There is no mention of Coastguard service

I object to the proposed Development Strategy on the grounds that infrastructure delivery is uncertain, unproven and not adequately secured. Existing infrastructure across Rother—particularly water and wastewater capacity, drainage, transport, healthcare and education—is already under significant strain.

While the Council acknowledges these concerns, the Infrastructure Delivery Plan remains a “living” and incomplete document, with key schemes, costs, funding sources and phasing still unconfirmed. Relying on future updates does not provide the certainty required to demonstrate that infrastructure will be delivered in advance of, or alongside, significant housing growth.

Without firm commitments from infrastructure providers or guaranteed funding mechanisms, the Plan risks permitting development ahead of essential infrastructure, worsening existing deficits and undermining the Local Plan’s own objectives of “Live Well Locally” and “Green to the Core”. This calls into question whether the Plan is effective, justified or deliverable

1. The Strategic Spatial Objectives are sound – BUT they should not just be stated as pious intentions - they need to be honestly adhered to in the formulating of the plan.
In particular, Point 11 states “Deliver sustainable development ………… having regard to local context and character”. There are clear instances in the approach towards Peasmarsh for example, where this principle is clearly breached.

The Objectives do not include any mention of the Area of Outstanding Natural Beauty – now called the High Weald National Landscape. Cynics might assume that the change of name is entirely because the depredation of a “landscape” sounds so much more inoffensive than destroying “Natural Beauty”. Just changing the name doesn’t make it any less beautiful or worthy of preservation. If it is destroyed once, it is destroyed forever. The Objective of preserving this should be added. This would clearly set out the context in which Chapter 6.2 can be read.

5. Regarding Infrastructure needs, my initial comments relate solely to Utility and Energy – with specific reference to the Peasmarsh area - which are the fundamental pre-requisites for any acceptable development.
The Peasmarsh Neighbourhood Development Plan (PNDP) – accepted by Rother DC in April 2024 after an Inspection and local Referendum – highlighted in great detail the deficiencies of these services in Peasmarsh.
The sewer system is grossly inadequate – the combined drain arrangement, combining storm water with sewage, taken together with the wet conditions, ensures not only flooding but the eruption into the road of raw sewage in particularly wet times. This is confirmed by many photos in the Appendices to the PNDP. Southern Water have admitted that the Sewage Pumping Station is at the limit of its’ capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary.

Old house by the main road have wells that never run dry and complicated drain arrangements that have been installed over the years in efforts to reduce flooding. Any post holes fil immediately with water. This high water-table problem has been known for many years but no remedies have ever been proposed or undertaken.
Both Power and Water Supply are clearly inadequate for the existing housing stock, without regard for any increases. In recent times alone, there have been many instances of power or water failure – some of these problems lasting for several days. It is foolish and irresponsible to consider any further development of the village without addressing these issues first.

In addition to these physical issues, it must be pointed out that the current Village School is oversubscribed and has no facilities to manage the large number of additional children the foreseen developments would generate.

6. The Development Option SDO13 – A21 Corridor Growth seems sensible and should indeed be pursued.
SDO14 – filling strategic gaps - should proceed as well though and the reasons given for abandoning it do not chime with the achievement of the development targets the plan defines.

Many of these reasons are well-meant, but the effect is to force unreasonable development targets onto areas which are technically totally unsuitable.

13. The proposed vision and development strategy for the Eastern Settlements Cluster seems totally wrong. It has all the hallmarks of a paper exercise – conducted from a desk and totally ignoring real life and the situation on the ground.
Firstly, the allocation of new homes to Peasmarsh is totally out of proportion to the existing size of the village and its’ capacity to absorb additional development. The proposals would increase the size of the village population by 15-20%, completely changing its’ character. The population of the UK is projected to rise by 7% by 2040. Why should a village in the AONB/High Weald National Landscape bear an increase twice that of the country as a whole.
Secondly, the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village – despite the very clear geographical limitations of the Village. Expecting Peasmarsh to take 20% of the additional homes in this area is clearly unbalanced and seeks for some reason to turn Peasmarsh into a dormitory suburb of Rye. The much-touted “commercial centres” in Peasmarsh are all on one site, part of one enterprise, and routinely exposed to commercial realities.
The wishes of the village, in the democratic consultations only recently, clearly expressed the wish that developments should be small-scale or infill. These proposals are the opposite of this.
It is also worth pointing out, that Peasmarsh already has more social and low-cost housing than many other East Sussex villages. Any argument therefore that large scale development is needed is incorrect. Bringing in people who would prefer to live in an urban environment into a rural village with a very limited and expensive bus service and no access to local employment is something without benefit to any of the parties involved.
The last exercise that created social housing in The Maltings Peasmarsh ended up – contrary to early statements – with few local people being housed and the council placing people from Hastings and much further afield. There is no evidence that this would not happen again.

