GU2 proposals. Rock Lane is too narrow to support this site. With planning already granted for 20 + dwellings opposite Churchill Avenue the traffic will horrendous and very dangerous. Rock lane regularly floods at this proposed site entrance.

1 green belt area
2 rock lane already busy
3 drainage issue
4 sewage pipes not strong already a smell
5 Entrance not safe
6 speed too fast

Development should remain on Hastings BC side of boundary, not just over boundary into Rother. Vehicles 7.5 tonnes not allowed through Three Oaks or the lanes to/from A259 but do. No enforcement so traffic already destroying Butchers, Rock, & Ivyhouse LANES which have no substructure so collapsing. Water supply & drains already breaking under weight of vehicles. Ivyhouse Lane industrial estate needs to be blocked to through traffic & ONLY accessible from The Ridge.

We support the provision for additional housing in the proposed area subject to:

1. It should be a requirement of the developer to provide 25% social housing;

2. The current road is inadequate and dangerous; there should be a 20 mile an hour speed limit imposed, improved footpath provision and resurfacing with proper drainage.

This land is part of the High Weald Natural Landscape and development of this area would have a profound impact on wildlife, including protected species. It is an area known to suffer from surface water flooding and water supply issues due to Southern Water’s poor infrastructure which would add further burden to this.
Access to further housing developments via Rock Lane would be totally inappropriate and unviable, given what is already a well established area of many properties accessed via this very narrow, poorly maintained road. There would be huge logistical difficulties, disruption and further damage to road surfaces caused by the build itself, as access for large vehicles would be extremely difficult. Even during daytime hours, the upper part of Rock Lane is jam packed with parked cars. The general traffic flow on this road is already problematic, and at times, unsafe.

In relation to Policy GU2: This land is part of the High Weald Natural Landscape and development of this area would have a profound impact on wildlife, including protected species. It is an area known to suffer from surface water flooding and water supply issues due to Southern Water’s poor infrastructure which would add further burden to this. Access to further housing developments via Rock Lane would be totally inappropriate and unviable, given what is already a well established area of many properties accessed via this very narrow, poorly maintained road. There would be huge logistical difficulties, disruption and further damage to road surfaces caused by the build itself, as access for large vehicles would be extremely difficult. Even during daytime hours, the upper part of Rock Lane is jam packed with parked cars. The general traffic flow on this road is already problematic, and at times, unsafe.

I object to future development on GU2 land were is all the wild life going to go newts badgers foxes field mice sparrow hawks barn owls and other protected species and this land is classed as part of the high Weald natural landscape,The road itself is like single track in areas and a increase in traffic due to extra housing and existing traffic from housing in the area the road wasn’t made to accommodate the extra traffic there are also problems with flooding in this area water from the sloping adjoining fields water pressure is poor could be a problem for the extra housing and even bigger problem for existing properties around this area access for large vehicles attending this GU2 site will find it difficult due to the limitations of this small lane and definitely would be a hazard to other road users

Green space
Road too narrow
Sewage won't cope
No schools/doctors for extra pressure
Wild life
Agriculture land
Plenty of brown sites to use

It builds on the High Weald National Landscape with an abundance of wildlife including protected species, it is steeply sloping with existing surface water and drainage problems. The adjoing land above it, that Hastings Borough Counil are considering for development, slopes down to it from the Rye Road and a 2023 residents survey identified flood risk and natural ground instability due to climate change between 5 and 30 years. Access is only via Rock Lane, which is already over capacitated and dangerous to drive on. Cumulatively the RDC and Hastings proposals build circa 90 houses on land that currently houses one single dwelling. There is an old rubbish dump on the land, an old brickworks and railway architecture. Residents have formed a well supported public campaign group to oppose this and the Hastings proposals. It also falls foul of a number of provisions in the 2025 National Planning PolicyFramework.

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.

I live above the proposed site GU2.This site is at the bottom of sloping fields and must be liable to flooding.Rainwater off Rye Road pours down onto our properties and continues into the fields below us.With extreme rainfall every winter becoming the norm this can only become worse over time.
Rock Lane is a narrow, busy and often downright dangerous country lane.A new access road with its additional traffic will add to the danger.
We have a great variety of wildlife and people love to observe them.It would be tragic to lose this vital green space with its trees, hedgerows and wildlife habitats that have been undisturbed for many years.
Developers are pushing for easy builds on Greenfield sites with no consideration for residents, their environment or local wildlife.
Local councils must do all they can to protect their green spaces and look to develop brownfield and derelict sites.

I have no comments on GU1 but on GU2 I think it is essential that before any further houses are built adjacent to Rock Lane, the general condition of the road on the whole of Rock Lane should be improved so that the surface is better and visibility improved. The addition of 20 new dwellings will add further traffic to an already poor road with a very bad surface in some areas and which is subject to flooding in parts.

Guestling / Hastings Rock lane site - this is totally unsuitable in terms of:
1. Access - is really poor to this site from Rock Lane
2. Ecology - No ecological / dark skies assessment has taken place. This area has bats, newts, birds of prey amongst countless others.
3. Flood risk - topology does not support this and drainage is tricky given high water table and water logging of the area. House surveys in Churchill Avenue are already highlighting a 1:30 flood risk
4. Ribbon development: the proposal for adjoining Hastings / Rother developments makes for ribbon development, banned under your own policy framework.

