RDC has formally sought views upon the Draft Local Plan. The comments below represent my response to this invitation.

A/ THE DRAFT PLAN. (the Plan):
The Plan lacks ambition,
Repeats the errors and failings of the existing and previous Local Plans,
Is discordant with its failure to adopt an "infrastructure first" approach to new development
is short sighted in its allocation of possible housing sites
1/ The RDC "State of the District" (SD) report 2025 sets out clearly why an ambitious Plan is required. RDC is ranked 135 out of 317 English local authorities (1 being highest) with higher percentages than the local average claiming a range of welfare benefits. Though employment is generally above regional and national averages, gross median pay is substantially lower at £31k compared with England's average of £38k. Significantly this negative gap of 17.5% is increasing. Employment is dominated by small and micro-businesses with businesses employing more than 250 people comprising just 0.02% of total businesses in the District. (sources: RDC State of the District report). There are correlations arising from this data supplemented by the facts that working age people in the District have lower than national average degree level education (38% v 43% in England) (source:SD). With the District's working age population being 51% of the whole, those under 16 comprising 17% and, significantly, and growing, those over 65 representing 33%, and with the employment and income profiles set out above, it should be a clear objective of the Plan show intent to improve both economic and social facets across Rother. As drafted the Plan demonstrates no such intent or ambition.

2/ The draft Plan repeats much of what has been seen in previous Local Plans but which has demonstrably failed to be the economic drivers expected of them. The number of existing, but undeveloped, "Enterprise Park" sites is testimony to this failure, but the draft Plan simply repeats them. Unless a much more radical approach is adopted future RDC "State of the District" reports will show a greater, and accelerating decline of weekly earnings compared with the national average, increasing demands for welfare benefits and a continuing exodus of higher educated working age people to other areas where their aspirations can be achieved. The "gap" is likely to be filled by more people of pensionable age with their consequent demands on the NHS and other age related benefit services.

3/ The draft Plan sets out no clear and practical approach to the provision of the infrastructure necessary for the successful and sustainable development of the sites allocated within it. Specifically, the District has a woeful primary road network comprising a discordant and fragmented series of routeways connecting to the principle east west and northerly Strategic Roads (the A259 and the A21). There is no defined "northern bypass" avoiding the urban areas for through traffic, the vestigial Link Road joins the A259 within Bexhill town and the Sidley bypass arm peters out on the Battle Road. The A259 is already noted as being over capacity. The Draft Plan refers to the Jacobs Study of three possible "extensions" to the Link road, yet none offer the correct solution. Clarity is needed about the purpose of any western extension of the Sidley bypass or an alternative route connecting to the A259 west of Bexhill with equal clarity about where such a road needs to connect to the north and west of that town. It is further noted that the Plan repeats suggestions from the current Local Plan suggesting improvements to Little Common roundabout. Such improvements are not specified. However, Little Common roundabout has already been subject to very limited modifications as a result of planning consents recently granted. It is noted that any further changes will be very difficult to accomplish. Not only do neither National Highways, nor East Sussex County Council (Highways) own or control much of the surrounding paved areas alongside the public footpaths (they are private forecourt spaces), but the roundabout itself is elongated with four points of entry onto tight turning circumference. Dual lane traffic movement is highly restricted, and impossible when articulated vehicles are maneuvering. With shops, a pub, a bus stop and other built features bordering the roundabout site it is quite unclear what, if any, changes can now be made. Moreover, were these to be possible, the question must be asked ; "why have they not been carried out already?"
The draft Plan assumes foul and drinking water facilities will be available or will be provided at some, indeterminate future date. This is disingenuous and flies in the face of reality. The many problems across the water industry have been well documented and RDC has experienced the failings of our local suppliers, Southern Water and South East Water, to manage their businesses in the ways we should all expect. This said, it is noted that RDC expects new developments to be approved only where connections to foul water systems "with adequate capacity" already exist. This vital caveat is crucial to decision taking about any planning applications for those sites. Officers must hold fast to their principles on this point, and it would not be appropriate for them to deflect this issue of system capacity by simply defaulting to the Water Industry Act which enables developers to hold a statutory right to connect to drainage systems. A right to connect is not the same as a right to connect to a system with adequate capacity. Accordingly, it is suggested that the RDC condition of adequate capacity should be more strongly worded to avoid any misunderstandings.
The assessment under point 1 above points to increasing pressure upon the already pressurised NHS, schools and other social services in the District. Again, despite an intent to build a considerable number of new homes in the District, mostly in Bexhill, no commitments are provided about the provision of the essential support services that will be required.
The Draft Plan fails to offer an "infrastructure fist" programme, or, even an "infrastructure and development integrated" programme to ensure essential services are provided contemporaneous with housing and other development. Without such committed and funded programmes, intolerable burdens will be imposed on already well overstretched social services.