47. I have major objections to two of the site allocations in Peasmarsh – PE3 Tanyard Field and PE5 Malthouse Business Park.
First PE3 Tanyard Field.
You refer inaccurately and laughably to this as a “new” site. This is nonsense. The Landowner has been seeking Planning Permission for this site, as a matter of certain knowledge, for more than 40 years and has repeatedly been rebuffed and rejected on appeal on at least one occasion. I hope that you will still be able to refer in your own files to the letter and document issued by Rother DC on 22nd February 1990 under Reference RR/90/0021/P which is the earliest reference I can find to development being rejected. All the reasons for rejection remain valid today and indeed in some cases are more serious than they were then.
In addition, this site was carefully investigated during the preparation of the PNDP, both by the village working group and by independent consultants, and subsequently rejected. There can be no reason, other than the persistence of the Landowner, to ride roughshod over the PNDP – endorsed as it was by decisive village democratic referendum and accepted by Rother DC in April 2024.
The site is totally unsuitable for development on many grounds:

• The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its’ undulating park-like appearance is visible from many locations round the village. Development would have a catastrophic impact on the rural character of the area.
• The visual amenity of the entire village would also be thereby damaged.
• There would be a general loss of amenity, privacy and quiet enjoyment for the large number of village houses within sight and sound of Tanyard Field.
• Acceptance of the site would encourage other similarly unsuitable applications in the vicinity.
• The suggestion that the site would accommodate 15 dwellings is a very naïve understanding of the issue. If the site went ahead, then this would be the thin end of the wedge. The Landowner has put forward various outlines for the site in recent years – the largest involved nearly 100 houses and relentless pressure would ensue to rise to this total.
• Any development would impact unfavourably on nearby listed buildings.
• The field has a historic right of way across the western end. For nearly a thousand years, villagers have used it to walk up to the church and the vista from this path would be irretrievably damaged.
• The field slopes very steeply downwards towards the North, making it totally unsuitable for housing and helping to generate the drainage problem referred to below.
• The major technical issue is the drainage of the site, which is totally wet. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. The heavy clay soil makes the surface completely impermeable, so heavy rain simply runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street – see comments on Infrastructure in response to question 5. Your own letter of 1990 – reference above – states “the local Planning Authority in consultation with Southern Water is not satisfied that the site can be adequately drained”.
• Surface water run-off is a major problem throughout the village. The clue is in the name – Peasmarsh. Some years ago, the turf was stripped off Tanyard for unknown reasons and this greatly increased the problems – perhaps due to the clay soil being further compacted.
• The vehicular access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road, where the 30mph speed limit is regularly ignored to the despair of villagers.
• Any new housing would result in a substantial increase in car use and traffic generally, which is contrary to national environmental and transport policies.
• As stated repeatedly, the infrastructure around the site is completely inadequate for any further housing. The drains cannot cope. See copious photos in the Appendices to the PNDP.
• This ancient green field site, with ancient woodland to the South, and a copse at its’ centre, supports multiple species of birds, animals and plants. These include protected species such as Bats, Hedgehogs, Tawny Owls, Woodpeckers and many others.

Second PE5 Malthouse Business Park.

This small development of light industrial and commercial units is of great value to many in Peasmarsh. Its’ loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work and it seems counterproductive to positively take steps to deter employment.

67. Regarding Development Strategy Options and Preferred Approaches in Appendix 3, I do NOT agree with the elimination of option SD09 which is at least worthy of further investigation on a case-by-case basis. However, it has to be remembered that no desk-chosen arbitrary option is necessarily going to produce a figure for a community that is achievable on the ground given local constraints.

1. The Strategic Spatial Objectives are sound – BUT they should not just be stated as pious intentions - they need to be honestly adhered to in the formulating of the plan.
In particular, Point 11 states “Deliver sustainable development ………… having regard to local context and character”. There are clear instances in the approach towards Peasmarsh for example, where this principle is clearly breached.
The Objectives do not include any mention of the Area of Outstanding Natural Beauty – now called the High Weald National Landscape. Cynics might assume that the change of name is entirely because the depredation of a “landscape” sounds so much more inoffensive than destroying “Natural Beauty”. The Objective of preserving this should be added. This would clearly set out the context in which Chapter 6.2 can be read.

5. Regarding Infrastructure needs, my comments relate solely to Utility and Energy – with specific reference to the Peasmarsh area - which are the fundamental pre-requisites for any acceptable development.

The Peasmarsh Neighbourhood Development Plan (PNDP) – accepted by Rother DC in April 2024 after an Inspection and local Referendum – highlighted in great detail the deficiencies of these services in Peasmarsh.

The sewer system is grossly inadequate – the combined drain arrangement, combining storm water with sewage, taken together with the wet conditions, ensures not only flooding but the eruption into the road of raw sewage in particularly wet times. This is confirmed by many photos in the Appendices to the PNDP. The Pumping Station is at the limit of its’ capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary.
Both Power and Water Supply are clearly inadequate for the existing housing stock, without regard for any increases. In recent times alone, there have been many instances of power or water failure – some of these problems lasting for several days. It is foolish and irresponsible to consider any further development of the village without addressing these issues first.

6. The Development Option SDO13 – A21 Corridor Growth seems sensible and should indeed be pursued.

SDO14 – filling strategic gaps - should proceed as well though and the reasons given for abandoning it do not chime with the achievement of the development targets the plan defines.
Many of these reasons are well-meant, but the effect is to force unreasonable development targets onto areas which are technically totally unsuitable.

13. The proposed vision and development strategy for the Eastern Settlements Cluster seems totally wrong. It has all the hallmarks of a paper exercise – conducted from a desk and totally ignoring real life and the situation on the ground.

Firstly, the allocation of new homes to Peasmarsh is totally out of proportion to the existing size of the village and its’ capacity to absorb additional development.

