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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

NHS Sussex-PC support the objective of strengthening the local economy and creating jobs. However, increased employment, particularly in logistics, industrial, and town centre uses, will increase daytime and resident populations, placing additional pressure on already constrained GP services.

The Local Plan does not adequately recognise the impact of employment growth on primary healthcare capacity. Economic growth must be supported by appropriate healthcare infrastructure to ensure a healthy and productive workforce.

The Plan should explicitly recognise primary healthcare as essential infrastructure and require developer contributions where employment development generates additional healthcare demand. Healthcare facilities should also be considered within mixed-use and town centre developments to improve accessibility.

Without appropriate healthcare infrastructure planning alongside economic growth, there is a risk of unsustainable pressure on primary care services and reduced access for both existing and future populations.

Please see individual responses and attachment for comments on the proposed sites in Battle Civil Parish.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Retail and commercial behaviour is changing. Most purchases and retail are completed online. It is a mistake to be blind to this and not face up to changing public perceptions and behaviour ie. don't flog the idea that town centres must grow - it is doomed to fail. If housing is needed so badly then town centres should be converted to supply this need. See town centres on the continent such as Sweden, who already have a mix of housing and retail and it works very well. There are several empty buildings that could be converted to housing or out of town retail such as the camping store and land at John's Cross and the old Post Office building in Hastings. If people are so keen on the town centre then why do they shop online? Now there's a question.

It will be essential to ensure adequate parking provision is made available

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

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

This is a very weak section. Needs a lot more information needs and wealth creation: how, where, who, costs, income to the council, transport etc

The Draft Local Plan assumes that sufficient employment opportunities exist to support the scale of housing proposed. However, this assumption does not appear to reflect the reality of the district’s employment geography.
A significant proportion of the proposed housing allocations are located on remote greenfield sites such at BT7 at Almonry Farm which has very limited local employment opportunities. These locations do not have the economic base to support a large increase in residents seeking work locally.
As a result, many new residents would likely need to commute outside the district for employment, increasing traffic congestion, pressure on transport infrastructure, and carbon emissions. This approach conflicts with the principle of sustainable development.
Without clear evidence of substantial new employment creation within or near these settlements, the claim that sufficient work exists for the proposed level of housing growth appears unrealistic and inadequately justified.

The fact that 3 sites received planning for business opportunities have dropped out speaks volumes in the current high taxation climate. Creating employment opportunities in towns is realistic, in rural communities not so good. Sustainability is the key through this whole project. Villages do not have a sustainable transportation system, fact! Max opportunity for nature conservation, preserve character of High Weald landscape & protect habitat, no one would object to that. The truth is because of the dicatate from central government the council intends to building large housing estates over green field sites totally ruining the landscape and having a drastic impact on all forms of wildlife habitat.

Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation

Rother District Council Regulation 18 Local Plan 2025-2042 Consultation
Thank you for inviting Ashford Borough Council to comment on Rother District Council’s (RDC’s) Regulation 18 Local Plan Consultation.

Housing Need
The latest version of Rother’s Local Plan states that the district’s housing need figure calculates to 15,504 new homes over the 17-year plan period, using the standard method calculation. The Council note that this figure has risen since the previous Regulation 18 consultation in 2024. The Regulation 18 draft of the Local Plan clarifies that RDC only proposes to deliver 8,427 new dwellings over the plan period, which is approximately 54% of the district’s overall housing need requirement.

Given that there is a shortfall and that it is significant, Ashford Borough Council considers that there needs to be a more detailed justification for why the draft Local Plan fails to meet the housing requirement in full. Although the Council acknowledge the challenges RDC face because of the extent of the district covered by National Landscape, in the Council’s opinion it is not enough to rely on this constraint alone to justify the extent to which there is an unmet need.

The Council considers that the justification for the shortfall should be addressed in greater depth. For example, it is currently unknown whether there is any local evidence to suggest that an alternative method should be used to establish the housing need figure and whether this might result in a reduced requirement. A more detailed explanation is needed to demonstrate that RDC have explored all options to seek to rectify the shortfall. Only then can the Council fully understand the real extent of the shortfall and the potential impact on Ashford borough as a neighbouring authority.

