See attachment for response.

The snappy punchline of 'Green to the core' and 'Live well locally' is a bold attempt to show a commitment to protecting rural communities and local ecology but your HELAA land allocation of CAT0001 and potential site CAT0016 in Catsfield fly in the face of these claims/promises. The proposal of 60 new houses (some proposing to be built on protected AONB land) in this small rural village (doubling the size of the main village), is absolutely shocking and I object strongly to these sites being included for allocation in this plan. These proposals would not only destroy ancient woodland, biodiversity and protected wildlife habitats, they would also severely impact the lives of local residents with increased pollution and a serious decline in the already insufficient utilities and local infrastructure.
This site is also within a high flood risk area.
See further comments on HELAA Part 2 Chapter 3.

Please see:

- Mr John Lovering - Rother Draft Local Plan 2020 (comments of draft Local Plan)
- Land off Uckham Lane - Location Plan
- Landscape Feasability Study
- Transport Report
- Access Plan

Thank you for consulting us on the Rother Local Plan 2020 - 2040 Draft (Regulation
18) Version (April 2024). Eastbourne Borough Council (EBC) welcomes the
opportunity to engage with Rother District Council (RDC) on their local plan,
particularly due to the requirement to engage constructively, actively and on an ongoing basis in relation to cross boundary planning matters under the Duty to Cooperate in accordance with the Localism Act 2011.
EBC notes that the draft Local Plan has two overall priorities: “Green to the Core”
and “Live Well Locally”:
• Green to the Core emphasises the need to consider the impact of planning
decisions on the climate emergency, biodiversity crisis and the High Weald
National Landscape.
• Live Well Locally recognises that in all planning decisions, the goal is to create
healthy, sustainable and inclusive communities.
In 2019, EBC declared a climate emergency and set an ambition to be a carbon
neutral town by 2030. Therefore, EBC strongly supports the need for addressing
climate change through the Rother Local Plan, and welcomes these overall priorities,
particularly ‘Overall Priority 1 – Green to the Core’ in respect of reducing carbon
emissions through planning for sustainable transport, net zero housing and
renewable energy.
EBC supports the spatial strategy to direct growth towards existing sustainable
settlements where there are existing services and sustainable transport networks,
and particularly urban intensification and redevelopment across the district in
appropriate and sustainable brownfield site locations.
We note the ‘standard method’ housing need in Rother of 14,000 new homes over
the plan period at an average of over 700 homes per year is significantly in excess of
the average of 200 homes that have been delivered in Rother per year since 2011.
Given the significant constraints in the form of national landscape designations and
environmental designations, it is appreciated that that the evidence supporting the
draft Local Plan only identifies potential land for between 5,158 and 7,287 new
homes to 2040, which is likely to result in unmet housing need. EBC notes that the
Rother Local Plan does not include proposed site allocations at this stage.
We can confirm that EBC has received a letter from RDC dated 28 June 2024 to
make us aware that it is unlikely that RDC will be able to meet its housing need in full
and in accordance with the NPPF, to formally ask whether EBC would be able to
meet any of Wealden’s unmet housing or economic development needs. We will
respond to this letter separately.
EBC do not have any other specific comments to make on the proposed policies or
questions asked within the consultation document at this time.
However, we would welcome the opportunity to continue Duty to Cooperate
discussions and to further discuss strategic matters such as the cumulative impacts
of development and growth on the Pevensey Levels and transport infrastructure.
EBC is committed to engaging constructively with RDC on relevant strategic cross
boundary matters in accordance with the Duty to Co-operate, and the production of a
Statement of Common Ground.

Housing and Employment Needs:

Like other local authorities in East Sussex, Rother’s housing need is a major strategic planning issue facing the district. WDC understands that RDC have taken a positive approach to the assessment of housing development potential within the district to establish whether housing growth could be significantly increased but RDC’s delivery rate for new housing over the Plan period is still likely to be substantially short of the levels of the housing need identified by the ‘standard method’, as prescribed under paragraph 61 of the National Planning Policy Framework (NPPF) (December 2023).

We note that the Government’s ‘standard method’ provides an annual housing need figure of 733 dwellings per annum (dpa) for Rother District (base date 2023). However, the draft Rother Local Plan confirms that at the current time, RDC is only able to identify a potential supply of between 5,158 to 7,287 dwellings, at an average rate of 258 to 364 dpa, against the Government’s ‘standard method’ target of 14,660 dwellings if extrapolated over the proposed twenty-year plan period from 2020 to 2040, which represents a significant shortfall. WDC notes that this would result in a potential unmet housing need of between 7,947 to 9,502 dwellings within the plan period.

Paragraph 5.4 of the draft Rother Local Plan confirms that the Plan period is 2020-2040. It is noted that RDC could bring forward the base date of the draft Rother Local Plan (i.e. to 2023) to reduce its potential unmet housing need, although it is recognised that paragraph 22 of the NPPF stipulates that strategic policies should continue to look ahead over a minimum of 15-year period from adoption. None the less, this should be considered for the Regulation 19 version of the Rother Local Plan.

We also note that the draft Rother Local Plan identifies a need for 74,189 sqm of
employment floorspace that was established through the Rother and Hastings joint Housing and Economic Development Needs Assessment (HEDNA) (2024). The draft Rother District Plan confirms, except for storage and distribution uses (Use Class B8), that employment needs can be met through identified sites in the draft Rother Local Plan, but flexibility needs to be allowed for growth in rural locations and the changing economic market and projections. Overall, as set out in Figure 11 (page 118) of the draft Rother Local Plan, the current supply of employment floorspace in the district of 106,600 sqm represents a potential oversupply of employment floorspace of 32,411 sqm against RDCs employment need, and this is supported by WDC.

It is recognised that Rother’s plan area is significantly constrained by environmental
designations, with approximately 83% of the district being within the High Weald National Landscape, and a further 7% of the district containing other nationally or internationally important habitat designations such as the Pevensey Levels or Dungeness complex of habitats sites, which prevents higher levels of development coming forward in those locations.

We note from your Housing and Economic Land Availability Assessment (HELAA) report (April 2024) that RDC’s ‘Call for Sites’ has remained open following the completion of the initial ‘Call for Sites’ period in December 2020, and that the Council will continue to accept site submissions beyond the publication of the draft Regulation 18 Rother Local Plan. WDC does support the early positive steps that are being taken by RDC to take forward the proposed development strategy.

WDC has noted the response from RDC dated 10 May 2024 in response to our letter on unmet housing and employment needs of WDC (dated 25 April 2024) to make us aware that it is unlikely that RDC will be able to meet its own housing requirement, and therefore, is unable to accommodate some, or all of WDC’s unmet housing need. It is also noted in that letter that although RDC may be able to meet its employment needs through identified sites in the draft Rother Local Plan, it has been identified that RDC needs flexibility to allow growth in rural locations, and to account for changing economic market and projections. It also notes that the Functional Economic Market Area (FEMA) for RDC is shared with Hastings Borough Council (HBC). Therefore, RDC confirmed that it is not able to assist with meeting either housing or employment needs.

WDC is committed to maintaining continued close working with RDC on this strategic issue, and we look forward to progressing a Statement of Common Ground (SoCG) that will confirm, amongst other matters, the level and distribution of identified needs within both plan areas once further work has been undertaken for both emerging Local Plans.

Individual comments made on specific policies as logged

Support for representations made by Ticehurst Parish Council.

Individual comments made on specific policies as logged.

Please also see attached a draft policy for Bewl Water drawn up by the Northern Parishes Group.