Secondly, the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village – despite the very clear geographical limitations of the Village. Expecting Peasmarsh to take 20% of the additional homes in this area is clearly unbalanced and seeks for some reason to turn Peasmarsh into a dormitory suburb of Rye. The much-touted “commercial centres” in Peasmarsh are all on one site, part of one enterprise, and routinely exposed to commercial realities.

47. I have major objections to two of the site allocations in Peasmarsh – PE3 Tanyard Field and PE5 Malthouse Business Park.

First PE3 Tanyard Field.
You refer ludicrously to this as a “new” site. This is nonsense. The Landowner has been seeking Planning Permission for this site, as a matter of certain knowledge, for more than 40 years and has repeatedly been rebuffed and rejected on appeal on at least one occasion. I hope that you will still be able to refer in your own files to the letter and document issued by Rother DC on 22nd February 1990 under Reference RR/90/0021/P which is the earliest reference I can find to development being rejected. All the reasons for rejection remain valid today and indeed in some cases are more serious than they were then.

In addition, this site was carefully investigated during the preparation of the PNDP, both by the village working group and by independent consultants, and subsequently rejected. There can be no reason, other than the persistence of the Landowner, to ride roughshod over the PNDP – endorsed as it was by democratic referendum and accepted by Rother DC in April 2024.
The site is totally unsuitable for development on many grounds:

• The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its’ undulating park-like appearance is visible from many locations round the village. Development would have a catastrophic impact on the rural character of the area.
• The visual amenity of the entire village would also be thereby damaged.
• Acceptance of the site would encourage other similarly unsuitable applications in the vicinity.
• The suggestion that the site would accommodate 15 dwellings is a very naïve understanding of the issue. If the site went ahead, then this would be the thin end of the wedge. The Landowner has put forward various outlines for the site in recent years – the largest involved nearly 100 houses and relentless pressure would ensue to rise to this total.
• Any development would impact unfavourably on nearby listed buildings.
• The field has a historic right of way across the western end. For nearly a thousand years, villagers have used it to walk up to the church and the vista from this path would be irretrievably damaged.
• The major technical issue is the drainage of the site, which is totally wet. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. The heavy clay soil makes the surface completely impermeable, so heavy rain simply runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street – see comments on Infrastructure in response to question 5. Your own letter of 1990 – reference above – states “the local Planning Authority in consultation with Southern Water is not satisfied that the site can be adequately drained.
• The access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road, where the 30mph speed limit is regularly ignored to the despair of villagers.
• As stated repeatedly, the infrastructure around the site is completely inadequate for any further housing. The drains cannot cope. See copious photos in the Appendices to the PNDP.

Second PE5 Malthouse Business Park.

This small development of light industrial and commercial units is of great value to many in Peasmarsh. Its’ loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work and it seems counterproductive to positively take steps to deter employment.

67. Regarding Development Strategy Options and Preferred Approaches in Appendix 3, I do NOT agree with the elimination of option SD09 which is at least worthy of further investigation on a case-by-case basis. However, it has to be remembered that no desk-chosen arbitrary option is necessarily going to produce a figure for a community that is achievable on the ground given local constraints.

1.The Strategic Spatial Objectives are sound – BUT they should not just be stated as pious intentions - they need to be honestly adhered to in the formulating of the plan.
In particular, Point 11 states “Deliver sustainable development ………… having regard to local context and character”. There are clear instances in the approach towards Peasmarsh for example, where this principle is clearly breached.

The Objectives do not include any mention of the Area of Outstanding Natural Beauty – now called the High Weald National Landscape. Cynics might assume that the change of name is entirely because the depredation of a “landscape” sounds so much more inoffensive than destroying “Natural Beauty”. Just changing the name doesn’t make it any less beautiful or worthy of preservation. If it is destroyed once, it is destroyed forever. The Objective of preserving this should be added. This would clearly set out the context in which Chapter 6.2 can be read.

2. Regarding Infrastructure needs.

The Peasmarsh Neighbourhood Development Plan (PNDP) – accepted by Rother DC in April 2024 after an Inspection and local Referendum – highlighted in great detail the deficiencies of these services in Peasmarsh.

The sewer system is grossly inadequate – the combined drain arrangement, combining storm water with sewage, taken together with the wet conditions, ensures not only flooding but the eruption into the road of raw sewage in particularly wet times. This is confirmed by many photos in the Appendices to the PNDP. Southern Water have admitted that the Sewage Pumping Station is at the limit of its’ capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary.

Old house by the main road have wells that never run dry and complicated drain arrangements that have been installed over the years in efforts to reduce flooding. Any holes dug fill immediately with water. This high water-table problem has been known for many years but no remedies have ever been proposed or undertaken.

Both Power and Water Supply are clearly inadequate for the existing housing stock, without regard for any increases. In recent times alone, there have been many instances of power or water failure – some of these problems lasting for several days. It is foolish and irresponsible to consider any further development of the village without addressing these issues first.
In addition to these physical issues, it must be pointed out that the current Village School is oversubscribed and has no facilities to manage the large number of additional children the foreseen developments would generate.

The two local Doctors’ surgeries (Rye and Northiam) are taking on no further patients. Where is medical treatment going to be obtained?