As RDC will be aware the Council also recently consulted on a Regulation 18 draft of a new Local Plan for Ashford covering the period up to 2042. The Regulation 18 version of the emerging Local Plan highlights the Council’s own challenging need (17,622 dwellings for the plan period 2024 and 2042).

Based on our emerging work and taking into account our own strategic environmental constraints (including the restrictions imposed on new residential development within the river Stour catchment due to the condition of the designated Stodmarsh lakes), it is clear that accommodating our own identified need will be extremely challenging.

Proposed Site Allocations
The Council notes the Regulation 18 Local Plan includes a number of proposed site allocations across five sub areas. Due to the location, size, and scale of the proposed sites closest to our joint boundary, the Council does not have any comments to make on any individual sites currently proposed within this latest version of the Plan.

Gypsy and Traveller and Travelling Showpeople (GT&TS) Accommodation Needs
The Council support the efforts being made by RDC to seek to accommodate its GT&TS accommodation needs in full within their own administrative area.

Employment Needs
The Council support the efforts being made by RDC to seek to accommodate its employment needs in full within their own administrative area.

Maintaining Cooperation
Irrespective of the issues raised in this letter Ashford Borough Council would like to take the opportunity to express that it remains committed to working collaboratively with Rother District Council to discuss any strategic cross-boundary issues and look forward to continuing to engage to discuss respective emerging Local Plans.

The Council notes RDC’s formal request for assistance to meet its unmet housing need set out in its letter dated 4 March 2026. The Council are considering this request a will respond by separate letter.

To encourage new residents' enjoyment and attachment to our town, we should further develop the town centre and promenade to support small and medium sized, independent retail and leisure providers. A commitment to maintaining and enhancing the town centre conservation area and the many historic buildings in retail, leisure and other employment uses should be included in the Retail and main town centre section.

You have an econoic estimate of 3800 new jobs, but you are putting in 8427 dwellings. In other words, where are the jobs to support these households?

I object because rent and business rates are far out stripping people wanting to set up businesses. Aswell as the tax implications Labour have bestowed upon us. I very rarely go to battle with the banks all shut down, but when I do it seems like a ghost town. It is only the Abbey drawing tourists in.

-

Whilst agreeing with the analysis of local employment needs again the objectives include thinga way beyond the reach of a local government council and so I have to ask whether the vision is sustainable and achievable

We support the economic objectives of the plan but cannot see any substantive reference to the need to promote sustainable tourism within the district. Rother is well sited in the south-east corner of the country, on some of the most beautiful coastline, and in an area dominated by the national landscape and other ecology and historic attributes. There is a strong demand, as demonstrated by the successful project at Powdermills Hotel in Battle, for high quality hotel accommodation. This provides a not insignificant level of income and employment for the district, puts the district on the map, and on this basis there should be a clear and unequivocal policy support for such uses within the emerging Local Plan.

As a target it seems about right, providing any retail sites have the right mixture of unit size to attract a variety of smaller independent outlets. Rother should not become an area full of large commercial retail outlets.

Seems reasonable

PART 1 CHAPTER 2 My concerns about the local strategy
with regards to Peasmarsh developments is that it meets the requirements of social having, however other local villages have not been developed as much as Peasmarsh and as a result, Peasmarsh has been identified for development and expansion with no consideration for other areas.

PART 2 CHAPTER 3 No 2
The proposed development plan is mixed as it does not reflect a balanced view of the Rother District in its entire scape. In addition, with regards to Peasmarsh, the infrastructure: the area does not meet present needs and flooding, pot holes, outages and problems with flooding only exacerbated with more dwellings.

PART 2 Chapter 3 No 3
Employment is important but is met in Rye itself, local hotels and restaurants and Jempsons itself. Building more homes, will then expand more shops and retailing in the future that then takes away the character of the village, to just find land to build, which is not a responsible use of planning or resources.

PART 2 CHAPTER 4
It is good to see that Rother are making plans for the future, however with regards to-the social and critical infrastructure ie bus stops, with the homes and temporary accommodation proposed in the village and is PE5, will be offset with increased impact an policing, social care, doctors, and maintenance and upkeep due to excessive use of roads ie more potholes as well as the demographics of the village and available school spaces and resources.