4/ In housing development terms the District is constrained by its geography and topography. The coastline, wetlands to the east and west and the National Landscape (AoNB) to the north impose a range of specific challenges if housing sites are to be allocated as required by central Government. The draft Plan continues the historic approach of allocating the majority of new housing around Bexhill (Ref: the Emerging Local Plan site allocations). The small towns and villages within the National Landscape designated area make a contribution to the whole but this is relatively small in aggregate terms. I will make some specific comments about the allocations in the Bexhill West Growth area below but note here that in the Plan sites in Bexhill are allocated to the north and west of the town. Crucially, the Plan observes that the main reason for this is that the protected wetlands of the Glynde valley dividing Bexhill from St. Leonards precludes further development in that area. The Pevensey Levels to the west of Bexhill provide an equally inviolate buffer from development to the west of the town. The site allocations in the draft plan to the west of Bexhill (BX 20 to BX28) for 1923 new homes, should they all be approved, would leave no further land available for development west of Bexhill. This would be equally true should not all the sites be approved for development. Either way, RDC would have only one remaining direction for alternative site allocation within this Plan or for, what might be called, the next round of site requirements looking beyond the current allocations. The only way any such further sites can be found must be by allowing some form of development in larger volumes within the National Landscape (NL). Such proposals would, necessarily, have to be very carefully assessed and considered within the context of NL limitations. I venture that a large number of village/small town extensions for housing development of volume would not be appropriate. I propose that the alternative of a new large village or small town concept, integrating homes, schools, shops,employment and health services and connected to rail and road networks would be preferable. The simultaneous provision of these forms of infrastructure would be essential for the successful creation of a vibrant, sustainable new community which could be focussed towards upwards of 6,000 new homes. Choosing a site for such a new community would need research, but, given the restrictions already outlined above on future development near Bexhill, the draft Plan should include proposals to bring forward a new community proposition as soon as possible. In this way the many and various important studies required to create a truly integrated, planned and funded master plan for the chosen site can be undertaken in a properly project managed way, avoiding the crisis managed approach that would become necessary if action is delayed. My own research has identified a possible site. This is in the valley to the south of Robertsbridge. Ready access to the railway and A21 would be available, the new community could be connected to and enhance Robertsbridge without imposing on the historic heart of that town and, visually, the new community would be relatively hidden from view (limited views mostly from the A21 Robertsbridge bypass). The visually more open area of the "high" National Landscape area would be untouched.
I do not believe RDC can defer action to include this form of proposal from inclusion in the draft Plan. Were it to do so, it would be abdication responsibility for an action that will inevitably be required. Not to start now will make decisions later much, much harder with delivery of resultant development deferred into the far distance. Starting now, offers the prospect of the start of delivery within the draft Plan horizon, with various agencies, (highways, water, health, education) being able to simultaneously plan, budget and fund their contributions to the integrated whole.

B/ HOUSING SITE ALLOCATION - WEST BEXHILL:
Ref: Rother Local Plan 2025-2042 - Development Strategy and Site Allocations. Part 4 - Site Allocations. section 7 - Site Allocations.)

BX19; I object to the removal of this public car park which enables folk to enjoy the coastline at Cooden Beach, where, in summer especially, parking close to the beach is a valuable asset for families. Parking distances away, on public roads, is a burden on families who will have buggies and beach equipment to manage.

BX20: This site is already subject to lengthy debate and assessment. Despite an Outline planning consent having been granted, the developers have failed so far to produce acceptable proposals for a highway connection to the A259 ( Barnhorn Road), surface water drainage and ecological objections. Indeed their most recent drainage ideas were seriously retrograde and did not comply with earlier principles. It is noteworthy that these issues were first raised as concerns by objectors to the RDC DaSA some 9 years' ago. It remains very unclear if this development can proceed.

BX21: This site would become an extension to the development of BX20. As such it would result in an increase in traffic accessing Barnhorn Road for the intended junction. However, this junction is not yet capable of meeting the National Highways requirements of the Design Manual for Roads and Bridges within the BX20 planning application process so it is impossible to see how this site can be allocated . National Highways has previously stated that the maximum number of houses it would accept having access via the Barnhorn Road junction under BX20 was 160 (ex the caravan site). The inclusion of BX19 takes this above that threshold.

BX22: this allocated site has no point of access to the A259, Barnhorn Road, identified. As such, and given that access cannot be via the BX20 access point for reasons of traffic volume and non-compliance with the Design Manual for Roads and Bridges, it is difficult to see how this site could possibly be treated as "deliverable". It is clearly not deliverable without an access point. RDC should be clear about where this will be or remove this site from the allocation.

BX24, BX26 and BX27: These three sites are taken together as my comments are common to each of them. Fundamentally the access of these sites onto the A259 Barnhorn Road, create grounds for deep uncertainty about the deliverability of the sites for development. The use of Coneybarrow Lane is denied and the Barnhorn Road in the vicinity of the potential alternative access points, topographically difficult, subject to sight line restrictions because of road curves and existing side road/cul;-de-sac access points. National Highways will require compliance with the Design Manual for Roads and Bridges if it is to accept further junctions onto this busy and overcapacity Strategic National Highway. It is hard to see them accepting these proposals.