6. The Development Option SDO13 – A21 Corridor Growth seems sensible and should indeed be pursued.

SDO14 – filling strategic gaps - should proceed as well though and the reasons given for abandoning it do not chime with the achievement of the development targets the plan defines.
Many of these reasons are well-meant, but the effect is to force unreasonable development targets onto areas which are technically totally unsuitable.
 
13. The proposed vision and development strategy for the Eastern Settlements Cluster seems totally wrong. It has all the hallmarks of a paper exercise – conducted from a desk and totally ignoring real life and the situation on the ground.

Firstly, the allocation of new homes to Peasmarsh is totally out of proportion to the existing size of the village and its’ capacity to absorb additional development. The proposals would increase the size of the village population by 15-20%, completely changing its’ character. The population of the UK is projected to rise by 7% by 2040. Why should a village in the AONB/High Weald National Landscape bear an increase twice that of the country as a whole.

Secondly, the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village – despite the very clear geographical limitations of the Village. Expecting Peasmarsh to take 20% of the additional homes in this area is clearly unbalanced and seeks for some reason to turn Peasmarsh into a dormitory suburb of Rye. The much-touted “commercial centres” in Peasmarsh are all on one site, part of one enterprise, and routinely exposed to commercial realities.

The wishes of the village, in the democratic consultations only recently, clearly expressed the wish that developments should be small-scale or infill. These proposals are the opposite of this.
It is also worth pointing out, that Peasmarsh already has more social and low-cost housing than many other East Sussex villages. Any argument therefore that large scale development is needed is incorrect. Bringing in people who would prefer to live in an urban environment into a rural village with a very limited and expensive bus service and no access to local employment is something without benefit to any of the parties involved.

The last exercise that created social housing in The Maltings Peasmarsh ended up – contrary to early statements – with few local people being housed and the council placing people from Hastings and much further afield. There is no evidence that this would not happen again.

47. I have major objections to two of the site allocations in Peasmarsh – PE3 Tanyard Field and PE5 Malthouse Business Park.

First PE3 Tanyard Field.

You refer inaccurately and laughably to this as a “new” site. This is nonsense. The Landowner has been seeking Planning Permission for this site, as a matter of certain knowledge, for more than 40 years and has repeatedly been rebuffed and rejected on appeal on at least one occasion. I hope that you will still be able to refer in your own files to the letter and document issued by Rother DC on 22nd February 1990 under Reference RR/90/0021/P which is the earliest reference I can find to development being rejected. All the reasons for rejection remain valid today and indeed in some cases are more serious than they were then.

In addition, this site was carefully investigated during the preparation of the PNDP, both by the village working group and by independent consultants, and subsequently rejected. There can be no reason, other than the persistence of the Landowner, to ride roughshod over the PNDP – endorsed as it was by decisive village democratic referendum and accepted by Rother DC in April 2024.

The site is totally unsuitable for development on many grounds:

• The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its’ undulating park-like appearance is visible from many locations round the village. Development would have a catastrophic impact on the rural character of the area.

• The visual amenity of the entire village would also be thereby damaged.

• There would be a general loss of amenity, privacy and quiet enjoyment for the large number of village houses within sight and sound of Tanyard Field.


• Acceptance of the site would encourage other similarly unsuitable applications in the vicinity.

• The suggestion that the site would accommodate 15 dwellings is a very naïve understanding of the issue. If the site went ahead, then this would be the thin end of the wedge. The Landowner has put forward various outlines for the site in recent years – the largest involved nearly 100 houses and relentless pressure would ensue to rise to this total.

• Any development would impact unfavourably on nearby listed buildings.

• The field has a historic right of way across the western end. For nearly a thousand years, villagers have used it to walk up to the church and the vista from this path would be irretrievably damaged.

• The field slopes very steeply downwards towards the North, making it totally unsuitable for housing and helping to generate the drainage problem referred to below.

• The major technical issue is the drainage of the site, which is totally wet. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. The heavy clay soil makes the surface completely impermeable, so heavy rain simply runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street – see comments on Infrastructure in response to question 5. Your own letter of 1990 – reference above – states “the local Planning Authority in consultation with Southern Water is not satisfied that the site can be adequately drained”.

• Surface water run-off is a major problem throughout the village. The clue is in the name – Peasmarsh. Tanyard is called locally “Soggy Meadow”. Some years ago the turf was stripped off the field for some reason and this made the problem significantly worse – perhaps due the clay soil being further compacted and the length of grass reduced.

• The vehicular access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road, where the 30mph speed limit is regularly ignored to the despair of villagers.

• The exits of neighbouring drives are adjacent to this access and we have witnessed numerous near-misses when people are trying to get out onto the main road.

• Any new housing would result in a substantial increase in car use and traffic generally, which is contrary to national environmental and transport policies.

• As stated repeatedly, the infrastructure around the site is completely inadequate for any further housing. The drains cannot cope. See copious photos in the Appendices to the PNDP.

• This ancient green field site, with ancient woodland to the South, and a copse at its’ centre, supports multiple species of birds, animals and plants. These include protected species such as Bats, Hedgehogs, Tawny Owls, Woodpeckers and many others.

Second PE5 Malthouse Business Park.

This small development of light industrial and commercial units is of great value to many in Peasmarsh. Its’ loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work and it seems counterproductive to positively take steps to deter employment. These units were built with EU money from Brussels with the express purpose of helping and promoting rural businesses. Despite Brexit, it would be a huge breach of faith to consider demolishing them now.

