The development suggested for 28 new dwellings cannot be supported with access to Chapel Lane. Chapel Lane is busy as it it is and it would be dangerous to add potentially access to and from for a minimum of another 28 vehicles. There have been accidents already reported with drivers having to swerve to avoid ongoing vehicles. At school drop off and pick up it is particularly bad and from what I am told, entry to Guestling Primary School is already over subscribed so how can that support further development.

The highways infrastructure as it is cannot support this type of development in this location unless access to and from the proposed sites is directly from the A259.

This site historically/currently is a water logged field - the proposal in the plans to combat this will not help as the water will run off not only the site the but towards the proposed roadway down onto the narrow single track country lane adding hugely to the flood situation of 2 properties which have already experienced their homes flooded further down the lane

The lane can not manage this amount of extra traffic potentially 100 more resident vehicles and prior site traffic with both entrances into the lane narrow and awkward. We have an already oversubscribed school where parents park down the lane .

I am concerned about my own very old GradeII listed house and those others on the lane being damaged by constant large building lorries and subsequent more traffic. This build will have a terrible everlasting effect on us if allowed.

We object to this development because insufficient consideration has been given to the fact it has two borders with a working farm. The additional vehicles, possibly 40 plus, would bring noise and pollution, impacting farm animals and wildlife. It is a greenfield site, elevated above the lane and fields so making a significant visual impact on the recognised area of natural beauty. Chapel Lane narrows towards The Green and Pett Road junction, any new access road would add to existing safety issues and congestion. impacting on other road users especially cyclists, pedestrians and horse riders. The current sewage infrastructure has given problems and considerable improvements would be required.

Moved here just over a year ago.Chapel Lane is a narrow road with room for one car in places and no footpath.It is already used as a rat run by speeding cars and the junction with the A259 is already clogged especially at school times.It is also used daily by horseriders.Another 20 homes = a potential extra 20 to 40 cars using the lane every day increasing co2 emissions. Also pulling out from a new road onto Chapel Lane will be an accident waiting to happen.
This Lane is already dangerous enough to walk and drive down without increased traffic.

The site lies within the setting of an Area of Outstanding Natural Beauty where great weight should be given to conserving landscape and scenic character. The scale of development would urbanise the countryside and cause harm.
The area supports habitats for protected species, including bats. The development risks disturbance, fragmentation and biodiversity loss, and insufficient evidence has been provided to show these impacts can be adequately mitigated.
Local infrastructure is already under pressure. The primary and secondary schools are oversubscribed and existing services are struggling to meet current needs. Additional housing will worsen this situation.
The surrounding lanes are narrow and unsuitable for increased traffic. They already experience severe congestion and gridlock, particularly at school drop-off and pick-up times. Extra vehicle movements would further harm highway safety for pedestrians, cyclists and drivers.

The sites are within the High Weald AONB, a protected area of exceptional natural beauty. Building here would harm the landscape, impacting visual and ecological values that are meant to be preserved. The area is entirely lacking in essential amenities — no shops, medical facilities, or public transport options — meaning future residents would be forced to rely on private vehicles, adding to congestion on narrow, country lanes, especially during school drop-off times. The local primary school is already over-subscribed, and the addition of new homes will exacerbate pressure on an already stretched educational system. The development site is situated next to a working farm, where sheep graze and fields are used to grow hay for livestock feed. This proximity could lead to conflicts between farming practices (e.g., noise, odours) and residential living. Lastly, the existing sewage system is incapable of handling additional waste, creating further risks for local infrastructure.

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.

Residents of Guestling Green strongly object to GU4 Wild Meadows and GU5, Former Highways
Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to tiny, ancient
hamlet within High Weald National Landscape, causing irreversible harm.
Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows,
dark skies, and profound tranquillity - vital for elderly population.
Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further
enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF
“great weight” to landscape beauty, and listed building settings.
Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow
Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality
decline, and habitat loss.
No local need exists: 2021 survey identified
Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected
rural gem.

Residents of Guestling Green strongly object to GU4 Wild Meadows and GU5, Former Highways
Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to tiny, ancient
hamlet within High Weald National Landscape, causing irreversible harm.
Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows,
dark skies, and profound tranquillity - vital for elderly population.
Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further
enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF
“great weight” to landscape beauty, and listed building settings.
Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow
Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality
decline, and habitat loss.
No local need exists: 2021 survey identified
Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected
rural gem.

The proposal to build 20 houses on the site of Wild Meadows would have a devastating impact on the AONB from the landscape view from Church Lane where Higham.Gardens sits into a lowering landscape Wild Meadows sits much higher which would ruin the outlook. Together with these fields have historical feeding routes for the nighttime wild life to the ancient woodland under dark skies would also end if this build we to be allowed . Having lived here for some years and sadly had to move it would change the landscape and the life for the residents forever who have worked hard to maintain it

The building of 20 houses on the site of Wild Meadows should not be allowed as looking from Church Lane the land of Wild Meadows sits high in the landscape of AONB protected land where the suggested alignment with Higham gardens cannot be compared as this area sits much lower contouring to the landscape. The local school is oversubscribed and the buses run infrequently. Most new homes suggested would use cars adding to at least 60 additional vehicles not to mention deliveries to new homes . The listed buildings including Honeysuckle Cottage do not have modern foundations which puts them at risk and the suggestion of vehicles going to the yard is not comparable to constant heavy plant and digging closely opposite and those entering the lane close to others.This site had been refused by Rother Planning and by the appeal board. This is a constant anxiety for us all