The Land GU2 sits within the High Weald National Landscape is very marshy, prone to flooding and runs into Rock lane at the bottom end causing flooding. Climate change will only make things worse. Access is in a very narrow, busy, often flooded poorly maintained Rock lane. An abundant wildlife ecosystem exists with protected species, foxes, bats, newts and a large population of slow worms coming from the established hedgerows. Local infrastructure has problems coping at present let alone without the extra pressures that new houses will bring.

Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations: Public Consultation under Regulation 18 of The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended)

Thank you for your consultation on the above draft Local Plan.

We have a number of significant concerns with the quantum and scale of site allocations proposed in the draft Local Plan, in terms of impacts on the nationally designated High Weald National Landscape, such that we would consider the plan to conflict with paragraphs 189 and 190 of the NPPF, and thereby unsound in its present form. We would make the following comments:

Development Strategy

Notwithstanding the references in paras 3.9 and 3.21 of the draft plan regarding the protection of National Landscapes, and the ability to reduce housing requirements accordingly, we are extremely concerned by the proposed Development Strategy set out in section 5 of the draft plan, and the quantum of development proposed within the High Weald National Landscape.

Paragraph 189 of the NPPF sets out that ‘great weight’ should be given to conserving and enhancing landscape and scenic beauty in National Landscapes, which (along with National Parks & the Broads) ‘have the highest status of protection in relation to these issues’. It also sets out that ‘the scale and extent of development within these designated areas should be limited’ and that ‘development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.’

The proposed 2,055 number of new dwellings on sites within the High Weald National Landscape (over and above existing allocations in the 2019 DaSA) could in no way be described as ‘limited in extent’, nor could the fact that 23 of the site allocations are proposed for 30+ dwellings, (and 11 of those sites proposed for 60+ dwellings) be descried as ‘limited in scale’. At the broadest level, and notwithstanding the large area of Rother District that lies within the High Weald National Landscape, we therefore consider the allocations strategy at the broadest level would fail to comply with para 189 of the NPPF.

You will see from the Site Allocations comments later in this response, and our site-specific comments appended in table form to this response, that we consider a large number of the proposed site allocations would be harmful to the natural beauty of the High Weald National Landscape, and would fail to comply with para 189 of the NPPF, and, in a number of instances, para 190 too. We therefore consider that a number of the proposed site allocations should be deleted from the draft Local Plan, and the proposed number of dwellings in the housing requirement reduced accordingly.

We appreciate that the 2024 changes to the standard method for calculating objectively assed need has resulted in a larger OAN for Rother DC (described in paras 3.1-3.4 of the draft plan). However, importantly, the NPPF allows for strategic policies in Local Plans to provide for less than the housing need in certain circumstances, while the NPPG clarifies that Local housing need (calculated using the standard method as amended in December 2024) is not necessarily the same as the housing requirement that goes forward in a Local Plan.
This was confirmed by the Government in their published Government response to the proposed reforms to the NPPF (Government response for Questions 1 and 2) published 20th July 2024, which states:

“The standard method identifies the minimum number of homes needed and local planning authorities are expected to plan to meet their housing needs in full. However it is recognised that there may be local constraints on land and delivery that could justify a lower housing requirement figure.” (N.B. Underlining added for emphasis).

Accordingly, para 69 of the NPPF sets out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period. (N.B. bold added for emphasis)
That Government response also clarified that the NPPG had been updated accordingly. The NPPG (Housing and Economic Needs Assessment) confirms that:

“The standard method set out below identifies a minimum annual housing need figure, … It does not produce a housing requirement figure.” (Paragraph: 002 Reference ID: 2a-002-20241212)

and explains the difference between local housing need and housing requirement, and clarifying that:

“The housing requirement is the minimum number of homes that a plan seeks to provide during the plan period. Once local housing need has been assessed, as set out in this guidance, authorities should then make an assessment of the amount of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters.” (Paragraph: 040 Reference ID: 2a-040-20241212)

Paragraph 11 (b) (i) of the NPPF sets out that local planning authorities should provide for objectively assessed needs for housing and other uses, as well as any unmet needs from neighbouring areas, unless “the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area”. The assets referred to are listed in footnote 7 and include National Landscapes, the relevant policies for which in the Framework being 189 and 190.

Accordingly, the NPPG (natural Environment) clarifies that, with regard to National Landscapes:

“The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas…” (Paragraph: 041 Reference ID: 8-041-20190721.) (bold text added for emphasis)

Whilst we acknowledge the intention to seek to meet as far as possible the OAN, this must be carried out in the context of the limited scale and extent of development in National Landscapes required by the NPPF, and within the context of the ‘great weight’ to be given to conserving and enhancing their landscape and scenic beauty.
Further, this must be carried out in a way which is compliant with the High Weald AONB Management Plan 2024-2029 This statutory document is adopted by all the relevant local authorities with land in the High Weald National Landscape, including Rother District Council, as their policy for the management of the area and for the carrying out of their functions in relation to it, and is a material consideration for planning applications affecting the HWNL.