1. The Strategic Spatial Objectives are sound – BUT they should not just be stated as pious intentions - they need to be honestly adhered to in the formulating of the plan.
In particular, Point 11 states “Deliver sustainable development ………… having regard to local context and character”. There are clear instances in the approach towards Peasmarsh for example, where this principle is clearly breached.

The Objectives do not include any mention of the Area of Outstanding Natural Beauty – now called the High Weald National Landscape. Cynics might assume that the change of name is entirely because the depredation of a “landscape” sounds so much more inoffensive than destroying “Natural Beauty”. Just changing the name doesn’t make it any less beautiful or worthy of preservation. If it is destroyed once, it is destroyed forever. The Objective of preserving this should be added. This would clearly set out the context in which Chapter 6.2 can be read.

5. Regarding Infrastructure needs.

The Peasmarsh Neighbourhood Development Plan (PNDP) – accepted by Rother DC in April 2024 after an Inspection and local Referendum – highlighted in great detail the deficiencies of these services in Peasmarsh.

The sewer system is grossly inadequate – the combined drain arrangement, combining storm water with sewage, taken together with the wet conditions, ensures not only flooding but the eruption into the road of raw sewage in particularly wet times. This is confirmed by many photos in the Appendices to the PNDP. Southern Water have admitted that the Sewage Pumping Station is at the limit of its’ capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary.

Old house by the main road have wells that never run dry and complicated drain arrangements that have been installed over the years in efforts to reduce flooding. Any holes dug fill immediately with water. This high water-table problem has been known for many years but no remedies have ever been proposed or undertaken.

Both Power and Water Supply are clearly inadequate for the existing housing stock, without regard for any increases. In recent times alone, there have been many instances of power or water failure – some of these problems lasting for several days. It is foolish and irresponsible to consider any further development of the village without addressing these issues first.

In addition to these physical issues, it must be pointed out that the current Village School is oversubscribed and has no facilities to manage the large number of additional children the foreseen developments would generate.

The two local Doctors’ surgeries (Rye and Northiam) are taking on no further patients. Where is medical treatment going to be obtained?

6. The Development Option SDO13 – A21 Corridor Growth seems sensible and should indeed be pursued.

SDO14 – filling strategic gaps - should proceed as well though and the reasons given for abandoning it do not chime with the achievement of the development targets the plan defines.
Many of these reasons are well-meant, but the effect is to force unreasonable development targets onto areas which are technically totally unsuitable.

13. The proposed vision and development strategy for the Eastern Settlements Cluster seems totally wrong. It has all the hallmarks of a paper exercise – conducted from a desk and totally ignoring real life and the situation on the ground.

Firstly, the allocation of new homes to Peasmarsh is totally out of proportion to the existing size of the village and its’ capacity to absorb additional development. The proposals would increase the size of the village population by 15-20%, completely changing its’ character. The population of the UK is projected to rise by 7% by 2040. Why should a village in the AONB/High Weald National Landscape bear an increase twice that of the country as a whole.

Secondly, the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village – despite the very clear geographical limitations of the Village. Expecting Peasmarsh to take 20% of the additional homes in this area is clearly unbalanced and seeks for some reason to turn Peasmarsh into a dormitory suburb of Rye. The much-touted “commercial centres” in Peasmarsh are all on one site, part of one enterprise, and routinely exposed to commercial realities.

The wishes of the village, in the democratic consultations only recently, clearly expressed the wish that developments should be small-scale or infill. These proposals are the opposite of this.
It is also worth pointing out, that Peasmarsh already has more social and low-cost housing than many other East Sussex villages. Any argument therefore that large scale development is needed is incorrect. Bringing in people who would prefer to live in an urban environment into a rural village with a very limited and expensive bus service and no access to local employment is something without benefit to any of the parties involved.

The last exercise that created social housing in The Maltings Peasmarsh ended up – contrary to early statements – with few local people being housed and the council placing people from Hastings and much further afield. There is no evidence that this would not happen again.


47. I have major objections to two of the site allocations in Peasmarsh – PE3 Tanyard Field and PE5 Malthouse Business Park.

First PE3 Tanyard Field.

You refer inaccurately and laughably to this as a “new” site. This is nonsense. The Landowner has been seeking Planning Permission for this site, as a matter of certain knowledge, for more than 40 years and has repeatedly been rebuffed and rejected on appeal on at least one occasion. I hope that you will still be able to refer in your own files to the letter and document issued by Rother DC on 22nd February 1990 under Reference RR/90/0021/P which is the earliest reference I can find to development being rejected. All the reasons for rejection remain valid today and indeed in some cases are more serious than they were then.

In addition, this site was carefully investigated during the preparation of the PNDP, both by the village working group and by independent consultants, and subsequently rejected. There can be no reason, other than the persistence of the Landowner, to ride roughshod over the PNDP – endorsed as it was by decisive village democratic referendum and accepted by Rother DC in April 2024.