Residents of Guestling & surrounds strongly object to GU4 Wild Meadows and GU5, Former Highways Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to tiny, ancient hamlet within High Weald National Landscape, causing irreversible harm. Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows, dark skies, profound tranquillity - vital for elderly population. Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF “great weight” to landscape beauty, and listed building settings. Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality decline, and habitat loss. No local need exists: 2021 survey identified Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected rural gem

Residents of Guestling Green strongly object to GU4 Wild Meadows and GU5, Former Highways
Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to a tiny, ancient
hamlet within High Weald National Landscape, causing irreversible harm.
Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows,
dark skies, and profound tranquillity - vital for elderly population.
Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further
enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF
“great weight” to landscape beauty, and listed building settings.
Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow
Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality
decline, and habitat loss.
No local need exists: 2021 survey identified
Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected
rural gem.

Objection to Policies GU4 (Wild Meadows) and GU5 (Former
Highways Depot), Chapel Lane, Guestling Green
–
Rother Local
Plan 2025-2042


Dear Rother Planning Policy Team,

We, the residents of Guestling Green and the surrounds, strongly object to the proposed allocations under Policies GU4 (Wild Meadows, some 20 dwellings) and GU5 (Former Guestling Highways Depot, some 8 dwellings) in the Draft Local Plan2025-2042. These greenfield and brownfield sites, both on Chapel Lane, would collectively add 28 new homes to our tiny, historic hamlet in the heart of the High Weald National Landscape. This would cause irreversible harm to our irreplaceable rural character, breach statutory protections, exacerbate practical issues like flooding and traffic, and serve no demonstrated local need. We urge the removal of both sites entirely from the plan, with all growth redirected to less sensitive local urban areas.

Guestling Green is a quintessential Wealden hamlet: a loose cluster of ancient buildings scattered around the Grade I listed St Laurence’s Church (dating to the 12th century), with iconic Grade II listed cottages such as The Thatch, Honeysuckle Cottage, and Magnolia Cottage evoking traditional Sussex life. Surrounded by ancient woodlands, irregular medieval fields, thick hedgerows, and panoramic views, it exemplifies the High Weald’s outstanding natural beauty—designated for the highest level of national protection. The area draws walkers along the 1066 Country Trail and offers profound tranquillity, with dark skies and low pollution
levels that support wildlife and residents alike. Our community is predominantly older (Rother has 32.5% over 65s, far above national averages), valuing this peaceful, low-density environment for health, wellbeing, and independence.

Introducing 28 homes would suburbanise this precious pocket of rural England, setting a precedent for further sprawl and eroding what makes it special. These allocations directly breach overriding legal and policy protections. First, Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling-up and Regeneration Act 2023) imposes a statutory duty on Rother District Council to “seek to further” the conservation and enhancement of the High Weald National Landscape’s natural beauty, wildlife, and cultural heritage. The 2025 High Court ruling in R (CPRE Kent) v Secretary of State confirms this requires proactive enhancement, not mere mitigation of harm. Yet GU4—a 2.7-acre greenfield site of garden and equestrian paddocks—would fragment medieval field patterns and ancient hedgerows, while GU5 (0.96 acres, a former depot) would introduce dense housing incompatible with the dispersed settlement form. Neither “furthers” protection; they actively undermine it. Similarly, the High Weald National Landscape Management Plan 2024–2029, adopted by Rother as a material consideration, is violated. Objectives S3 (conserving built heritage and settlement patterns), FH2 (maintaining small, irregular fields bounded by hedgerows and woodlands), and DS1/DS2 (preserving dark skies and minimising light pollution) are all contravened. GU4’s
development would suburbanise a classic dispersed hamlet, as per the Plan’s Parish Information Maps for Guestling, while GU5’s infill on a semi-rural site would add visual intrusion.

The Plan’s Dark Skies Planning Advice Note (2024) highlights the High Weald’s rare darkness; new homes mean streetlights, security lighting, and window spill, disrupting nocturnal species like bats and owls, and harming human sleep and wellbeing. Under the National Planning Policy Framework (NPPF) paragraphs 189–190, “great weight” must be given to conserving landscape and scenic beauty in National Landscapes, with major development refused unless exceptional circumstances exist and it serves the public interest. These sites—treated as “major” in scale for a tiny hamlet—fail this test. No overriding need justifies the harm, especially when Rother’s housing targets can be met in less protected areas. The Planning (Listed Buildings and Conservation Areas) Act 1990 further protects the settings of nearby Grade II buildings; both sites adjoin Honeysuckle Cottage, with GU4 also near The Thatch, risking harm to their historic integrity through visual and noise intrusion. Practical harms are severe and unmitigable, starting with flood risk.

GU4’s northern and eastern parts are at surface water flood risk, as admitted in the plan and confirmed by Environment Agency maps (low to medium probability, 0.1–3.3% annually). Development onthe 1.36-acre built area would increase impermeable surfaces, worsening runoff toward the River Bewl tributary and Chapel Lane. Climate projections (UKCP18) forecast 25–40% more intense rainfall by the 2040s, amplifying risks in East Sussex’s clay soils. Sustainable Drainage Systems (SuDS) are required but challenging on a sloped site with high water tables, potentially failing biodiversity net gain under the Environment Act 2021. GU5 has southern runoff issues, compounding cumulative flooding from both sites. This breaches NPPF’s sequential test, directing growth to lower-risk zones. Traffic and infrastructure strain would be intolerable.