Generally - BX20 to BX 28:
These sites continue the RDC approach of allocating sites in an unplanned way. Each is regarded individually with no declared master plan for the housing development or any supporting infrastructure (of which there is little). The result is a series of incoherent individual housing neighbourhoods (BX23 excepted) - very far from placemaking and lacking in any form of collective community.
Beyond this, when considering the traffic impacts, effects on the protections of the Pevensey Levels and drainage intentions, it is necessary to look at the potential cumulative impacts. No mention of these is made in the Plan, yet it is already known that National Highways has safety and traffic volume concerns about the A259 from Pevensey Roundabout into central Bexhill. The site allocation proposals will exacerbate these, already unacceptable highways concerns.
Foul water disposal is a further area of concern. The existing sewer in Barnhorn road is too small - even before the current Rosewood Park development was approved, with resultant foul water flooding a frequent event (if mainly in winter). Southern Water acknowledges that it has no plan in the pipeline to fund and commission any upgrades to the system so adding up to 1900 extra houses will exaggerate the current pollution problem. This cannot be allowed to happen - and, again, the cumulative impact of the proposals must be the starting point for assessment of future drainage requirements if foul flooding is to be avoided. At the minimum a clear, defined upgrade plan, costed, funded and programmed, must be in place before any planning approvals are granted for these sites, noting again the condition of adequate foul water capacity listed in the Plan details for each site.
Strict protections for the Pevensey Levels must be ensured with cumulative impacts central to decisions taken. It is noted that each site specifies the need to ensure compliance with the Habitats Regulations.

Finally, the risk that some of these sites may not be developable reinforces the strategic proposition I set out in point A/ para 4 above. If RDC cannot progress with any of these sites, or those elsewhere in the draft Plan, it will be forced to look in the designated National Landscape for volume sites. I urge that it does so now and incorporates a proposal into the next iteration of the draft Plan.

I commend these comments to you.
Yours

Q2 Target unrealistic given protected High Weald National Landscape; no evidence of local housing need on the scale suggested; inadequate infrastructure for current population.
Q3 Much stronger emphasis and specific localised plans for employment opportunities needed – particularly, for example, regarding tourism, green energy development and retrofitting, sustainable farming, rural skills and crafts etc.
Q5 Before housing numbers can be determined, revised Infrastructure Delivery Plan needs to specify detailed commitments rather than targets from agencies regarding: water supply, drainage and sewerage capacity; road, rail and bus capacity; energy supplies; health infrastructure; SEN provision, community parking provision etc – to ensure whatever housing target is finally agreed can be sustained.
Hurst Green requires a bypass/relief road in order to thrive as a community economically, socially, etc.
Q7 Housing densities of 35 per hectare is too high – much higher than any other area within Hurst Green.
Q56 HG1 and HG2 already granted planning permission – 54 houses.
HG3 – as this is a relatively sustainable location close to the village centre some reduced density (35 per hectare is too high) housing could be accommodated but community parking provision should be a condition.
HG4 – this development should be rejected: 150 houses is a major development completely out of keeping with a High Weald village; it would be a prominent visual intrusion on the landscape; there is no evidence of housing need on this scale in the village; and there is insufficient infrastructure existing or committed to accommodate such a large increase in population.
The eastern boundary of the above site outlines and existing village development should be considered as a potential relief road route for Hurst Green.

See attachments.

We have only just been given the details of the planning for new housing estate. Upping our proposed housing by 487%. This would seem totally unreasonable. In your own rules already laid out this Cannot Be Done. This plan seems totally developer led. It has no foundation of need. Surely councillors should be protecting our small green spaces. Land in the area is bought as an investment and left to rot. Then sold at a large profit and the council facilitate this..Why is this being pushed at the last minute. This land has had wild life netting around for 12/18 months. I am also writing this on behalf of Mr&Mrs [redacted] who have difficulty with a computer.

Dear Rother District Council,

I sent a long response to your previous Local Plan consultation and I
have little to add. I think the plan is largely delusional and has no
relationship to the harsh reality of living in Rother. The roads are
difficult to drive on and we have had four new tyres in the last few
years, the rural bus service is irregular and unreliable, the local GP
Surgery is oversubscribed. In Fairlight the issues of flooding, surface
water, drainage and sewage, make life difficult. One resident tested
positive for ecoli and their family frequently experience nausea from
sewage incidents.

The Central Government reliance on private sector developers building
new homes to grow the economy has little to do with planning
applications. Meeting the Government housing targets will not meet the
needs of those on the lowest incomes in temporary accomodation. Quite
the opposite, it will increase the number of buy to let landlords, air
b&b's and housing with fleecehold arrangements, paying management fees
for garss cutting, SUDS maintenance.

It would be more honest to start with the data of how many planning
permissions have already been granted in Rother.

How many empty properties are there?

How many brownfield sites?

How many under occupied houses are there?

How many times has Rother prosecuted any developers or served any
injunctions for TPO's?

