I object for any new housing until such time as the infrastructure in or Town is resolved. 2 more doctors surgeries to close (or closed) me paying that residents from the center of Bexhill may have to travel to Pebsham or Ninfield. That’s adverse to your climate emergency

object to the proposed housing target because it is not realistic, justified or deliverable given Rother’s severe environmental and infrastructure constraints. The housing need figure is driven by the national standard method, which produces a requirement nearly three times higher than historic delivery rates, despite Rother consistently failing to meet much lower targets.

Around 90% of the district is constrained by National Landscape designation, protected habitats, flood risk, heritage assets and ancient woodland. The Council’s own evidence confirms there is insufficient suitable land to meet the identified need, yet the Plan still proposes a level of housing growth that exceeds what the district can sustainably accommodate.

Setting an artificially high target risks over-allocating sensitive sites, increasing flood risk, harming protected landscapes and undermining public confidence, rather than delivering genuinely sustainable and achievable development.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

NHS Sussex - PC object to the proposed housing target unless firm commitments are made to deliver healthcare infrastructure alongside housing growth.

Additions of 495 dwellings per annum, will significantly increase demand for GP services. Existing practices in Rother are already under pressure, and additional growth without mitigation will worsen access to care and place unsustainable strain on services.

The Local Plan does not provide sufficient assurance that primary care infrastructure will be delivered in parallel with housing. Without explicit policy support and secured developer contributions, there is a risk that housing will be occupied before adequate healthcare capacity is in place.

The Plan must explicitly recognise primary healthcare as essential infrastructure and require timely delivery or expansion of GP facilities to support sustainable communities. Without this, the housing target is not supported.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

The target declared is extremely ambitious and appears to ignore road capacity constraints and infrastructure shortfalls. Current building rates are less that the target and water , sewage, schools and Medical Services are already overstretched.

The targets appear to be 'top-down', as proscribed by government. I have seen no evidence of this being validated by bottom-up analysis, which links supply with actual demand.
Whilst there may be a crude sense of a legitimate need for housing volumes as specified, the absence of bottom-up analysis means that supply is unlikely deliver housing were there are jobs, schools, transport links and the necessary local infrastructure (including utilities), nor the right type of housing for people who can afford, or want, the housing being delivered. This is target led 'finger-in-the-air' planning.
A more robust and targeted analysis might get my support.

Whilst I accept that the numbers are driven by central government policy I am concerned that the projected fall in birth rate will render many of these housing developments unnecessary.

Q1
Strategic Spatial Objective 6
6.There is no overall strategy specified as to how economic growth in Rother is to be achieved. This will be essential to create demand for housing and services from the younger strata of the population otherwise Rother will continue to be a retirees destination as is much of the UK south coast.
Q2
Housing Target
3.4 The target of 8,427 over 17 year is unrealistic. The proposed sites already tend to occupy the only land within the local development area available to the north and west of Bexhill since development to the east has been ruled out and the southern coastal boundary precludes development. The timescale is significant and the possible effects of climate warming and sea rises that my well cause changes that might well prevent development in some area within this timescale. Consequently, a shorter time horizon of 5-10 years would be more sensible. Furthermore, all new dwellings should have energy saving measures such as high grade insulation, roof mounted solar panels (necessitating orientation of roofs to allow adequate solar insolation capture) and grey water recycling and storage tanks inbuilt.
Q3
Town Centre Usage
3.3. While possible uses are identified there is no mention or recognition of the need for adequate town centre parking to cope with increased footfall and, presumably, economic activity.
Q5
Infrastructure
7. Not only a focus on but early implementation of infrastructure will be essential for the Road Network, Rail access, and especially adequate parking at Stations. Adequate waste water disposal and fresh water provision must be in place prior to the planned occupancy of any new housing development.
Q10
Vision and Development Strategy for Bexhill
While this strategy recognises the limitations of the A259 and Little Common Roundabout it does not mention that the A259 is an already capacity limited highway ( regular traffic queues back to the Custom Café and beyond) and that all connections to this highway are really only country lanes that have very limited capability to handle more traffic. Mention is made of a possible bypass that would clearly relieve the problems that now exist on the A259 but no timeframe is proposed and all of the new development proposed in West Bexhill will only add to the already heavy traffic.