Chapel Lane is narrow, winding, and hedge-lined—unsuitable for 60 + extra vehicles (assuming 1.5–2 per home). School runs, deliveries, and commuting would create congestion and safety hazards, especially near Guestling Bradshaw CE Primary School, already overpopulated at capacity. New families would drive to alternatives in Ore or Hastings, increasing air pollution (NO₂ and PM2.5) on local lanes. Rother’s Sustainability Appraisal acknowledges inevitable pollution rises from development; in our clean-air hamlet, this is unacceptable. Noise pollution from cars, doors, and activity would shatter our profound rural tranquillity, vital for older
residents’ mental health and reduced isolation. Pollution extends to light and water. GU4 and GU5 would introduce light spill, ruining the High Weald’s dark skies—one of the South East’s best for stargazing. Air quality, currently excellent (no Air Quality Management Areas), would deteriorate from traffic, harming respiratory health in our elderly-heavy community.

Run off could carry pollutants (oils, chemicals) into streams and ancient woodlands, fragmenting habitats for rare species. Crucially, there is no local need justifying this. The 2021 Guestling & Pett Housing Needs Survey—commissioned by the parish councils—identified only 11 households parish-wide needing affordable housing, all with strong local ties (family, work, residency). Mostly younger singles or couples seeking 1–2 bed units, this tiny demand has likely reduced through turnover. Parish councils reviewed it in 2023–2024 and confirmed insufficient support for low-cost housing. Yet the plan mandates 40% affordable (about 11 units total), serving district-wide waiting lists and outsiders, altering our owner-occupied, cohesive community without benefiting locals.

This ignores Rother’s policies prioritising urban growth and fails to meet “local only” exception sites. The cumulative impact of 28 homes is devastating: overpopulating our quiet hamlet, straining services (no shops, limited buses), harming tourism (our walks and heritage draw visitors), and eroding social cohesion. It sets a precedent for sprawl, undermining the High Weald’s uniqueness. Better alternatives exist where infrastructure already exists. We call for both sites’ removal. This consultation (open until March 23, 2026) must heed local voices, as per the Interim Consultation Statement. Failing to protect Guestling Green betrays national
duties and our community’s future.

The residents of Guestling Green and the surrounds, strongly object to the proposed allocations under Policies GU4 (Wild Meadows, some 20 dwellings) and GU5 (Former Guestling Highways Depot, some 8 dwellings) in the Draft Local Plan 2025-2042.

These greenfield and brownfield sites, both on Chapel Lane, would collectively add 28 new homes to our tiny, historic hamlet in the heart of the High Weald National Landscape. This would cause irreversible harm to our irreplaceable rural character, breach statutory protections, exacerbate practical issues like flooding and traffic, and serve no demonstrated local need. We urge the removal of both sites entirely from the plan, with all growth redirected to less sensitive local urban areas.

Guestling Green is a quintessential Wealden hamlet: a loose cluster of ancient buildings scattered around the Grade I listed St Laurence’s Church (dating to the 12th century), with iconic Grade II listed cottages such as The Thatch, Honeysuckle Cottage, and Magnolia Cottage evoking traditional Sussex life. Surrounded by ancient woodlands, irregular medieval fields, thick hedgerows, and panoramic views, it exemplifies the High Weald’s outstanding natural beauty—designated for the highest level of national protection. The area draws walkers along the 1066 Country Trail and offers profound tranquillity, with dark skies and low pollution levels that support wildlife and residents alike. Our community is predominantly older (Rother has 32.5% over 65s, far above national averages), valuing this peaceful, low-density environment for health, wellbeing, and independence. Introducing 28 homes would suburbanise this precious pocket of rural England, setting a precedent for further sprawl and eroding what makes it special.

These allocations directly breach overriding legal and policy protections. First, Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling-up and Regeneration Act 2023) imposes a statutory duty on Rother District Council to “seek to further” the conservation and enhancement of the High Weald National Landscape’s natural beauty, wildlife, and cultural heritage. The 2025 High Court ruling in R (CPRE Kent) v Secretary of State confirms this requires proactive enhancement, not mere mitigation of harm. Yet GU4—a 2.7-acre greenfield site of garden and equestrian paddocks—would fragment medieval field patterns and ancient hedgerows, while GU5 (0.96 acres, a former depot) would introduce dense housing incompatible with the dispersed settlement form. Neither “furthers” protection; they actively undermine it. Similarly, the High Weald National Landscape Management Plan 2024–2029, adopted by Rother as a material consideration, is violated. Objectives S3 (conserving built heritage and settlement patterns), FH2 (maintaining small, irregular fields bounded by hedgerows and woodlands), and DS1/DS2 (preserving dark skies and minimising light pollution) are all contravened. GU4’s development would suburbanise a classic dispersed hamlet, as per the Plan’s Parish Information Maps for Guestling, while GU5’s infill on a semi-rural site would add visual intrusion.