We live in Fairlight near the doomed Market Garden Development, now the
subject of national research due to the environmental harm caused and
the fact that one of the houses is built so near a watercourse, the
stream bank has collapsed. This will be part of Rothers legacy, all be
it the Planning Inspectorate approved it at the end, but It was always
supported by Planning Officers. The "Landscape Management Plan" removed
all the historic hedgerow, most of the trees and shrubs. Only one house
out of 16 sold to another developer. The rest have had to go to rent as
no one will be able to get insurance. Never an apology, never any face
to face meetings with residents. 17 individuals are moving out of
Fairlight as the Market Garden Site is such an eye sore. 4 households
have already left.

I am opposed to the East Field/Wakehams Field development as there is no
demand for housing that has no walkway to the village. You have to cross
the main road twice and on a blind bend across a fast road. The repeated
attempts to build on this underwater site make people move out of the
village.

We will be glad when Rother is no more and we are part of a unitary
authority with a functioning complaints department.

When Developers make planning applications it should be Southern Water
that is required to provide proper data: how many storm overflows, water
quality testing, how many man hole covers lifted, how many call outs.
Planning should be data driven, not "Planning Income" for cash strapped
local authorities.

I'm sorry if this response does not meet your Consultation format, but I
don't have time to fill out the form it was too long.

See attached representations in response to questions 2, 3, 4, 6, 7, 8, 10, 12, 14, 17, 23, 38, 61, and 68

Please see attached response, responding to questions 1 (Strategic Spatial Objectives), 2 (proposed housing target), 12 (Vision and development strategy for Battle and Surrounding Settlements) and 38 (proposed site allocations in Catsfield, specifically Policy CT3).

1
The Strategic Spatial Objectives appear positive at first glance, but on closer inspection there are clear inconsistencies.

For instance, the aim to protect the natural environment and historic landscape is difficult to reconcile with the allocation of four out of five sites in Peasmarsh on greenfield land (PE1–PE4), including development on elevated ground at PE3 which would dominate the village.

Similarly, the objective of delivering housing aligned with local incomes does not reflect economic reality. Local wages err towards minimum wage, meaning even dual-income households are unlikely to afford homes at current market prices. With average house prices in Peasmarsh exceeding £400,000, the proposed “affordable” housing is unlikely to be genuinely accessible to younger residents.

The plan also promotes public transport, yet fails to acknowledge how limited, unreliable, and costly local services are in practice.

In addition, reference is made to neighbourhood planning, but the Peasmarsh Neighbourhood Development Plan appears to have been largely overlooked.

Overall, while the objectives are well intentioned, there is a clear gap between what is promised and what is realistically deliverable. The frequent use of the term “sustainable” is not supported by the proposals that follow.


2
The housing targets do not appear to take account of the number of properties that are currently unused, including second homes, holiday lets, and investment properties.

There is little indication of how such housing stock might be brought back into use through policy or incentives. As a result, the emphasis seems to be on increasing supply through new development rather than making better use of existing homes.

5
(a) Transport and Movement

Public transport provision is extremely limited. Bus services are infrequent, often delayed, and poorly coordinated with onward connections. This makes travel by public transport impractical in many cases.

For example, journeys to key destinations such as The Conquest Hospital in Hastings can take several hours by bus, and costs are relatively high compared to local incomes.

Road conditions are also poor, with potholes and seasonal flooding creating hazards for drivers and cyclists. Pedestrian infrastructure is inconsistent, with uneven pavements and a lack of safe crossing points.

In practice, the current transport network encourages reliance on private cars, which runs counter to the plan’s sustainability objectives.

(b) Community and Cultural Facilities

Peasmarsh benefits from several valued community assets, including the Memorial Hall and recreation facilities. However, these are largely maintained through local initiative rather than district-level support.

This highlights the importance of local knowledge and community-led provision, which does not appear to be fully reflected in the plan.

(c) Education

Local secondary education options are limited. Rye College has faced challenges in recent years and lacks a sixth form, which affects its attractiveness to families.

While alternative schools exist, accessing them can be difficult due to transport constraints.

(d) Health and Social Care

There is no GP surgery within the village, and nearby practices have limited capacity. Access to healthcare therefore depends heavily on travel, which is both costly and time-consuming without a car.

(e) Flooding

Flooding is a significant issue in Peasmarsh, despite suggestions in the plan that it is not.

Surface water flooding and a high water table are well-known local concerns. The assessment appears to rely on incomplete or inappropriate data, potentially overlooking these risks.

(f) Utilities and Energy

There have been repeated failures in water and electricity supply in recent years, sometimes lasting for extended periods.

Wastewater and sewage infrastructure are also problematic, with frequent discharges into the River Rother.

Power outages have wider consequences, affecting communications, heating, and access to essential services. These issues raise serious questions about the resilience of existing infrastructure.

(g) Emergency and Security Services

Infrastructure failures can directly impact the ability to contact emergency services.

Flooding incidents already require intervention from the fire service, and rural crime remains a concern. Overall, emergency resilience is closely tied to the weaknesses identified in other infrastructure systems.

Summary

Across all areas, infrastructure appears under strain. Without significant investment and a coordinated strategy, additional development is likely to increase pressure on already limited resources.