With particular regard to the High Weald National Landscape, Management Plan Settlement Action ‘h’ sets out that partners will “Pursue landscape-led positive planning approaches to settlement planning and housing delivery in the AONB, seeking to prioritise the delivery of new housing primarily through small-scale development consistent with AONB character, recognising the potential for harm through the cumulative effects of separate developments on the designated landscape”

Rother District Council has had considerable success over the last couple of years, including since the publishing of the new standard methodology for OAN, in defending housing development appeals in the HWNL, with Inspectors agreeing with the Council’s assessment of harms of specific proposals on the landscape character and natural beauty of the HWNL, and that such harms meant that policies of the Framework provide a strong reason for refusing the development proposed. The same logic can and should therefore confidently be applied to the consideration of proposed sites under NPPF para 11(d)(i).

Major Development

With regard to the subject of major development in the HWNL in site allocations, we are particularly concerned by para 6.6. of the ‘Draft Development Stategy for Rother’, which, while recognising that the NPPF confirms that major development in National Landscapes should only be permitted in exceptional circumstances and where it can be demonstrated that the development is in the public interest, states ”The need for housing, including affordable housing, in sustainable locations within the district could potentially be an exceptional circumstance that could allow for a major development within the HWNL.”.

To justify major development on the basis of meeting objectively assessed housing needs for the local planning authority area is a circular argument at plan-making stage, because the impact of the scale and distribution of development on the National Landscape should be taken into account in deciding the level of housing provision (NPPF paras 69 and 11(d)(i)). If such housing levels can only be achieved by allocating major development in the NL, which by definition will have “a significant adverse impact on the purposes for which the area has been designated” then this is a good indicator that the impact on the National Landscape provides “a strong reason for restricting the overall scale, type or distribution of development in the plan area” as provided for in NPPF paragraph 11.

Paragraph 190 of the NPPF sets out that within National Landscapes, planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.

Whilst paragraph 190 specifically refers to planning permissions, it has also been considered relevant by Local Plan Inspectors to allocations within Local Plans.1 Legal advice provided to the South Downs National Park Authority by Landmark Chambers also concluded that “it would arguably amount to an error of law to fail to consider paragraph 116 (now 190) at the site allocations stage of plan making for the National Park. The consequence of doing so would be to risk allocating land for major development that was undeliverable because it was incapable of meeting the major development test in the NPPF”2.

We would consider a large number (some 16) of the site allocations proposed in the draft plan to constitute major development under the NPPF definition in footnote 64 of paragraph 190. As such, there would be a presumption against the allocation of these sites for development, and they are considered in more detail in the individual site comments below and appended table. In summary it is considered that the inclusion of the majority of these major sites would render the current plan unsound, as it would conflict with the NPPF.

Proposed draft Site Allocations

We are extremely concerned that sites with the HWNL have been proposed in this draft local plan prior to the carrying out of any detailed Landscape Capacity Studies, Landscape Sensitivity Studies or Landscape Visual Assessments, as part of the evidence base. We consider any proposed site allocations to be premature in the absence of such work.

We note that some sites have been considered in the HELAA Landscape Sensitivity Assessment (September 2022), however, this work is very brief, just one or two paragraphs per site plus a table, and we do not consider this is a sufficiently robust or detailed assessment of the impacts of the sites; the Site Assessment Table doesn’t assess the sensitivity of the sites in the HWNL against the AONB Management Plan key character components of natural beauty, and includes no map or photographic based assessment. Also, along with sensitivity assessments, those sheets also assign a range of ‘value’ to each site, including those within the HWNL (high, high/medium/medium etc) – whereas as designated NLs they have already been assigned the highest level of value by government (see Landscape Institute’s GLVIA3 Notes & Clarifications 5(7). Furthermore, in some instances the cautionary conclusions of the HELAA LSA do not seem to have informed the proposed allocations.

For any sites within, or affecting the setting of the National Landscapes, site assessment work needs to take into account the impact of those potential sites on the purposes of the designation, taking into account the HWNL (AONB) Management Plan. Planning Principle 1 of the High Weald AONB Management Plan 2024-2029 gives advice on the type of assessments that should inform local plans.

Decisions on allocating sites within or affecting the setting of National Landscapes requires a robust understanding of landscape including the history and settlement patterns of the wider landscape. Site-specific landscape sensitivity studies and landscape and visual assessments and are an important part of this, to inform the principle of allocation, the appropriate quantum and location of development, the extent of site coverage, any mitigation strategies, e.g. landscape buffers and their appropriate location and size, and to consider any other site-specific issues.

A key concern is that we note that for a number of the proposed site allocations, the ‘site specific development requirements’ in the draft local plan mention the need for development to be informed by a landscape sensitivity assessment. However, this is too late in the process, the Landscape Sensitivity Study needs to be completed first, to inform the allocation process, not post-allocation. Moreover, the LSS needs to be prepared objectively by the LPA.

No allocation should be being proposed until the above work is completed -it is wholly insufficient to simply include a reference in the policy supporting text (as in the current draft) that ‘”It is within the High Weald National Landscape and therefore a sensitive form of development is required in line with Local Plan policies”– in order to align with the requirements of NPPF para 189, impacts on the setting of the HWNL need to be robustly considered prior to allocating a site; firstly regarding the principle of the allocation; the location and scale of development in relation to the HWNL, and secondly to inform/test the quantum of development that might be appropriate in such a location.