The Plan’s Dark Skies Planning Advice Note (2024) highlights the High Weald’s rare darkness; new homes mean streetlights, security lighting, and window spill, disrupting nocturnal species like bats and owls, and harming human sleep and wellbeing. Under the National Planning Policy Framework (NPPF) paragraphs 189–190, “great weight” must be given to conserving landscape and scenic beauty in National Landscapes, with major development refused unless exceptional circumstances exist and it serves the public interest. These sites—treated as “major” in scale for a tiny hamlet—fail this test. No overriding need justifies the harm, especially when Rother’s housing targets can be met in less protected areas. The Planning (Listed Buildings and Conservation Areas) Act 1990 further protects the settings of nearby Grade II buildings; both sites adjoin Honeysuckle Cottage, with GU4 also near The Thatch, risking harm to their historic integrity through visual and noise intrusion. Practical harms are severe and unmitigable, starting with flood risk. GU4’s northern and eastern parts are at surface water flood risk, as admitted in the plan and confirmed by Environment Agency maps (low to medium probability, 0.1–3.3% annually). Development on the 1.36-acre built area would increase impermeable surfaces, worsening runoff toward the River Bewl tributary and Chapel Lane. Climate projections (UKCP18) forecast 25–40% more intense rainfall by the 2040s, amplifying risks in East Sussex’s clay soils. Sustainable Drainage Systems (SuDS) are required but challenging on a sloped site with high water tables, potentially failing biodiversity net gain under the Environment Act 2021. GU5 has southern runoff issues, compounding cumulative flooding from both sites. This breaches NPPF’s sequential test, directing growth to lower-risk zones.

Traffic and infrastructure strain would be intolerable. Chapel Lane is narrow, winding, and hedge-lined—unsuitable for 60 + extra vehicles (assuming 1.5–2 per home). School runs, deliveries, and commuting would create congestion and safety hazards, especially near Guestling Bradshaw CE Primary School, already overpopulated at capacity. New families would drive to alternatives in Ore or Hastings, increasing air pollution (NO₂ and PM2.5) on local lanes. Rother’s Sustainability Appraisal acknowledges inevitable pollution rises from development; in our clean-air hamlet, this is unacceptable. Noise pollution from cars, doors, and activity would shatter our profound rural tranquillity, vital for older residents’ mental health and reduced isolation. Pollution extends to light and water. GU4 and GU5 would introduce light spill, ruining the High Weald’s dark skies—one of the South East’s best for stargazing. Air quality, currently excellent (no Air Quality Management Areas), would deteriorate from traffic, harming respiratory health in our elderly-heavy community. Run off could carry pollutants (oils, chemicals) into streams and ancient woodlands, fragmenting habitats for rare species. Crucially, there is no local need justifying this. The 2021 Guestling & Pett Housing Needs Survey—commissioned by the parish councils—identified only 11 households parish-wide needing affordable housing, all with strong local ties (family, work, residency). Mostly younger singles or couples seeking 1–2 bed units, this tiny demand has likely reduced through turnover. Parish councils reviewed it in 2023–2024 and confirmed insufficient support for low-cost housing. Yet the plan mandates 40% affordable (about 11 units total), serving district-wide waiting lists and outsiders, altering our owner-occupied, cohesive community without benefiting locals. This ignores Rother’s policies prioritising urban growth and fails to meet “local only” exception sites.

The cumulative impact of 28 homes is devastating: overpopulating our quiet hamlet, straining services (no shops, limited buses), harming tourism (our walks and heritage draw visitors), and eroding social cohesion. It sets a precedent for sprawl, undermining the High Weald’s uniqueness. Better alternatives exist where infrastructure already exists . We call for both sites’ removal. This consultation (open until March 23, 2026) must heed local voices, as per the Interim Consultation Statement. Failing to protect Guestling Green betrays national duties and our community’s future.

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.

See attached.

Residents of Guestling Green strongly object to GU4 Wild Meadows and GU5, Former Highways
Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to tiny, ancient
hamlet within High Weald National Landscape, causing irreversible harm.
Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows,
dark skies, and profound tranquillity - vital for elderly population.
Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further
enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF
“great weight” to landscape beauty, and listed building settings.
Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow
Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality
decline, and habitat loss.
No local need exists: 2021 survey identified
Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected
rural gem.

As a local resident I strongly object to GU4 Wild Meadows and GU5, Former Highways Depot in Rother’s Draft Local Plan 2025-2042. These would add 28 dwellings to tiny, ancient hamlet within High Weald National Landscape, causing irreversible harm. Features include Grade I and II listed buildings, medieval field patterns, woodlands, hedgerows, dark skies, and profound tranquillity - vital for elderly population. Proposals breach statutory duties under s.85 Countryside and Rights of Way Act ( further enhancement, 2025 High Court ruling), High Weald Management Plan (S3, FH2, DS1/DS2), NPPF “great weight” to landscape beauty, and listed building settings. Unmitigable harms, worsened flood risk from climate projections), severe traffic safety on narrow Chapel Lane (60+ extra vehicles), noise, light pollution (harming wildlife and sleep), air quality decline, and habitat loss. No local need exists: 2021 survey identified Residents demand removal of sites to prevent suburbanisation and protect irreplaceable protected rural gem

Additional submission by email received 23/093/2026:

As a resident of Chapel Lane I strongly object to the proposed allocations under Policies GU4 (Wild Meadows, some 20 dwellings) and GU5 (Former Guestling Highways Depot, some 8 dwellings) in the Draft Local Plan 2025-2042.