6
The policy relating to strategic gaps appears internally inconsistent.

On the one hand, it emphasises the importance of maintaining separation between settlements. On the other, it allows for development within these gaps where sites are deemed suitable.

This creates uncertainty and suggests that boundaries could be adjusted to accommodate development, undermining the original purpose of the policy.


8
The scale of proposed development in Peasmarsh (143 houses) represents a substantial increase relative to the existing housing stock.

Describing this level of growth as “small scale” does not align with the reality of a roughly 25% expansion. This appears inconsistent with the aim of delivering sensitive development in rural areas.

13
The classification of Peasmarsh as a sustainable location is questionable.

Many key services (Shop, Post Office, Pharmacy, Petrol Station and ATM) are effectively provided by a single business (Jempson’s), which introduces considerable vulnerability. Should this provision change, bearing in mind bricks and mortar retail exists in an increasingly hostile environment, the village’s service base would be immediately wiped out.

This reliance does not represent a robust or resilient foundation for long-term planning.


15
The plan states that development should support local needs and maintain rural character.

However, the scale and nature of the proposed developments, particularly on greenfield land, would alter the character of the village.

There is also a risk that affordable housing commitments may not be delivered in practice, as viability considerations often lead to such elements being reduced or removed.


47
PE1 (Kitewood)

Development of this site would result in the loss of greenfield land and contribute to the gradual erosion of the rural setting of the village.

There are likely to be impacts on local road networks, including increased traffic movements and potential safety concerns at access points. Drainage and flood risk also require careful consideration, given existing local conditions.

PE2 (Pippins)

This site raises particular concerns regarding the delivery of affordable housing. Previous applications have suggested that such provision may not be viable, which calls into question whether policy objectives can be met in practice.

As with other sites, development would introduce additional traffic and infrastructure demands, while also affecting the character of the surrounding area.

PE3 (Tanyard Field)

This site is especially sensitive due to its elevated and visually prominent position. Development here would have a significant impact on the wider landscape and views into and out of the village.

There is also a history of planning resistance on this site, reflecting longstanding local concerns. Flood risk and drainage issues further complicate its suitability.

In addition, there is concern that development here would lead to further expansion beyond the currently proposed boundaries. The initial proposal of 15 affordable homes is a Trojan Horse to blight a greenfield site, make it a brownfield site and then build a second wave of development which (if consistent with previous proposals and planning applications) could be as much as 60 to 70 more houses.

PE4 (Orchard Way)

Similar to other allocations, development on this site would involve greenfield land and raise questions about environmental impact and infrastructure capacity.

Access arrangements, traffic generation, and drainage all require further scrutiny, particularly in light of existing constraints.

PE5 (Malthouse Business Park)

Although this site may differ in character from the others, development would still contribute to cumulative impacts across the village.

Consideration should be given to how it integrates with existing settlement patterns, as well as its implications for local services and infrastructure.

Overall Site Assessment.

When considered individually, each site presents a range of challenges. Taken together, their cumulative impact is likely to be significant.

This includes increased traffic, pressure on infrastructure, loss of rural character, and potential environmental effects.

There is also limited assurance that new housing will meet local needs, rather than contributing to second home ownership or external demand.

A more comprehensive assessment of cumulative impacts and deliverability would strengthen the plan.


67
The removal of Policy SDO9 could enable rapid expansion in smaller settlements.

In the case of Peasmarsh, this could result in a significant increase in housing without corresponding improvements in infrastructure.

68
The Sustainability Appraisal appears to underestimate key issues, particularly flooding.

This raises concerns about the accuracy of the evidence base and whether local conditions have been properly understood (fluvial vs pluvial flooding).


69
The consultation process does not appear to have been fully inclusive.

The reliance on online materials may have excluded some residents, particularly those less comfortable with digital platforms. Limited outreach and a relatively short consultation period may also have reduced participation.

There is a risk that not all sections of the community have been adequately represented as a result.

While the plan sets out clear ambitions, there are significant concerns about how these will be achieved in practice.

In particular, there appears to be a disconnect between proposed development and the capacity of local infrastructure, as well as uncertainty over whether housing delivery will meet local needs.

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

Good morning,
On behalf of our client, Rurban Estates Limited, please find enclosed a representation on the Regulation 18 Draft Local Plan, which has principally been submitted to support the strategic growth identified for Battle and the proposed allocation of ‘Land adjoining Little Brans’ (Draft Policy BT10). Comments on the draft policies more generally are also enclosed, together with supporting appendices.
I would be grateful for confirmation of receipt. Thank you.
Kind regards,
Hannah

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent to the Pevensey Levels SSSI (Site of Special Scientific Interest),
SAC (Special Area of Conservation) and the Ramsar designated wetlands. It is
essential that the ecological integrity of this area is preserved. Any drainage water
flowing onto it requires a Sustainable Drainage System, to exclude any water-borne
pollutants, as well as the creation of an attenuation pond. These requirements are
proving very difficult to fulfil for the smaller development BX20. Building any more
houses, particularly a high-density estate with its polluting run-off, would severely
compromise the ecological integrity of this special area.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed that the narrow 9” sewer pipe under
Barnhorn Road cannot cope with the current quantity of sewage from the buildings
on both sides of the road in storm conditions. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