Additionally, any site allocations proposed for grassland sites in the HWNL should also be subject to grassland surveys, and if found to be unimproved grassland these should not continue to be allocated for development in the Reg 19 version, since this is an important habitat type within the HWNL, and an important part of its landscape character and natural beauty.

We consider there therefore needs to be considerable further site-specific work undertaken to inform the next iteration of the draft local plan. We understand that the next iteration is intended to be a Reg 19 version with consultation scheduled for the autumn, for submission in December under the current Local Plans regime. However, in view of the additional work needed in relation to the proposed sites, and our comments on the site allocations below, we consider this would be premature, and the timescale to be unrealistic, and instead we consider a further Reg 18 consultation would be more appropriate.

Densities

We note that para 5.16-5.26 of the draft Local Plan deal with the matter of densities in residential development. Whilst in principle we have no issue with higher densities – High Weald settlements are typically fairly high density in village cores- it is important to recognise that this is through their being populated with tight-knit streetscapes of smaller dwellings. In order to meet Settlement Objectives S1 and S2 of the High Weald AONB Management Plan, we consider that guidance, either in a general density policy and/or the site-specific policies, will need to clarify this, so as to manage developer expectations and avoid scenarios where schemes are submitted consisting of high numbers of detached/semi-detached buildings packed in close proximity to each other, as that would constitute an approach and grain that would be discordant with High Weald settlement pattern and streetscape character.

Site Specific Policies

Further to the site specific assessment work, and to ensure that clear and realistic expectations for each site are set, with regard to the High Weald AONB Management Plan, and the Council’s duty under section 85 of the CRoW Act, we advise that the site-specific policies for all those sites proposed within the HWNL (and those affecting its setting) included in the next iteration of the draft Local Plan should:

• include maps/plans setting guiding principles/parameters for development (including extent of site coverage, building heights, and the retention of any existing wooded boundaries, and enhancement of these where appropriate for mitigation measures), and
• refer to the HWNL in the ‘Site specific development requirements’, and include in those requirements that proposals need to reference the principles in the HW Housing Design Guide, and that lighting proposals (including highways lighting) to be based on the HWNL Dark Skies Planning Advice Note.

Individual proposed sites comments

In the light of the absence of a detailed landscape evidence base, the appended table represents our initial comments on the draft proposed sites; however, with some we are able to recognise significant harms to the HWNL even without the further work, and these are highlighted red in the table as sites that, at this stage, we object to being allocated for development.

Overall, you will see that we consider a number of sites would cause significant harm to the natural beauty of the High Weald National Landscape, would conflict with objectives of the HW AONB Management Plan 2024-2029, and would conflict with policy 189 of the NPPF, resulting in the plan being unsound, and therefore should not be allocated for development in the next iteration of the draft plan. These are: BT1 (in part), BT8, BT10, BC1, BR3, BW3, BW4, BWC1, EC2, EC3, FW2, GU6, HG4, IK1, IK2, NR2, PE1, PL1, SD11, SC2, and TC1. A summary of our reasons for arriving at these conclusions is included in the appended table. This list includes a number of sites that we consider should be considered ‘major development’ in the HWNL under the provisions of NPPF para 190, and for which there do not appear to be exceptional circumstances (see our earlier general comments in this response). However, the absence of red highlight on other sites in the table (or that they are not included in the above list) does not mean that we support the allocation, rather that at this stage we are unable to provide a definitive view on either the principle of development or the quantum proposed, without the further landscape assessment work being carried out (and we set this out for those sites).

Legislative Requirements

Lastly I would also draw to your attention Section 85 of the CRoW Act (as amended by the Levelling-Up and Regeneration Act in December 2023) sets out that ‘relevant authorities’, in exercising or performing any function that affect National Landscapes in England, “must seek to further the purpose of conserving and enhancing the natural beauty of the Area of Outstanding Natural Beauty.”3

Within the planning context, ‘relevant authorities’ are the Local Planning Authorities and the Planning Inspectorate, along with Parish Councils producing Neighbourhood Plans, and the duty applies to all aspects of the planning process, including decisions relating to site allocations in Local Plans etc. More information for LPAs on complying with the new duty in the planning policy plan-making process is available at CRoW-s.85-duty-guidance-for-LPAs_NLA-Briefing-Nov-24.pdf

Conserving and enhancing the natural beauty of the High Weald National Landscape (HWNL) will normally mean avoiding harm, and conserving and enhancing the character components identified in the AONB Management Plan; supporting the Management Plan Objectives as set out for each of these; and following any Management Plan Actions set out for each.

It is therefore important that this new duty is reflected in the language and content of the Local Plan throughout, including in the commitment to any particular housing requirement figure, the spatial strategy, policy direction and ambition, and the evaluation of any proposed site allocations.

The above comments are advisory and are the professional views of the HWNL Unit’s Planning & Design Advisor on the potential impacts on the High Weald landscape. They are not necessarily the views of the HWNL Joint Advisory Committee.


Please see attached documents including HWNL response letter and Appendix 1.