These greenfield and brownfield sites, both on Chapel Lane, would collectively add 28 new homes to our tiny, historic hamlet in the heart of the High Weald National Landscape. This would cause irreversible harm to our irreplaceable rural character, breach statutory protections, exacerbate practical issues like flooding and traffic, and serve no demonstrated local need. We urge the removal of both sites entirely from the plan, with all growth redirected to less sensitive local urban areas.

Guestling Green is a quintessential Wealden hamlet: a loose cluster of ancient buildings scattered around the Grade I listed St Laurence’s Church (dating to the 12th century), with iconic Grade II listed cottages such as The Thatch, Honeysuckle Cottage, and Magnolia Cottage evoking traditional Sussex life. Surrounded by ancient woodlands, irregular medieval fields, thick hedgerows, and panoramic views, it exemplifies the High Weald’s outstanding natural beauty—designated for the highest level of national protection. The area draws walkers along the 1066 Country Trail and offers profound tranquillity, with dark skies and low pollution levels that support wildlife and residents alike. Our community is predominantly older (Rother has 32.5% over 65s, far above national averages), valuing this peaceful, low-density environment for health, wellbeing, and independence. Introducing 28 homes would suburbanise this precious pocket of rural England, setting a precedent for further sprawl and eroding what makes it special.

These allocations directly breach overriding legal and policy protections. First, Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling-up and Regeneration Act 2023) imposes a statutory duty on Rother District Council to “seek to further” the conservation and enhancement of the High Weald National Landscape’s natural beauty, wildlife, and cultural heritage. The 2025 High Court ruling in R (CPRE Kent) v Secretary of State confirms this requires proactive enhancement, not mere mitigation of harm. Yet GU4—a 2.7-acre greenfield site of garden and equestrian paddocks—would fragment medieval field patterns and ancient hedgerows, while GU5 (0.96 acres, a former depot) would introduce dense housing incompatible with the dispersed settlement form. Neither “furthers” protection; they actively undermine it. Similarly, the High Weald National Landscape Management Plan 2024–2029, adopted by Rother as a material consideration, is violated. Objectives S3 (conserving built heritage and settlement patterns), FH2 (maintaining small, irregular fields bounded by hedgerows and woodlands), and DS1/DS2 (preserving dark skies and minimising light pollution) are all contravened. GU4’s development would suburbanise a classic dispersed hamlet, as per the Plan’s Parish Information Maps for Guestling, while GU5’s infill on a semi-rural site would add visual intrusion.

The Plan’s Dark Skies Planning Advice Note (2024) highlights the High Weald’s rare darkness; new homes mean streetlights, security lighting, and window spill, disrupting nocturnal species like bats and owls, and harming human sleep and wellbeing. Under the National Planning Policy Framework (NPPF) paragraphs 189–190, “great weight” must be given to conserving landscape and scenic beauty in National Landscapes, with major development refused unless exceptional circumstances exist and it serves the public interest. These sites—treated as “major” in scale for a tiny hamlet—fail this test. No overriding need justifies the harm, especially when Rother’s housing targets can be met in less protected areas. The Planning (Listed Buildings and Conservation Areas) Act 1990 further protects the settings of nearby Grade II buildings; both sites adjoin Honeysuckle Cottage, with GU4 also near The Thatch, risking harm to their historic integrity through visual and noise intrusion. Practical harms are severe and unmitigable, starting with flood risk. GU4’s northern and eastern parts are at surface water flood risk, as admitted in the plan and confirmed by Environment Agency maps (low to medium probability, 0.1–3.3% annually). Development on the 1.36-acre built area would increase impermeable surfaces, worsening runoff toward the River Bewl tributary and Chapel Lane. Climate projections (UKCP18) forecast 25–40% more intense rainfall by the 2040s, amplifying risks in East Sussex’s clay soils. Sustainable Drainage Systems (SuDS) are required but challenging on a sloped site with high water tables, potentially failing biodiversity net gain under the Environment Act 2021. GU5 has southern runoff issues, compounding cumulative flooding from both sites. This breaches NPPF’s sequential test, directing growth to lower-risk zones.

Traffic and infrastructure strain would be intolerable. Chapel Lane is narrow, winding, and hedge-lined—unsuitable for 60 + extra vehicles (assuming 1.5–2 per home). School runs, deliveries, and commuting would create congestion and safety hazards, especially near Guestling Bradshaw CE Primary School, already overpopulated at capacity. New families would drive to alternatives in Ore or Hastings, increasing air pollution (NO₂ and PM2.5) on local lanes. Rother’s Sustainability Appraisal acknowledges inevitable pollution rises from development; in our clean-air hamlet, this is unacceptable. Noise pollution from cars, doors, and activity would shatter our profound rural tranquillity, vital for older residents’ mental health and reduced isolation. Pollution extends to light and water. GU4 and GU5 would introduce light spill, ruining the High Weald’s dark skies—one of the South East’s best for stargazing. Air quality, currently excellent (no Air Quality Management Areas), would deteriorate from traffic, harming respiratory health in our elderly-heavy community. Run off could carry pollutants (oils, chemicals) into streams and ancient woodlands, fragmenting habitats for rare species. Crucially, there is no local need justifying this. The 2021 Guestling & Pett Housing Needs Survey—commissioned by the parish councils—identified only 11 households parish-wide needing affordable housing, all with strong local ties (family, work, residency). Mostly younger singles or couples seeking 1–2 bed units, this tiny demand has likely reduced through turnover. Parish councils reviewed it in 2023–2024 and confirmed insufficient support for low-cost housing. Yet the plan mandates 40% affordable (about 11 units total), serving district-wide waiting lists and outsiders, altering our owner-occupied, cohesive community without benefiting locals. This ignores Rother’s policies prioritising urban growth and fails to meet “local only” exception sites.