The site is totally unsuitable for development on many grounds:

• The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its’ undulating park-like appearance is visible from many locations round the village. Development would have a catastrophic impact on the rural character of the area.
• The visual amenity of the entire village would also be thereby damaged.
• There would be a general loss of amenity, privacy and quiet enjoyment for the large number of village houses within sight and sound of Tanyard Field.
• Acceptance of the site would encourage other similarly unsuitable applications in the vicinity.
• The suggestion that the site would accommodate 15 dwellings is a very naïve understanding of the issue. If the site went ahead, then this would be the thin end of the wedge. The Landowner has put forward various outlines for the site in recent years – the largest involved nearly 100 houses and relentless pressure would ensue to rise to this total.
• Any development would impact unfavourably on nearby listed buildings.
• The field has a historic right of way across the western end. For nearly a thousand years, villagers have used it to walk up to the church and the vista from this path would be irretrievably damaged.
• The field slopes very steeply downwards towards the North, making it totally unsuitable for housing and helping to generate the drainage problem referred to below.
• The major technical issue is the drainage of the site, which is totally wet. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. The heavy clay soil makes the surface completely impermeable, so heavy rain simply runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street – see comments on Infrastructure in response to question 5. Your own letter of 1990 – reference above – states “the local Planning Authority in consultation with Southern Water is not satisfied that the site can be adequately drained”.
• Surface water run-off is a major problem throughout the village. The clue is in the name – Peasmarsh. Tanyard is called locally “Soggy Meadow”. Some years ago the turf was stripped off the field for some reason and this made the problem significantly worse – perhaps due the clay soil being further compacted and the length of grass reduced.
The vehicular access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road, where the 30mph speed limit is regularly ignored to the despair of villagers.
• The exits of neighbouring drives are adjacent to this access and we have witnessed numerous near-misses when people are trying to get out onto the main road.
• Any new housing would result in a substantial increase in car use and traffic generally, which is contrary to national environmental and transport policies.
• As stated repeatedly, the infrastructure around the site is completely inadequate for any further housing. The drains cannot cope. See copious photos in the Appendices to the PNDP.
• This ancient green field site, with ancient woodland to the South, and a copse at its’ centre, supports multiple species of birds, animals and plants. These include protected species such as Bats, Hedgehogs, Tawny Owls, Woodpeckers and many others.

Second PE5 Malthouse Business Park.

This small development of light industrial and commercial units is of great value to many in Peasmarsh. Its’ loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work and it seems counterproductive to positively take steps to deter employment. These units were built with EU money from Brussels with the express purpose of helping and promoting rural businesses. Despite Brexit, it would be a huge breach of faith to consider demolishing them now.

With a high number of developments proposed for Hastings Road this will further increase congested traffic with very little protected pedestrian footways.
Once the Tapestry development is completed there will also be additional traffic onto the A2100, Hastings Road.
To reduce the reliance on individual transportation the public transport network should be increased.
Management of timing of developments should be considered to ensure there is time between developments to reduce the negative impact of traffic and construction noise, emissions and other disruptions.
Consideration must be given to the impact of increased population on emergency services and health provision.
A better process for working with the NHS and other local authority provisions should be mandatory

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.

Primary care infrastructure must be identified as a critical priority within the Infrastructure Delivery Plan. Existing GP practices in Rother are already operating at or near capacity, and the proposed housing and population growth will significantly increase demand.

The IDP must clearly identify current capacity constraints, required expansions, new healthcare facilities, and delivery timescales. Healthcare infrastructure must be planned and delivered in parallel with housing growth, not after occupation.

The Local Plan should include explicit policy mechanisms to secure developer contributions toward primary care infrastructure, including new or expanded GP premises, to ensure services remain accessible and sustainable.

Without clear, funded, and deliverable primary care infrastructure, the proposed growth risks worsening access to healthcare and undermining the creation of healthy, sustainable communities. Primary care provision must be treated as essential infrastructure.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The village is not designed to withstand such large developments, our roads cannot support the influx of cars due to out poor/average public transport system. Our local gps and dentists cannot take on the influx of people that come with such a vast amount of new homes. Our sewage system is already facing issues with the current population, let alone adding to this number. Our village simply cannot support such large developments

It will be critical to ensure identified infrastructure improvements are kept in step with housing provision and that developers are held to account if they fail to deliver infrastructure include in the planning permissions .

If I have understood this correctly, the infrastructure plan will evolve in line with circumstances. This is appropriate, given so much uncertainty around what will actually be needed, where and when. It also endorses my earlier comments under the top-down housing targets. Whilst an element of planning for overall resource allocation purposes is inevitably necessary, being too specific when there are so many moving pieces would be inappropriate.

In principle, we support the Council's development strategy, but ONLY if the necessary infrastructure, especially in terms of sewage management, is provided.

Bexhill-on-Sea Town Council would support IDP, however it was felt that developers should be required include sport facilities in the development plans. These facilities should comprise of MUGA, 3G or 4G pitches and other sports facilities available to all.

Infrastructure Development Plan needs to be one step ahead of housing allocation. So far, increased infrastructure has failed to keep pace with recent increases in housing development. RDC should maintain pressure on central government for more funding for health services and roads in particular.

There are already issues and constraints on the village infrastructure with the existing property density. Particularly in relation to lack of traffic management (particularly speeding and safe footpaths), telecoms, flooding and waste management.

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.

The NHS is devolving services from hospitals and the plan does not seem to allow this.