PART 3 CHAPTER 5 No 7
My concern with the local plan, is it is not feasable both in respecting nature, environment and also the very essence of the village. The clientel or the size of PE5 goes against regulation of planning in addition and key to all given the Unitary authority proposals, it seems rushed through with no active consultation understanding especially PE5. It cannot protect and enhance of deciduous woodland due to felling and effect on environment.

PART 3 CHAPTER 6 NO.13
Concerns above, but in addition the impact on natural and economic and housing strategy for the area. as well as present area not meeting the needs of flooding, excessive housing, basic infrastructure already strugging to cope. Adapting an approach already imposed will also put strain on further Services ie education, policing etc already not being met.

PART 3 CHAPTER 7 No.52
I do not believe that other areas have been considered in neighbouring villages and that Peasmarsh becomes an expensive area and loses its character in addition proposals for the village particularly PE5, does not take into account present under usage of the business units and do not allow for parking, further exhausted resources both natural, employment etc. By having similar focus as in other villages and areas mean that employment and resources are evenly spread OUT and also with the move to a super-council, would it not better for further ideas and consultation after re-organisation of local government has been need and local elections taken place ie after May 2026 elections as this is also move ethical and political
minded in the sense takes in the needs and wants of constituents council planning. I appose the plans.
PART 3 CHAPTER 7 No. 47
I am concerned with Rothers considerations and plans for Peasmarsh would-it not be further local Parish council then the issues raised an your site is not democratic but autocratic. Unless people are made aware publically and meetings arranged how can open and meaningful conversations take place. The area of the Maltings is beautiful but does not take into account two car families. As a result the new development of social and part owned part rent previously constructed have lack of parking and regularly block the highway. The proposed extension the Business path and to allocation of flats as the hectorage means that here are no guarantees that present problems, lack of parking, lack of resources ie maintenance of present social having by Sothern Housing and other Housing Associations as well as consider areas over criminal activities, draining critical resources like education and need for more teacher, buildings etc. as well as poor sewerage, increased lighting etc. my wary is that Peamarsh will become an area that destroys the community and the very beauty and heart of the village, something that has not ben taken into consideration.

I would propose a feasibility study drawn up with the Parish council and locals and to offer other suggestions such as neighbouring areas such as Beckley and other neighbouring villages, where resources and facilities are not in one area and meet the needs of all.

PART 1 CHAPTER 2 The local strategy does not reflect
the needs of local employment needs nor does it meet the needs of local residents due to lack of paring, road infrastructure and basic needs such as sewage etc. Expansion of services and business unite and flats will in the aesthetics of the village as well as an increase and effect as the already research business in the local area.

PART 2 CHAPTER 3 No.3
The problems I have is meeting the needs of my own business such as affordable premises but move importantly parking and access. The proposal for PE5, adds to that need with less parking. Poor road maintenance. Lack of parking leads to less customers in the demographics of the over, Most businesses are self employed so the need to have customers is important due to the very nature of business. In addition less customers will mean employer leave the village, meaning an any benefits. Equally the expansional the premises presently not only reduces aesthetics natural light and neighbourhoods which are the draw of the village If you as
a local government had same concerns would you build n your local area?

PART 2 CHAPTER 4 My concern is with regional resources. Due to its demographics and location as increase in village population to 147 names plus flats per hectarage which is ambiguous, means a drain of social and healthcare, education, refuse, policing and fire with an increase in social housing less employable adults available meaning less council tax and funding for infrastructure.

PART 3 CHAPTER 5 No 7 I do not believe in reading your
rational that the proposed business unit expansion helps the load, nature and environment leading problems.

CHAPTER 6 No 13 PART 3 CHAPTER 7 No.52
In adding the ambiguous language of 'Hectarage' with the super council proposals for East Sussex leaves it operated the expansion and possible loss of woodland protected areas and name another advanced in general. The checks
in those properties will they require have parking and how will this be net? Leading to less paring blight are the landscape and problems with road maintenance as well as blocking emergency vehicle access. The present problems with upkeep of the social housing and lack of parking has already led to problems in the area. PE5 is not right for the area.

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

See attached representations in response to questions 3, 4, 7, 8, 10

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

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 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.

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.

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.