The cumulative impact of 28 homes is devastating: overpopulating our quiet hamlet, straining services (no shops, limited buses), harming tourism (our walks and heritage draw visitors), and eroding social cohesion. It sets a precedent for sprawl, undermining the High Weald’s uniqueness. Better alternatives exist where infrastructure already exists . We call for both sites’ removal. This consultation (open until March 23, 2026) must heed local voices, as per the Interim Consultation Statement. Failing to protect Guestling Green betrays national duties and our community’s future.

Chapel Lane is attractive and has some fine buildings, particularly around the stream. Any permitted development should not detract from its character.

Objection to Policies GU4 (Wild Meadows) and GU5 (Former Highways Depot), Chapel Lane, Guestling Green - Rother Local Plan 2025-2042

Dear Rother Planning Policy Team,

We, the residents of Guestling Green and the surrounds, strongly object to the proposed allocations under Policies GU4 (Wild Meadows, some 20 dwellings) and GU5 (Former Guestling Highways Depot, some 8 dwellings) in the Draft Local Plan 2025-2042. These greenfield and brownfield sites, both on Chapel Lane, would collectively add 28 new homes to our tiny, historic hamlet in the heart of the High Weald National Landscape. This would cause irreversible harm to our irreplaceable rural character, breach statutory protections, exacerbate practical issues like flooding and traffic, and serve no demonstrated local need. We urge the removal of both sites entirely from the plan, with all growth redirected to less sensitive local urban areas.

Guestling Green is a quintessential Wealden hamlet: a loose cluster of ancient buildings scattered around the Grade I listed St Laurence's Church (dating to the 12th century), with iconic Grade II listed cottages such as The Thatch, Honeysuckle Cottage, and Magnolia Cottage evoking traditional Sussex life. Surrounded by ancient woodlands, irregular medieval fields, thick hedgerows, and panoramic views, it exemplifies the High Weald's outstanding natural beauty designated for the highest level of national protection. The area draws walkers along the 1066 Country Trail and offers profound tranquillity, with dark skies and low pollution levels that support wildlife and residents alike. Our community is predominantly older (Rother has 32.5% over 65s, far above national averages), valuing this peaceful, low-density environment for health, wellbeing, and independence. Introducing 28 homes would suburbanise this precious pocket of rural England, setting a precedent for further sprawl and eroding what makes it special.

These allocations directly breach overriding legal and policy protections. First, Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling-up and Regeneration Act 2023) imposes a statutory duty on Rother District Council to "seek to further" the conservation and enhancement of the High Weald National Landscape's natural beauty, wildlife, and cultural heritage. The 2025 High Court ruling in R (CPRE Kent) V Secretary of State confirms this requires proactive enhancement, not mere mitigation of harm. Yet GU4-a 2.7-acre greenfield site of garden and equestrian paddocks-would fragment medieval field patterns and ancient hedgerows, while GU5 (0.96 acres, a former depot) would introduce dense housing incompatible with the dispersed settlement form. Neither "furthers" protection; they actively undermine it.

Similarly, the High Weald National Landscape Management Plan 2024-2029, adopted by Rother as a material consideration, is violated. Objectives S3 (conserving built heritage and settlement patterns), FH2 (maintaining small, irregular fields bounded by hedgerows and woodlands), and DS1/DS2 (preserving dark skies and minimising light pollution) are all contravened. GU4's development would suburbanise a classic dispersed hamlet, as per the Plan's Parish Information Maps for Guestling, while GU5's infill on a semi-rural site would add visual intrusion. The Plan's Dark Skies Planning Advice Note (2024) highlights the High Weald's rare darkness; new homes mean streetlights, security lighting, and window spill, disrupting nocturnal species like bats and owls, and harming human sleep and wellbeing.

Under the National Planning Policy Framework (NPPF) paragraphs 189-190, "great weight" must be given to conserving landscape and scenic beauty in National Landscapes, with major development refused unless exceptional circumstances exist and it serves the public interest. These sites-treated as "major" in scale for a tiny hamlet-fail this test. No overriding need justifies the harm, especially when Rother's housing targets can be met in less protected areas. The Planning (Listed Buildings and Conservation Areas) Act 1990 further protects the settings of nearby Grade II buildings; both sites adjoin Honeysuckle Cottage, with GU4 also near The Thatch, risking harm to their historic integrity through visual and noise intrusion.

Practical harms are severe and unmitigable, starting with flood risk. GU4's northern and eastern parts are at surface water flood risk, as admitted in the plan and confirmed by Environment Agency maps (low to medium probability, 0.1-3.3% annually). Development on the 1.36-acre built area would increase impermeable surfaces, worsening runoff toward the River Bewl tributary and Chapel Lane. Climate projections (UKCP18) forecast 25-40% more intense rainfall by the 2040s, amplifying risks in East Sussex's clay soils. Sustainable Drainage Systems (SuDS) are required but challenging on a sloped site with high water tables, potentially failing biodiversity net gain under the Environment Act 2021. GU5 has southern runoff issues, compounding cumulative flooding from both sites. This breaches NPPF's sequential test, directing growth to lower-risk zones.