Please see attached for full representation:

- Full representation on Draft Rother District Local Plan 2025-2042 Consultation (including underlined text and hyperlinks that do not appear in text copied out below)
- Supporting document: Southern Water input to Rother District Council’s 2026 IDP review
- Supporting document: IDP feedback provided for the Regulation 18 consultation deadline 23rd July 2024

Q5 We attach our separate IDP response to Rother as part of our feedback to this Regulation 18 consultation on the Local Plan, requesting update of the IDP in accord with the information and explanations provided. This also includes our feedback from the previous 2024 Regulation 18 consultation, in addition to a full explanation of how Southern Water plans investment for adopted local plans. Included within this explanation are our key AMP8 (2025-2030) investment plans for the Rother district. Some plans extend into AMP9, but for the reasons we explain in our IDP response, most AMP9 schemes are not known at this time.

There is considerable investment planned for the district in this 2025-2030 AMP8 period, supported by a range of technical disciplines. This represents the latest investment information and therefore supersedes the DWMP content referred to (as this DWMP work was concluded in 2023).

Q8 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q9 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q10 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q17 Q17 - all BX sites.

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording to all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to critical assets running beneath sites.”

Southern Water’s initial checks indicate that a number of the new/changed sites (BX6, BX7, BX22, 23, 24, 27, 28, BX31, 34, 36, 37, 38, 39 and BX41) may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and all those we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BX9 and may require easements or diversion. For this site, and any we’ve previously requested layout wording please include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q19 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

26 CR1 to CR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

However, we note that for site CR2 in particular, there is no wording in the site allocation policy to address the site’s proximity to an operational wastewater treatment works. In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site CR2 is within 500m of Battle wastewater treatment works and we therefore request the additional wording –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

28 GU1 & GU2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for site GU2 at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Southern Water infrastructure crosses GU2 and may require easements or diversion.”

30 GU4 & 5

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site GU5 and may require easements or diversion. For GU5, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

31 GU6

Southern Water has identified no constraints for this site at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

32 IK1&2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site IK1 and may require easements or diversion. For IK1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

34 WS1 WS2, WS3 WS4 WS5

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that sites WS2 and WS3 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site WS3 and may require easements or diversion. For WS3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

36 BT1 to BT11 (BT3, BT4, BT5, BT6)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to this site is within 500m of Battle wastewater treatment works and we therefore request the additional wording – The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

Southern Water’s initial checks indicate that sites BT1, BT2, BT7, BT9, BT10 and BT11 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BT11 and may require easements or diversion. For BT11, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

38 CT1 CT2 CT3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure may cross sites CT2 and CT3 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

39 NE1 & 2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

40 SD10 SD11 (SD1 to SD9)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site SD11 (and as previously advised the for the existing site allocation SD7) is within 500m of Sedlescombe wastewater treatment works and we therefore request the following additional wording in these policies–
The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

42 BC1 (BC2) BC3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site BC3 and may require easements or diversion. For BC3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

43 (BR1) BR2 BR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

44 CM1 to CM3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

45 (ID1) ID2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site ID2 and may require easements or diversion. For ID2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

46 NR1 and NR2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for this site (NR2) at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

Additional policy wording is needed for each site to address it’s proximity to operational wastewater treatment works. The proposed boundary of each site is within 500m of an operational wastewater treatment works (Mill Corner Northiam WTW, and Quickbourne Lane Northiam WTW) and we therefore request the additional wording for each site policy –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses site NR2 and may require easements or diversion. For NR2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

47 PE1, 2 & 3 (PE4 & PE5)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

49 (RY1 to RY1, RY7&8) RY5, RY6 & RY9

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that sites RY5 and RY9 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses sites RY5, RY6 and RY9 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

50 RH1

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

53 BW1 to 4

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that site BW1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Please note that Southern Water wastewater sewers cross all BW sites (BW1 to 4) and may require easements or diversion (so please note that whilst we agree that consultation with Southern Water will be required, it may not be necessary for the developer to deliver a package treatment plant as currently stated in part Xi of the policy. Were the developer to want to deliver such plant they will first need to consult with the Environment Agency). For these sites, and any we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

54 BWC1 and 2

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

55 EC1 to 3

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site EC1 and may require easements or diversion. For EC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

56 (HG1&2) HG3 & 4

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that site HG4 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses site HG3 and may require easements or diversion. For HG3, and any sites we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

57 RB1, RB3, RB4 (RB2, RB5) to RB6a & RB6b

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to sites R3 and R4 (and also as will have been previously advised the boundary to existing site allocation RB2) are all within 500m of Robertsbridge wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses sites RB3, and RB5 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

58 SC1 & 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site SC1 and may require easements or diversion. For SC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

59 FW1 to FW3

Southern Water’s initial checks indicate that site FW2 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure crosses site FW2 and may require easements or diversion. For FW2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

60 TC1 (or 2)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water’s initial checks indicate that site TC1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure also crosses site TC1 and may require easements or diversion. For TC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

62 SG1 or 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundaries to each site are within 500m of Stonegate wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Southern Water infrastructure crosses these sites and may require easements or diversion. For these sites please therefore also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q64 GYP1 to GYP6

Southern Water’s initial checks indicate that some of the GYP sites are proposed within 500m of operational wastewater treatment works. For example, the boundary to site GYP6 is within 500m of Robertsbridge WTW.