Q17
West Bexhill Site Allocations
BX18
This appears to identify most of the essential infrastructure upgrades essential if the West Bexhill area is to be further developed. However, it is critical that most of these improvements are achieved before any new house building commences.
BX19 This proposal is to reduce parking space and increase housing and is admitted to be contrary to national planning policy. I object strongly to this site.
BX20
This site has been subject to planning action for nearly 10 years. It still offers dangerous access onto the A259, and Spindlewood Drive as well as drainage problems threatening the Pevensey Levels with its identified environmental sensitivities. There is no adequate sewerage capacity available that the site could be connected to. I object most strongly to this site.
BX21
This site would add to the issues raised by BX20 and is unsuitable for development. I object to this proposal.
BX22
This proposal creates even more problems requiring solution as does BX20 and BX21. Such a large proposed development would create and even bigger threat to the Pevensey Levels as well as destroying the views towards the sea. There is also no access to the A259. I object to this policy.
BX23
Yet another very sensitive site with no direct access to the main road. Although cycle paths are proposed there is no plan or obvious way to extend these on a route following the A259. There is no access to a sewerage system of adequate capacity. I object to this site.
BX24
Another land locked site with no access. Requires use to proposed site BX23. I object to this site.
BX25
This site is necessary to develop medical facilities for Little Common and approved sites. It should have been developed several years ago. This is an example of infrastructure not being provided in an adequate timescale. I support this site.
BX26
This land locked site has too many constraints that must be overcome. I object to this site.
BX27
Apart from the obvious lack of infrastructure access to the A259 is on a hill. Such a large proposed development would add significant extra traffic onto the A259 for which there are no proposals to alleviate. I object to this site.
BX28
This site is in a very sensitive environmental location and isolated from the rest of Bexhill. The access onto the A259 is difficult and together with the other sites proposed to the east will provide major ongoing hazards to traffic on the main road. I object to this site.

Too much land is being lost. The number of people envisaged can not be fed from the land available (this is also true for the whole of Britain). The infrastructure of this area is inadequate at present for both the road systems as well as other forms of transport and many further facilities such as Surgeries (medical as well as dentistery). The number of houses proposed only makes it more difficult to provide the necessary infrastructure and services, including employment for the number of people envisaged.

In Etchingham there are already vacant properties, so there is no need for this number of new houses for local people or anyone else. South East Water/the Planners did not provide a proper sewage system for the last development, so several times a year ,raw sewage is deposited in a local field which finds its way to the River Rother. With the number of houses proposed there needs to be a full explanation and plan for extra places in the local school, doctors, traffic concerns, dentists, parking and electricity supply. At present all these facilities are at bursting point. It would be interesting to see the Council’s full reasons and research as to why we need this number of houses in this area, as so far we have not seen any of the above.

Anchor Hanover, England’s largest provider of specialist housing and care for older people, supports the inclusion of a specific policy on older persons’ housing, given the significant and growing need. The policy should also include a clear numerical delivery target for older persons’ housing to ensure identified needs are met over the plan period.

Retirement/sheltered specialist housing types should be supported, to accord with national planning policy. Your housing needs assessment says you need 8,427 dwellings over 17 years.

We recommend making specific site allocations for older persons’ housing, rather than relying on M4(2) or M4(3) standards, which are not tailored to, or reserved for, older people. Allocations should consider the minimum viable scale for such housing, at least 65 units per development.

We recommend that a more flexible approach to housing mix is taken for older persons’ housing. Mixed tenure buildings can create market challenges and affect viability.

These targets are all well and good on paper but to keep chasing a target without guaranteed infrastructure is a folly. It’s like making a car but having no engine to put in it.

Our infrastructure is insufficient especially roads, parking is already a nightmare with folk often parking on double yellow lines in High Street.
The steam railway is another disaster about to come into the village bringing 2 new level crossings one in Northbridge st and other on A21. Traffic will be horrendous .
Agree with need some new houses but not in such huge quantities .
Schools and doctors will not be able to cope

I recognise that Rother District faces significant environmental constraints, including the extensive coverage of the High Weald National Landscape and protected habitats, which limit opportunities for large-scale development.