Good afternoon,
On behalf of our clients, Catesby Strategic Land Limited and Rurban Estates Limited, please find enclosed a representation on the Regulation 18 Draft Local Plan, which has principally been submitted to support the strategic growth identified for the Hastings Fringes and the proposed allocation of ‘Land east of Beaney’s Lane, Hastings’ (Draft Policy WS2). Comments on the draft policies more generally are also enclosed, together with the supporting appendices.
The document has been compressed for sending, so I have also attached the Constraints and Opportunities Plan from Appendix 3 for clearer reading.
I would be grateful for confirmation of receipt. Thank you.

See attached.

See attached.

Q2 OBJECT on the Development Needs. I don't see the need to build on any more houses on green fields in the area near Bexhill. We don't need them and its spoiling the reason the people like the place.

Q17 OBJECT BX17 It's a car park well worth keeping where people park and shop or go to their clubs in the town for the evening.

Q17 OBJECT BX16 This is a lovely area with tall mature trees and wildlife. It should be looked after for future generations to enjoy.

Q17 OBJECT BX19 I want to continue using the car park at The Gorses as its easy to walk from there to the beach or catch the train. Its no point building houses on a station car park and then wondering why people don't use the train. I hope the green space and woodland is safe from development on The Gorses as its a wildlife haven.

See attached representations from Homes England regarding sites RB6a and RB6b and questions 2, 5, 7, 8, 14, 57 and 68.

See attached response from Hastings Borough Council in response to questions 1, 2, 3, 4, 5, 6, 10, 11, 28, 29, 33 and 69.

See attached representation for full response to questions 2, 7, 8, 9, 10, 17, 18 which includes sites:
• Land east of Watermill Lane (BEX 34);
• Part of Land north of A2691 NBAR (east), Bexhill (BEX 36);
• Land north of Rosewood Park, Gotham Farm, Bexhill (BEX 23);
• Land south of Whydown Road (BEX 24); and
• Bexhill, Land at Gotham Farm (west), Sandhurst Lane, Bexhill (HELAA ref BEX0206)

See attached representations in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 56, 59, 61, 64, 65, 68 and 69.

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Comments:
1. The amended Rother Local Plan Strategic Spatial Objectives shown in Figure1
• There is a significant difference between the National Strategic Objectives as set out in Levelling Up & Regeneration Act (LURA) and the Local Strategic Objectives for Bexhill on Sea.
• I agree with ‘working towards’ a net zero carbon emissions but not by having a single power source or doing so in isolation from other countries. We produce less that 1% of carbon emissions and penalising our industries/commerce in competition with other countries. Ideology needs to incorporate Reality.
• The Strategic Objectives for Bexhill on Sea should reflect the requirements for its resident population. It should take account of the actual additional housing needs, not a ‘one size fits all’ need as calculated and identified Nationally.
• It should reflect that of the local residents of Bexhill on Sea, of which some 50% are >65years; compared to the National Ave of 19%.
• This has significant demand on the needs for employment and population growth/housing. Unless of course the Governments strategic objective is to increase the population of Bexhill on Sea, by provision of homes for an influx of non-local Residents, which would change it from being a predominantly retirement location town to which people choose to relocate to for a better quality of life.

2. Infrastructure
• If it is the intended objective to change Bexhill on Sea from what it’s always been and significantly increase the Housing requirements in line with National Strategic Objectives, which is effectively a Levelling Down, then:
• It is essential that planning approval for additional housing to meet the Governments Housing targets should only be provided once all necessary increases in infrastructure are in place, to cope with the increased demand.
• It is essential that Planning approval must take into account and include all sectors that provide the necessary infrastructure to meet the planned housing demand.
o Water services currently are not included in the planning application process, they are only requested to say they have a ‘strategy’ to supply. This may be long after planning applications have been approved and houses built. We’ve already recently seen problems with water supply, treatment of wastewater and flooding. Indeed, I believe their current strategy was developed pre the Governments recent Housing targets.
o Health Services are not included, GP services; A&E; Community services and Inpatient facilities are already under significant strain and not able to provide services for the existing local resident. This does not include all the housing developments already built and those approved and being developed!
I’ve only mentioned two services, but the situation is the same for all others. The provision of appropriate infrastructure is essential and is an integral element of the provision of housing and relevant to meet both Rother’s housing target and the National LURA Target which is not relevant to Local Resident Housing Needs, it is not a one size fits all target.
From discussions with neighbouring Local Councils, all have similar issues regarding availability of land and meeting the National LURA Housing targets and the ability to ensure the provision of necessary infrastructure. I would seem appropriate for Rother District Council, if they have not already done so, to develop links with other Local District Councils to explore a joint approach to the Government in respect of ‘Local Residents’ Housing Targets.
3. Turning to Development of Needs - Housing:
• Although the previously the number of houses built has not met the housing target that was set, it should be recognised that the number of sites allocated by Planners in the site plan for Developers to build on, was greater than the target required to be met. Indeed, sites that were not included in the consulted and approved Plan, I believe classified ‘windfall sites’ (though significantly greater in numbers to the 39 mentioned in the document), were discussed with Developers, put forward for planning approval and rejected but approved following an Appeal.
• Having been involved with the planning approval process as a resident and recognising the demands placed on the Council Officers to deliver housing on a top-down National level calculation, the involvement of the local residents is basically tokenism. The housing target is given is out of their control and the availability of land is finite, Developers will only choose sites that are financially viable, what influence do the residents have. None………. only once approved, to try and influence the developer on the impact of the site to the local residents.
• Rother District is fortunate to be surrounded by Areas of Natural Beauty, but this is a two-edged sword as all the green areas where you can walk are gradually disappearing and Bexhill is losing its appeal and becoming a New Town surrounded by housing estates. It’s not really planning it’s filling in all the green spaces.