I am writing this letter to strongly object toany building of houses of any sort in Brackendale (GU2) and Winchelsea Lane which backs on to Brackendale.

This is an area of outstanding natural beauty.

It is agricultural land.

The land is very wet because it is steep and the water from the Rye Road above runs down it and onto the road which floods frequently.

There is a lot of wildlife on this land which includes ; Frogs, Newts, Bats, Snakes, foxes, Hedgehogs, Birds, Lizards, Barn Owls, Slow Worms and more.
Rock Lane is not up to taking any more traffic as it is already a very busy and dangerous road.

There are also not enough Doctor's, Dentist's, Hospital appointments and Schools to cope with more people.

PS on Southern News 11 March S/E Water said it would not have water for more houses etc.

I would like to protest against the proposal to build 20 houses on Brackendale Rock Lane (GU2) and also houses in Winchelsea Lane and other local areas. (approximately 80 new houses over three sites)

This road is already a death trap and more houses mean more traffic.

When I am walking my dog up and down the road cars do not slow down at all and if they hit a bump in the road or a pothole they could swerve into us. In fact I was shouted at the other day by a driver.

There is a gentleman who walks up and down the road every day and has told me he often has to dive into the hedge to avoid being hit.

Brackendale is agricultural land in an area of outstanding natural beauty. It is also very wet because it is steep and water runs down from Rye Road above and comes out onto the road which frequently floods.

I also understand that there is a lot of wildlife on the property; Slow Worms, Foxes, Hedgehogs, Newts, Lizards, Snakes, Barn Owls, Bats and many more.

There are also not enough Doctor's willing to take on new patients, Dentist's Schools, and Hospitals.

Coming out of my driveway cars do not slow down.

There have been several Foxes killed recently on the road.

We live in Austen Way. Our gardens are currently bogs and when it rains we have to sweep water away to stop our house flooding.
I am really concerned that if more plants are removed our homes will be under water.
The problem has been getting worse each year

Re: GU2

Rock Lane is a country lane which is not suitable for any more traffic than it already has. It is hardly wide enough even for pavements. Construction traffic that is required for development of a site on this land would create noise and disruption for local residents and wildlife, and there would be increased use of the lane by domestic traffic with new houses.
This is essentially a haven for wildlife, made up of gorse and other small trees and bushes, in which we have seen foxes rear their young, lots of small birds nesting in the branches and in the banks, and kestrels and buzzards hunting regularly over the field. There are hedgehogs, and badger pathways through the gardens around the field. It is quiet, with resident sheep; a green lung on the edge of town, and we feel it should not be included in the plan.

We object most strongly to the inclusion of GU2 in the Rother plan. The site is unsuitable for the development of multiple dwellings for the following reasons.
The site is within the High Weald National Landscape (HWNL), formerly known as the AONB, and this status offers protection to the land within by designating it as a protected landscape under the Countryside and Rights of Way Act 2000. Local authorities are required to conserve and enhance the area's natural beauty, not to construct housing estates on it!
The entire site, being in an elevated position, is visible from many surrounding areas and from other land within the HWNL. The preservation of this visual amenity is essential. Trees allegedly screening it on the west will not hide it from view from all other directions. Development will be detrimental to HWNL visitors and existing nearby residents.
Previous planning applications in this area have always been rejected on the grounds of AONB, access, and the visual amenity that the green spaces provide. Planning application HS/FA/88/864 made to Hastings Borough Council in 1988 was refused on the grounds that for the AONB, there is a "Natural Presumption" against further development other than in "EXCEPTIONAL CIRCUMSTANCES".
The entire site slopes and is susceptible to surface water and flooding from the land higher up the slope, including from the A259 Rye Road.
The land is enjoyed and inhabited by flora and fauna, namely foxes, badgers, hedgehogs, common newts, slow worms, nesting birds, including kestrels, bats, butterflies and moths, including cinnabar moths which feed on the ragwort that grows on the site. We believe the land has been classified as Agricultural.
Existing homes within the immediate surrounding area already suffer from low water pressure and frequent outages, due to lack of sufficient supply. Adding further homes to the area will exacerbate this problem.
Other essential services in the area are already insufficient to meet existing demand. For example, all local schools are already significantly over subscribed. There are no adjacent GP surgeries, and no dentists, etc. There is NO public transport available to this site.
Vehicular and pedestrian access to any housing development on the site will be unacceptable. The existing road known as Rock Lane has no pavements and is very narrow. Traffic levels already verge on dangerous. Especially if pavements were to be added the lane would remain too narrow, if not even narrower. The level of traffic that will be generated by the new household's private vehicles, as well as service vehicles (refuse carts, delivery vehicles, etc), and emergency vehicles will be too high for the local roads to carry and will lead to dangerously high increases in traffic flows.

I object to GU2 due to:-
Site of natural beauty, area of flooding, very poor access, very poor drainage, protected wildlife (newts,sloeworms,kites,bats,owls). The infrastructure of the area can not sustain more people. Houses will have multiple cars and the roads are not built for large amount of traffic only just get 1 car at a time down. The roads around the area are already crumbling.