However, the substantial difference between the nationally assessed housing need and the proposed housing target suggests that it will be important for the Local Plan to maximise opportunities for sustainable housing delivery wherever possible.

In particular, the Plan should ensure that suitable opportunities for small and medium-scale housing development in and around existing settlements are fully explored, especially where sites relate well to existing development and can support the vitality of rural communities.

Ensuring that such opportunities are carefully assessed and supported where appropriate will help the Council make the most effective use of available land while still protecting the district’s important environmental assets.

I know this is being worked out in terms of national policy but we can not continue to build housing without infrastructure. It is ridiculous to think that the local area can accept a further 500 odd houses without more local jobs and improvement to the road network. Over 25% of working age people here are economically inactive... how are they supposed to buy a new home? The housing market locally is stagnant.
This is contrary to the Green to the core policy by building over the countryside and build more houses using resources, generating more waste. This is contrary to the Live well locally policy because there is no or poor infrastructure in the area to support the existing residents let alone further development and future residents.

The proposed housing target of 8,427 dwellings (495 per annum) is not supported by credible delivery evidence.
Historic completion rates within Rother have averaged approximately 200 dwellings per annum over a sustained period. No clear trajectory has been presented demonstrating how delivery will increase to more than double this rate.
Without such evidence, the Plan risks failing the soundness test of effectiveness (NPPF paragraph 35), as it is unlikely to be deliverable over the plan period.
Furthermore, approximately 92% of the District lies within the High Weald National Landscape (HWNL), where there is a statutory duty under Section 85 of the Countryside and Rights of Way Act 2000 to conserve and enhance landscape character. Inflated housing targets risk driving unnecessary allocations within protected landscapes.
The housing requirement should be reassessed to one reflecting the environmental constraints and actual build out rates. There are already substantial unbuilt permissions in Rother. Until these are built out there is not sensible point in allocating more site as they by definition will in most cases damage the HWNL

Of course we need more housing but the local infrastructure is not considered when this happens. I am finding it increasingly harder to walk and cycle around already due to the constantly increasing traffic and that is my much preferred method of travelling. We MUST change this for the sake of everyone’s health. You rarely see children and families on bikes or walking locally as they feel it is too dangerous. I’m fed up with all the talk about alternatives when developers put forward planning applications. They are just paying lip service to active travel and nothing ever changes. Until we do something about this Sussex will soon become gridlocked with traffic.

Burwash is quite protected which I am pleased about. But it's the type of houses that get built, we have a situation where young adults can't live home for financial costs, elderly can't downsize to bungalows within village area. Working families are not being provided for in our area at a cost they can afford. Affordable housing has not been delivered in our village. Our site was rejected HELAA but as I had noted we would do an RES, RDC listed as potential as RES- if the tangible benefits offset the damage to landscape it would be considered. But RDC won't put in allocated sites so therefore no developer will invest. So we follow the old path, RDC select land noting developers have to provide affordable housing. Current bill from lists medium sites 10-49 houses (if approved march 26) states no legal requirement for affordable housing on site.

Increases in housing bring increases in council tax to RDC/East Sussex. Developers will reap financial benefits as well. Residents need information on how infrastructure is going to be supported with growing population

Obviously housing is important to everyone, but must be suitable to the needs and affordability of the tenants plus preserving rural habitats and prior tenants .

There are far to many houses being built at the west end of the village, when Mr. John Slater Planning Ltd examined the Peasmarsh NPD
in May 2023 , he advised to many sites at the west end , why were there no sites allocated near the Primary School in School lane, so site PE1 would be a site suggested preferable to be near the school at the east end of the village ,also near key facilities like recreation ground, development needs to be be equally spread over the village not all in one area , after all the The Primary school is under subscribed and this is a Key facility of the village, development site PE5 in the maltings is central to the centre of the village , recreation ground, school, and the village hall which as described by the examiner Mr. John Slater Planning Ltd.

Beckley and the surrounding villages as well as Rye need more affordable homes for young people. This is in both the private and social housing sector. The reasoning behind this is social cohesion and support - to keep families near each other and within the communities they work in, were schooled in and brought up in. This will help all ages socially and economically within our communities.

See attached.