4. Objections to Specific Site Allocations

• BX 14 - Although already approved 210 dwellings (420 cars) this site has serious traffic implications car and pedestrian as access and egress is via Ellerslie Lane which is a narrow lane with no footpath.
• BX 15 – 35 dwellings (70 cars) identified site allocation additional accessed via BX 14, increasing traffic concerns for cars and pedestrians on Ellerslie Lane.
• BX 22 – Additional 400 dwellings (800 cars) Access onto Barnhorn Road at peak times is extremely congested, recently made worse following Rosewood Park major housing development on opposite side of Barnhorn Road.
• BX 27 – Additional 540 dwellings (1,080 cars) on Pevensey Levels (Marshes?) accessing onto an already congested Barnhorn Road .
• BX 39 – Additional 500 dwellings (1,000 cars)
Note the number of additional cars from these five sites alone. So much for reducing the eco footprint for Bexhill on Sea.

See attached representations and supporting documents from Burwash: Save Our Fields in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 53, 54, 61, 64, 65, 66, 67, 68 and 69.

Please see attached representations on questions: 2, 6, 7, 9, 13 & 49.

Please see attached consultation response to Regulation 18 Rother Local Plan Review Draft Allocation SD11 - Land North of Brede Lane, Sedlescombe”

Attached documents forming representation:
- Catesby Estates Respresentations to RDC Regulation 18 Consultation
- Landscape Appraisal
- Landscape Vision Document

Fairlight Parish Council - Response to Local Plan Consultation.

Q1) The overall objectives are acceptable. However, in Section 5, the proposed amount of development in the Bexhill area is excessive. It raises the question of why the Bexhill–Hastings link road is not being progressed as initially planned and discussed. Developments on the Hastings Fringe must be carefully evaluated to ensure genuine sustainability, without placing undue strain on existing road networks due to reliance on private vehicles. In Section 8, the proposed sustainable transport hierarchy is unlikely to be effective in rural areas. Achieving a truly sustainable transport model in these locations would require extensive and significant infrastructure upgrades.

Q2) The target appears reasonable when taking into account the demographic changes in Rother. However, many of the proposed sites are scattered, selective, and appear to have been chosen primarily based on availability. A significant number of these locations are not sustainable, making reliance on private motor vehicles almost inevitable.

Q3) The target seems reasonable given the demographic changes in Rother. However, many of the proposed sites are scattered and appear to have been selected mainly for their availability. Numerous locations are unsustainable, making reliance on private vehicles almost unavoidable.

Q4) Although the need is relatively small, these sites should be located closer to major link roads. It is noted that Battle currently has a cluster of sites; would it not be more appropriate to locate them along the A21, A259, or A27?

Q5) Infrastructure upgrades must correspond to the locations of major new allocations. Bexhill, Battle, and Rye, along with their proposed developments, will all require significant infrastructure improvements.

Q6) The proposed strategic gap infill between Fairlight and Hastings, and to some extent Crowhurst towards Hastings, would conflict with existing spatial policies. Unsustainable rural infill is also problematic due to insufficient infrastructure, leading to increased reliance on private vehicles to access essential amenities.

Regarding development between Hastings and Fairlight, a comprehensive assessment of flooding risks in Marsham Valley is essential. While most of the area falls within Flood Zone 1, the terrain slopes for approximately one and a half miles into areas already designated as Flood Zone 3. Any additional development within Marsham Valley would increase the risk of flooding downstream at Pett Level and beyond. Furthermore, the C92 road is already constrained by its width and steepness, and additional traffic would exacerbate existing issues, creating further detriment.

Q7) To preserve the character and appeal of Rother’s villages and rural areas, a lower allocation for villages with development boundaries would likely be more appropriate for the communities affected.

Q8) With 83% of the district falling within the High Weald National Landscape (HWNL), some development in the area is inevitable. However, it is the scale of certain proposed sites that poses a risk of harm. While it is straightforward to meet housing targets by focusing on site availability, many of the larger sites in rural, unsustainable locations are unnecessary. Greater emphasis should be placed on development in areas where sustainability objectives can be achieved and infrastructure upgrades are more cost-effective.