We therefore request Rother consult us on planning applications for all sites so that we can share the results of more detailed checks with the authority. Southern Water also request the addition of the following wording for all sites –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

And for each site proposed within 500m of operational wastewater treatment works (eg GYP6) please include the following additional wording;
“The layout of ‘sensitive residences’ for any site allocation within 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Q69 Any other issues or comments?

All site allocations should be proposed in locations where utilities can provide for the forecasted needs of the development without prejudicing existing or future utility provision necessary to support growth. Southern Water therefore requests the following additional policy wording in the Regulation 19 draft of the Local Plan:
The utility network should be protected and development proposals that would compromise existing utilities infrastructure, or encroach on future connections for utilities, will be refused. Opportunities should be sought to safeguard the provision of utilities wherever possible.

Concerns for Peasmarsh regarding very sparse transport via bus. Pathways and pavement are not all suitable for walking/ cycling. Plus dark sky policy means travelling around at night is difficult.
Local GP surgery is full and cannot take further patients at this time.
No local NHS dentist practice available. The village has had numerous power and water issues, with an already poor infrastructure with the stress of more homes using that poor infrastructure it will impact all without major utilities being improved ,..

The residents and businesses on Eversley Road rely heavily upon the Eversley Road parking lot. Space is already limited for us, who pay a lot of money to park near our homes. Additionally, this is a quiet street, and residents are strongly opposed to the idea of more noise, less space, and more strain on our delicate infrastructure. We do NOT want or need more housing in this street. We need our parking space.

This document all sounds very good but from what I see to much development goes ahead without guaranteed infrastructure in place and underway before housing developments get underway. In Bexhill there is already a shortage of school places and doctors appointments are very difficult to get and this has only got worse in the last 2/3 years with all the development going on. The evidence is there no new schools or doctors surgeries.

Trains are only once an hour and are very overcrowded. There is only one bus an hour. The are queues to get a doctors appointment. The soul of the village is being ripped with no consideration for the locals or wildlife and we will be living in a town

I support the principle that new development should be supported by appropriate infrastructure and that infrastructure planning should form an integral part of the Local Plan.

However, it is important to recognise that different scales of development place different demands on infrastructure. Smaller and medium-scale developments within or adjacent to existing settlements can often be accommodated more easily within existing infrastructure networks, particularly where they relate well to established communities and services.

In considering the Development Strategy, the Council should therefore ensure that opportunities for well-located smaller sites are not overlooked, as these can contribute positively to housing delivery while placing relatively limited pressure on strategic infrastructure.

I object to the proposed development strategy
The road network that serves the district along the south coast and the A21 linking Hastings and part of Rother to M25 and beyond, all experience heavy volumes of traffic making journey times slow and unreliable. The lack of road infrastructure has impacted on Rother and Hastings bringing low levels of investment to the area.
The rail network and standard of train services require upgrade and better infrastructure.
Water supply needs updating before any new homes are built.
An upgraded sewage system is greatly needed.
Managing surface water.
Improved pedestrian and cycle networks.
Youth and community facilities.
Play areas.
Health service, doctors and dentists all require a major transformation.

I would like you to add to the transport and movement section. The allocation of cycle routes along the A21 and between the villages is very poor and this is not addressed later in the document. Cycle routes should be built in to this whole strategy and given more priority. Further, equestrianism needs to be added to all cycle routes. This will enable safer riding and the ability for the equestrian sector to thrive, which is an important part of the rural economy in the Rother area.

Q5: Poor drainage and flooding. Poor road surfaces and too much traffic. Lack of healthcare services, only 1 major hospital (Conquest). No village GP surgery. Shortage of dental clinics. School oversubscribed. No more reservoir/ water treatment/ sewage treatment. No more power stations. So where will all these extra homes get their water supply and electricity from?
Q69: There will be no affordable property for local young people to buy or rent. Our village will become populated by people from other areas eg London. Also more Airbnbs

In Peasmarsh we have a bus service that is not fit for purpose , one bus every two hours , how can anybody hold down a job with that kind of service , also does not tie up with other services trains etc , then in Peasmarsh we have lots of power cuts through out the year , then the sewage is constantly being dumped by southern water, so how can anymore houses be built here , southern water has admitted it will not be able to supply drinking water if all the houses that central government want were to be built , hosepipe bans in june 2025 to January 2026 , look at how many problems southern water had in early 2026 , none of this development is sustainable with outdated
pumping stations etc etc this is all asking for problems going forward, also NO doctors in Peasmarsh

With Strategic Objective 1 being amended to include resilience to climate change and adaptation there needs to be a whole new chapter in this LDF around Emergency Preparedness.

I recommend as follows:
1. Consult with LRF partners on this. Ensure the LDF supports their statutory duties under the Civil Contingencies Act to warn and inform, develop plans and serve vulnerable people.
2. Set minimum resilience standards for new community buildings: Generators / Solar PV / batteries, Ability to remain cool, defensible perimeter for wildfire, accessible, water storage, ability to support bottled water / other distributions, first aid / AED etc.
3. Identify places of safety in each community having reviewed the LRF Community risk register. Identify community groups that should be supported to provide local response (e.g. Businesses, third sector, community groups, farmers etc) as part of the economic strategy.
NOTE: The local authority rest centre model will likely be overwhelmed in the next few years and emergency services are increasingly likely to be delayed responding particularly in rural areas. The first responder is likely to be your neighbour and local communities
4. Ensure that developers are building in accessible spaces that are resilient to climate change.