out in the Local Plan.

Please see attached submitted document for full comments.