GU1, already access route to a very busy industrial estate and then leading to a narrow single track (in places) road where there are already major lorry access issues.
The Ridge at this area does not have the capacity for more traffic in and out of a road that constantly has numerous caravans and lorries parked along the sides
GU2 - This is an area with width restrictions, overparking beacuse of flats , small houses and a carvan park, buses already struggle for access in the area and this is just encroaching furyer and furher into the AONB , into an area that was always meat to be a "buffer" zone between rural and urnban areas

Local Plan Consultation: GU2: Brackendale, Rock Lane.

The reason that I am commenting on this proposal is that I live in Winchelsea Lane in Hastings that sits above Rother's GU2.

I did submit a few of my comments on your website but as it limited me to 100 words I had to miss out a lot of what I wanted to say.

I have therefore set out my full views here.

GU2 allows for a comprehensive scheme to be developed in conjunction with the adjoining land within Hastings Borough. Their proposals are HS13 and HS21 in their Local Plan.

Rother's (RDC) proposal is for 40 houses and Hastings Borough Council (HBC) are for one of 20 houses and another of 32. In total therefore, 92 new houses on largely previously undeveloped land in the High Weald National Landscape.

I completely oppose GU2 as I know are our neighbours and local residents in Winchelsea Lane, Churchill Avenue and Austen Way, who have formed a campaign group against GU2 and the HBC proposals.

This group has met in Ore Community Centre with a large turn out and the local press attended. We have also gone door to door to chat to people, most of whom were completely unaware of RDC GU2 and the HBC proposals.

Reasons for Opposition to GU2

- High Weald National Landscape

RDC say in the draft Local Plan, that the site comprises one single residential dwelling in a large plot of land adjacent to existing built development and within the High Weald National Landscape.

This places significant protections on that area and I completely oppose any attempt by RDC to build a housing estate on this protected land, that added to HBC proposals will cover all of this area of land in houses.

- Protected Species and Wildlife

As well as it being in the High Weald National Landscape, there is abundant wildlife present including many protected species; hedgehogs, newts, lizards, slow worms, grass snakes, bats, barn owls and a whole variety of nesting birds. Lengthy construction work and all the houses built will only lead to the complete destruction of the habitats of the wildlife and many of the wildlife unable to escape.

This is completely unacceptable and I will oppose any destruction of the wildlife and its habitats on this part of the protected National Landscape.

- Vehicle Access

The access to GU2 is via Rock Lane. This is a narrow lane, already over capacitated and quite dangerous to drive along. Adding another 40 properties by RDC will make this significantly worse. In addition, HBC HS21 says that access to 32 proposed new properties on that land can only be accessed from Rock Lane.

Therefore, on top of the lengthy building work, with large construction vehicles and workers vehicles, the 72 houses when built with all add on considerable traffic to an already well over congested Lane.

This is worsened when you take into account the need for access for emergency vehicles, waste collection, Royal Mail and other essential services.

I would argue that GU2 automatically fails the test on those grounds alone, irrespective of HBC'S HS21.

- 2023 Home Buyers Survey: Flooding and ground instability

A resident of Churchill Avenue whose property backs directly onto the land above GU2 had a search completed in 2023 and this reported that the land in HBC'S HS13;

Climate Change: Flood risk and natural ground instability between 5 and 30 years.

Indeed HBC say in proposal HS13 that the land is steeply sloping and will require a land stability assessment. This also reinforces the issues highlighted in HS21 where it is stated that there is a sharp difference in levels with the land in that proposal, and the issues in the Home Buyers survey mentioned above.

That land directly leads at a steep level into RDC GU2. Indeed the RDC report includes mention of risks from surface water flooding.

- Drainage

Drainage is an on-going significant issue with water and drains running down the very steep incline from Rye Road and the houses on the main Winchelsea Lane down towards Rock Lane.

There is a main drain beside No 7 Winchelsea Lane, directly to the side of the field and that leads to a soakaway in HS13. The owner of the land of HS13 has previously warned about the danger of going on that land due to the swampy nature of it.Drains that lead from the houses on the main Winchelsea Lane failed in recent years leading to our garage below them, to be flooded and they had to be diverted into a new soakaway into the land behind our house.

Gardens on Winchelsea Lane have also experienced flooding in recent times and Again, the home buyers survey mentioned above reinforces this genuine concern.

With the incessant wet winters we are now experiencing with significant heavy rainfall, these concerns are even more to the forefront and the on-going drainage problems in HBC HS13 and HS21 will only seep into RDC GU2.

- Disused Rubbish Dump and Brick Works

A resident on the main Winchelsea Lane, who is 93 and lived there for decades, says there was a rubbish dump on the land and a brick works.

Quite what is buried there adds to the concerns, with potential very toxic waste materials.

- Historic Railway Architecture.

The home buyer's survey mentioned above also identified historic railway architecture on the land.

- Opportunity For A Footpath Cycle Connection Towards Winchelsea Lane

The only access to Winchelsea Lane is via a privately owned drive of which No's 7, 9 and 11 and a landowner who doesn't live here, have joint responsibility for the up keep of. The owners of 7, 9 and 11 will not give their permission for the creation of a footpath and or cycle connection on this private land.