Traffic and infrastructure strain would be intolerable. Chapel Lane is narrow, winding, and hedge-lined-unsuitable for 60 + extra vehicles (assuming 1.5-2 per home). School runs, deliveries, and commuting would create congestion and safety hazards, especially near Guestling Bradshaw CE Primary School, already overpopulated at capacity. New families would drive to alternatives in Ore or Hastings, increasing air pollution (NO₂ and PM2.5) on local lanes. Rother's Sustainability Appraisal acknowledges inevitable pollution rises from development; in our clean-air hamlet, this is unacceptable. Noise pollution from cars, doors, and activity would shatter our profound rural tranquillity, vital for older residents' mental health and reduced isolation.

Pollution extends to light and water. GU4 and GU5 would introduce light spill, ruining the High Weald's dark skies-one of the South East's best for stargazing. Air quality, currently excellent (no Air Quality Management Areas), would deteriorate from traffic, harming respiratory health in our elderly-heavy community. Run off could carry pollutants (oils, chemicals) into streams and ancient woodlands, fragmenting habitats for rare species.

Crucially, there is no local need justifying this. The 2021 Guestling & Pett Housing Needs Survey-commissioned by the parish councils-identified only 11 households parish-wide needing affordable housing, all with strong local ties (family, work, residency). Mostly younger singles or couples seeking 1-2 bed units, this tiny demand has likely reduced through turnover. Parish councils reviewed it in 2023-2024 and confirmed insufficient support for low-cost housing. Yet the plan mandates 40% affordable (about 11 units total), serving district-wide waiting lists and outsiders, altering our owner-occupied, cohesive community without benefiting locals. This ignores Rother's policies prioritising urban growth and fails to meet "local only" exception sites.

The cumulative impact of 28 homes is devastating: overpopulating our quiet hamlet, straining services (no shops, limited buses), harming tourism (our walks and heritage draw visitors), and eroding social cohesion. It sets a precedent for sprawl, undermining the High Weald's uniqueness. Better alternatives exist where infrastructure already exists.

We call for both sites' removal. This consultation (open until March 23, 2026) must heed local voices, as per the Interim Consultation Statement. Failing to protect Guestling Green betrays national duties and our community's future.

Bordering an ancient woodland designated by the Woodland Trust
1066 National Walk (Hastings Branch) runs very close to the proposed area and area is part of AONB
Bus access is on A259 but down a windy single track road with no lighting and no footpath
No train access
No Drs surgery

See supporting letter and Proposed Site Layout for representation on draft allocation GU4, Wild Meadows, Guestling.

We wish to register our objection to the proposed plan to build 28 houses on the Wild Meadows and former Highways Depot sites.

Guestling Green is a unique Wealden hamlet and this unnecessary development will impact the quality of life for all its residents. The additional traffic and infra structure strain will be intolerable. Chapel Lane is a very narrow and winding road which will will suffer greatly if the introduction of approximately sixty plus cars ( 2 per new home) is allowed. This proposal will serve no demonstrated local need.

It must be refused to prevent suburbanisation and protect an irreplaceable protected rural gem.