Q9) With such a significant increase in both housing and employment floor space in the Bexhill area, the road network will need to be addressed to accommodate this growth. There is no doubt that the link road connection to the A21 will experience a substantial increase in traffic. Rother, ESCC, and National Highways will need to address this issue. The new connecting layout has been poorly designed to manage this level of growth. The original concept for the link road included the possibility of a trunk connection to join the A21 north of Battle, which now appears to be a necessity.

Q10) The growth is substantial and requires the necessary infrastructure to be delivered without fail. Although some development in the northern area takes advantage of the link road, this could be expanded to reduce the pressure of infill in other parts of the town. There are, without doubt, significant challenges to address regarding roads and traffic around Little Common..

QA|11) The width and condition of Rock Lane and Austin Way is concerning. At present, these roads cannot accommodate the planned developments. Any building sites where surface water drains into Marsham Valley should be carefully assessed due to existing flooding issues and the harmful effects on SSSI and Ramsar sites

Q13) A disproportionate number of housing allocation for Peasmarsh considering its sewage capacity.

Q15) The objectives are reasonable. However, as has been seen in the past, farming and arable land outside development boundaries, when ‘offered up’ by landowners, has later been incorporated within development boundaries. Provided that such actions are not repeated, as they have been previously, the strategy should be effective.

Q 16) As per question 4

Site allocation response.

Fairlight Cove Policy reference: FA1

This site should be removed from the Local Plan/DASA once and for all for the following reasons.
This site has had numerous planning applications submitted for development dating back to the 1970s. All have been refused by Rother, and many have failed on appeal. The reasons for refusal have consistently related to spatial and sustainability strategies, and, most importantly, water issues, both surface and sewage, which cannot be adequately addressed.
The site is subject to groundwater flooding. Fairlight Cove suffers from unique subsurface problems caused by two main earth fault lines: the Haddocks Fault and the Fairlight Cove Reverse Fault. The Fairlight Reverse Fault crosses this site and is responsible for the majority of groundwater issues. Water from the elevated land at Fairlight Village and Hastings Country Park flows downhill to the lowest-lying land and is forced to the surface by this underground fault. Any development of any size, even with attenuation SUDS, could potentially result in land collapse. No land stability study has ever been conducted for this site, and this risk has been overlooked for years, despite the known dangers of development.
In addition to the natural fault, there are other water-related issues. The southern boundary is in Flood Zone 3 and contains a watercourse that flows through the lower part of Fairlight Cove into the Marsham Brook system. This area has flooded numerous times, and the addition of 35 dwellings would exacerbate this flooding. Furthermore, there is a Combined Sewer Overflow (CSO) on the site that currently discharges raw sewage into the watercourse around 20 times per year, contaminating watercourses all the way to SSSI and Ramsar sites. Connecting 35 dwellings would further strain the local treatment plant, which is already handling a population of approximately 700–800, well below its design capacity of 1,500. The CSO on the site is served by a 450mm sewer, while the outgoing sewer for site connection is only 175mm. Existing back pressure causes the CSO discharges, and additional housing would increase this pressure, resulting in further untreated effluent and stormwater being released. The additional flood risk and watercourse contamination are unacceptable.
The most recent planning refusal appeal was not upheld, primarily because the site had not been sequentially tested. This requirement still applies and must be met for any planning application. With 14 potential sites identified within a two-mile radius in the latest HELAA, and given the known surface water and sewage issues, this site would not qualify for an exception and would fail a sequential test.
Considering the water hierarchy, this site fails on the first three criteria: sequential testing, surface water flooding, and local sewer infrastructure. It would also likely fail on treatment plant capacity, despite Southern Water’s current statements. Recently obtained release records via a Freedom of Information request confirm that the treatment plant is operating beyond its designed capacity.
Beyond the inherent and unresolvable water issues, the site also fails on sustainability, spatial, and transport grounds. Fairlight Cove is not a service village and lacks essential amenities. The only pedestrian access to the site is via a discontinuous, unlit, and narrow footpath less than 2 metres wide. Sustainable transport cannot be achieved; private vehicles would be the only practical means to reach amenities, most of which are in Hastings. The nearest NHS provision is in Sedlescombe or Westfield. Due to its location, the site would be highly visible as a satellite development within the High Weald Landscape. The access road crosses a highway drainage SUDS network in a known flood zone and is positioned in a dangerous location with limited visibility.
This site is not viable, as evidenced by the repeated refusals of planning applications and the extensive water-related challenges. Simply being offered in a call for sites and meeting housing requirement figures does not make it a suitable or safe site for development.

See attachments

See attachments

Please see attached:

- Catesby Strategic Land and Rurban Estates - BX36 - Representation
- Appendices Part 1
- Appendices Part 2

Please see attached documents for representations relating to BX39 Land west of Ninfield Road, Bexhill:

- Representation Document
- Appendices Part 1
- Appendices Part 2

See attachment