- Cumulative Impact of HBC Proposals HS13 and HS21 with Rother Proposal GU2

It is important to flag up the cumulative effect of these three proposals that taken together build 92 houses on land in the protected High Weald Natural Landscape running between Winchelsea Lane in Hastings and Rock Lane in Rother.

The area over HS13 and HS13 plus Rother's GU2, is of a peaceful tranquil nature with historic trees and hedgerows, abundant wildlife including many protected species in an area of National Landscape with no housing or other developments.

- National Policy Planning Policy Framework 2025

As I write this, this new framework is out for consultation but I understand the Local Plan will need to conform to on the day it comes into force.

The concerns I have outlined above are covered in this including the impact of climate change, flooding, drainage and ground instability.It also states, if significant harm to biodiversity resulting from a development cannot be avoided then the development should be refused (after considering potential mitigations) and in N4: Protected Landscapes, it states that proposal for major developments within these should only be supported in exceptional circumstances.

The cumulative impact of RDC GU2 and HBC's HS13 and HS21 in one strip from Winchelsea Lane down to Rock Lane clearly makes this a major development.

Also I have covered above, there is abundant wildlife including protected species. Further; on page 89; Protected Landscapes, it states that proposals for major developments within protected landscapes should only be supported in exceptional circumstances.

On page 23; Principle of Development Within Settlements, Section S4, it makes it clear that developments should be refused where the proposals would have an unacceptable impact in relation to local green space, designated wildlife habitats.

This section also importantly says that proposed developments that involve the whole or partial loss of undeveloped land which is used for flood risk management, unless suitable compensatory provision is made, which does not increase the risk of flooding either on or off site.

As I have highlighted above, those drainage issues are not potential, they are a serious on-going concern and the landowner has previously advised not to go on it as it is very swampy. The high levels of incessant rainfall we now experience simply exasperates this with the various soakaways from the main Winchelsea Lane and above draining into the land.

On Page 69 onwards; Local Parking Standards, it highlights the importance of parking standards for residential development and dealing with the issues of avoiding or mitigating any adverse environmental impacts from traffic.

There are considerable adverse environmental impacts from these proposals. Currently there is one dwelling on GU2 with a tiny number of vehicle journeys each day. Building an estate of 40 houses, plus 32 in HBC adjoining HS21 will easily increase that to the 100's each day with polluting carbon monoxide.

This would be in addition to the years of heavy construction vehicles, builders Transport and the on-going existing significant traffic problems in Rock Lane.

This is reinforced on Pages 80 and 81 where avoiding exposure to levels of noise, artificial light and so forth that could have unacceptable adverse impact on health and wellbeing is covered.

Conclusion

I urge Rother District Council to take full note of the number of valid arguments above that highlight just how unsatisfactory proposal GU2 is and exclude it from the Local Plan. Also to exclude HBC HS13 and HS21 from joint work with RDC.

Local Plan Consultation: GU2: Brackendale, Rock Lane.

I live in Winchelsea Lane in Hastings that sits above Rother's GU2.

I have submitted my a few of my concerns on your website but I was not able to work out how to submit more than simply 100 words, which is not nearly enough and it did not allow me to submit everything I wanted to say.

I have therefore set out my full views here.

As your proposal states, GU2 allows for a comprehensive scheme to be developed in conjunction with the adjoining land within Hastings Borough. Their proposals are HS13 and HS21 in their Local Plan.

Rother's (RDC) proposal is for 40 houses and the two proposals from Hastings Borough Council (HBC) are for one of 20 houses and another of 32. In total therefore, 92 new houses on largely previously undeveloped land in the High Weald National Landscape.

I completely oppose GU2 as I know are our neighbours and local residents in Winchelsea Lane, Churchill Avenue and Austen Way, who have formed a campaign group against GU2 and the HBC proposals.

This group has met in Ore Community Centre with a large turn out and the local press attended. We have also gone door to door to chat to people, most of whom were completely unaware of RDC GU2 and the HBC proposals.

Reasons for Opposition to GU2

- High Weald National Landscape

RDC say in the draft Local Plan, that the site comprises one single residential dwelling in a large plot of land adjacent to existing built development and within the High Weald National Landscape.

This places significant protections on that area and I completely oppose any attempt by RDC to build a housing estate on this protected land, that added to HBC proposals will cover all of this area of land in houses.

- Protected Species and Wildlife

As well as it being in the High Weald National Landscape, there is abundant wildlife present including many protected species; hedgehogs, newts, lizards, slow worms, grass snakes, bats, barn owls and a whole variety of nesting birds. Lengthy construction work and all the houses built will only lead to the complete destruction of the habitats of the wildlife and many of the wildlife unable to escape.

This is completely unacceptable and I will oppose any destruction of the wildlife and its habitats on this part of the protected National Landscape.

- Vehicle Access

The access to GU2 is via Rock Lane. This is a narrow lane, already over capacitated and quite dangerous to drive along. Adding another 40 properties by RDC will make this significantly worse. In addition, HBC HS21 says that access to 32 proposed new properties on that land can only be accessed from Rock Lane.

Therefore, on top of the lengthy building work, with large construction vehicles and workers vehicles, the 72 houses when built with all add on considerable traffic to an already well over congested Lane.

This is worsened when you take into account the need for access for emergency vehicles, waste collection, Royal Mail and other essential services.

I would argue that GU2 automatically fails the test on those grounds alone, irrespective of HBC'S HS21.

- 2023 Home Buyers Survey: Flooding and ground instability

A resident of Churchill Avenue whose property backs directly onto the land above GU2 had a search completed in 2023 and this reported that the land in HBC'S HS13;

Climate Change: Flood risk and natural ground instability between 5 and 30 years.

Indeed HBC say in proposal HS13 that the land is steeply sloping and will require a land stability assessment. This also reinforces the issues highlighted in HS21 where it is stated that there is a sharp difference in levels with the land in that proposal, and the issues in the Home Buyers survey mentioned above.

That land directly leads at a steep level into RDC GU2. Indeed the RDC report includes mention of risks from surface water flooding.

- Drainage

Drainage is an on-going significant issue with water and drains running down the very steep incline from Rye Road and the houses on the main Winchelsea Lane down towards Rock Lane.

There is a main drain beside No 7 Winchelsea Lane, directly to the side of the field and that leads to a soakaway in HS13. The owner of the land of HS13 has previously warned about the danger of going on that land due to the swampy nature of it.Drains that lead from the houses on the main Winchelsea Lane failed in recent years leading to our garage below them, to be flooded and they had to be diverted into a new soakaway into the land behind our house.

Gardens on Winchelsea Lane have also experienced flooding in recent times and Again, the home buyers survey mentioned above reinforces this genuine concern.

With the incessant wet winters we are now experiencing with significant heavy rainfall, these concerns are even more to the forefront and the on-going drainage problems in HBC HS13 and HS21 will only seep into RDC GU2.

- Disused Rubbish Dump

A resident on the main Winchelsea Lane, who is 93 and lived there for decades, says there was a rubbish dump on the land and a brick works.

Quite what is buried there adds to the concerns, with potential very toxic waste materials.

- Historic Railway Architecture.

The home buyer's survey mentioned above also identified historic railway architecture on the land.

- Opportunity For A Footpath Cycle Connection Towards Winchelsea Lane

The only access to Winchelsea Lane is via a privately owned drive of which No's 7, 9 and 11 and a landowner who doesn't live here, have joint responsibility for the up keep of. The owners of 7, 9 and 11 will not give their permission for the creation of a footpath and or cycle connection on this private land.

- Cumulative Impact of HBC Proposals HS13 and HS21 with Rother Proposal GU2

It is important to flag up the cumulative effect of these three proposals that taken together build 92 houses on land in the protected High Weald Natural Landscape running between Winchelsea Lane in Hastings and Rock Lane in Rother.

The area over HS13 and HS13 plus Rother's GU2, is of a peaceful tranquil nature with historic trees and hedgerows, abundant wildlife including many protected species in an area of National Landscape with no housing or other developments.

- National Policy Planning Policy Framework 2025

As I write this, this new framework is out for consultation but I understand the Local Plan will need to conform to on the day it comes into force.

The concerns I have outlined above are covered in this including the impact ofclimate change, flooding, drainage and ground instability.

It also states, if significant harm to biodiversity resulting from a development cannot be avoided then the development should be refused (after considering potential mitigations) and in N4: Protected Landscapes, it states that proposal for major developments within these should only be supported in exceptional circumstances.

The cumulative impact of RDC GU2 and HBC's HS13 and HS21 in one strip from Winchelsea Lane down to Rock Lane clearly makes this a major development.

Also I have covered above, there is abundant wildlife including protected species. Further; on page 89; Protected Landscapes, it states that proposals for major developments within protected landscapes should only be supported in exceptional circumstances.

On page 23; Principle of Development Within Settlements, Section S4, it makes it clear that developments should be refused where the proposals would have an unacceptable impact in relation to local green space, designated wildlife habitats.

This section also importantly says that proposed developments that involve the whole or partial loss of undeveloped land which is used for flood risk management, unless suitable compensatory provision is made, which does not increase the risk of flooding either on or off site.

As I have highlighted above, those drainage issues are not potential, they are a serious on-going concern and the landowner has previously advised not to go on it as it is very swampy. The high levels of incessant rainfall we now experience simply exasperates this with the various soakaways from the main Winchelsea Lane and above draining into the land.

On Page 69 onwards; Local Parking Standards, it highlights the importance of parking standards for residential development and dealing with the issues of avoiding or mitigating any adverse environmental impacts from traffic.

There are considerable adverse environmental impacts from these proposals. Currently there is one dwelling on GU2 with a tiny number of vehicle journeys each day. Building an estate of 40 houses, plus 32 in HBC adjoining HS21 will easily increase that to the 100's each day with polluting carbon monoxide.

This would be in addition to the years of heavy construction vehicles, builders Transport and the on-going existing significant traffic problems in Rock Lane.

This is reinforced on Pages 80 and 81 where avoiding exposure to levels of noise, artificial light and so forth that could have unacceptable adverse impact on health and wellbeing is covered.

Conclusion

I urge Rother District Council to take full note of the number of valid arguments above that highlight just how unsatisfactory proposal GU2 is and exclude it from the Local Plan. Also to exclude HBC HS13 and HS21 from joint work with RDC.

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