Objection to Policies GU4 (Wild Meadows) and GU5 (Former Highways Depot), Chapel Lane, Guestling Green
–
Rother Local Plan 2025-2042
Dear Rother Planning Policy Team,
We, the residents of Guestling Green and the surrounds, strongly object to the proposed allocations under Policies GU4 (Wild Meadows, some 20 dwellings) and GU5 (Former Guestling Highways Depot, some 8 dwellings) in the Draft Local Plan 2025–2042. These greenfield and brownfield sites, both on Chapel Lane, would collectively add 28 new homes to our tiny, historic hamlet in the heart of the High Weald National Landscape. This would cause irreversible harm to our irreplaceable rural character, breach statutory protections, exacerbate practical issues like flooding and traffic, and serve no demonstrated local need. We urge the removal of both sites entirely from the plan, with all growth redirected to less sensitive local urban areas.
Guestling Green is a quintessential Wealden hamlet: a loose cluster of ancient buildings scattered around the Grade I listed St Laurence’s Church (dating to the 12th century), with iconic Grade II listed cottages such as The Thatch, Honeysuckle Cottage, and Magnolia Cottage evoking traditional Sussex life. Surrounded by ancient woodlands, irregular medieval fields, thick hedgerows, and panoramic views, it exemplifies the High Weald’s outstanding natural beauty—designated for the highest level of national protection. The area draws walkers along the 1066 Country Trail and offers profound tranquillity, with dark skies and low pollution levels that support wildlife and residents alike. Our community is predominantly older (Rother has 32.5% over 65s, far above national averages), valuing this peaceful, low-density environment for health, wellbeing, and independence. Introducing 28 homes would suburbanise this precious pocket of rural England, setting a precedent for further sprawl and eroding what makes it special.
These allocations directly breach overriding legal and policy protections. First, Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling-up and Regeneration Act 2023) imposes a statutory duty on Rother District Council to “seek to further” the conservation and enhancement of the High Weald National Landscape’s natural beauty, wildlife, and cultural heritage. The 2025 High Court ruling in R (CPRE Kent) v Secretary of State confirms this requires proactive enhancement, not mere mitigation of harm. Yet GU4—a 2.7-acre greenfield site of garden and equestrian paddocks—would fragment medieval field patterns and ancient hedgerows, while GU5 (0.96 acres, a former depot) would introduce dense housing incompatible with the dispersed settlement form. Neither “furthers” protection; they actively undermine it.
Similarly, the High Weald National Landscape Management Plan 2024–2029, adopted by Rother as a material consideration, is violated. Objectives S3 (conserving built heritage and settlement patterns), FH2 (maintaining small, irregular fields bounded by hedgerows and woodlands), and DS1/DS2 (preserving dark skies and minimising light pollution) are all contravened. GU4’s development would suburbanise a classic dispersed hamlet, as per the Plan’s Parish Information Maps for Guestling, while GU5’s infill on a semi-rural site would add visual intrusion. The Plan’s Dark Skies Planning Advice Note (2024) highlights the High Weald’s rare darkness; new homes mean streetlights, security lighting, and window spill, disrupting nocturnal species like bats and owls, and harming human sleep and wellbeing.
Under the National Planning Policy Framework (NPPF) paragraphs 189–190, “great weight” must be given to conserving landscape and scenic beauty in National Landscapes, with major development refused unless exceptional circumstances exist and it serves the public interest. These sites—treated as “major” in scale for a tiny hamlet—fail this test. No overriding need justifies the harm, especially when Rother’s housing targets can be met in less protected areas. The Planning (Listed Buildings and Conservation Areas) Act 1990 further protects the settings of nearby Grade II buildings; both sites adjoin Honeysuckle Cottage, with GU4 also near The Thatch, risking harm to their historic integrity through visual and noise intrusion.
Practical harms are severe and unmitigable, starting with flood risk. GU4’s northern and eastern parts are at surface water flood risk, as admitted in the plan and confirmed by Environment Agency maps (low to medium probability, 0.1–3.3% annually). Development on the 1.36-acre built area would increase impermeable surfaces, worsening runoff toward the River Bewl tributary and Chapel Lane. Climate projections (UKCP18) forecast 25–40% more intense rainfall by the 2040s, amplifying risks in East Sussex’s clay soils. Sustainable Drainage Systems (SuDS) are required but challenging on a sloped site with high water tables, potentially failing biodiversity net gain under the Environment Act 2021. GU5 has southern runoff issues, compounding cumulative flooding from both sites. This breaches the NPPF’s sequential test, directing growth to lower-risk zones.
Traffic and infrastructure strain would be intolerable. Chapel Lane is narrow, winding, and hedge-lined—unsuitable for 60+ extra vehicles (assuming 1.5–2 per home). School runs, deliveries, and commuting would create congestion and safety hazards, especially near Guestling Bradshaw CE Primary School, already overpopulated at capacity. New families would drive to alternatives in Ore or Hastings, increasing air pollution (NO₂ and PM2.5) on local lanes. Rother’s Sustainability Appraisal acknowledges inevitable pollution rises from development; in our clean-air hamlet, this is unacceptable. Noise pollution from cars, doors, and activity would shatter our profound rural tranquillity, vital for older residents’ mental health and reduced isolation.
Pollution extends to light and water. GU4 and GU5 would introduce light spill, ruining the High Weald’s dark skies—one of the South East’s best for stargazing. Air quality, currently excellent (no Air Quality Management Areas), would deteriorate from traffic, harming respiratory health in our elderly-heavy community. Runoff could carry pollutants (oils, chemicals) into streams and ancient woodlands, fragmenting habitats for rare species.
Crucially, there is no local need justifying this. The 2021 Guestling & Pett Housing Needs Survey—commissioned by the parish councils—identified only 11 households parish-wide needing affordable housing, all with strong local ties (family, work, residency). Mostly younger singles or couples seeking 1–2 bed units, this tiny demand has likely reduced through turnover. Parish councils reviewed it in 2023–2024 and confirmed insufficient support for low-cost housing. Yet the plan mandates 40% affordable (about 11 units total), serving district-wide waiting lists and outsiders, altering our owner-occupied, cohesive community without benefiting locals. This ignores Rother’s policies prioritising urban growth and fails to meet “local only” exception sites.
The cumulative impact of 28 homes is devastating: overpopulating our quiet hamlet, straining services (no shops, limited buses), harming tourism (our walks and heritage draw visitors), and eroding social cohesion. It sets a precedent for sprawl, undermining the High Weald’s uniqueness. Better alternatives exist where infrastructure already exists.
We call for both sites’ removal. This consultation (open until March 23, 2026) must heed local voices, as per the Interim Consultation Statement. Failing to protect Guestling Green betrays national duties and our community’s future.

Draft Rother Local Plan (Regulation 18) - National Highways' response

Thank you for your email of 26 January 2026 consulting National Highways on the draft Rother Local Plan 2025-2042 - Development Strategy and Site Allocations (the draft Plan).

We are concerned about the safety, reliability, and operational efficiency of the Strategic Road Network (SRN). In the case of Rother district, the SRN comprises the A259 and the A21.

We have read the consultation document and understand that the focus is on the proposed site allocations. We have also read the Local Development Scheme (LDS) (March 2025) which maps out the timetable for the production of the Local Plan.

We have set out below our comments.

SRN policy context - vision-led approach:
We would like to draw your attention to the Department for Transport (DfT) Circular 01/2022: Strategic road network and the delivery of sustainable development (December 2022) which represents the government's policy for the SRN.

Plan-making needs to respond to the expectations of this policy including a vision-led approach to development. The objective of vision-led development is to manage down traffic impacts by maximising opportunities for sustainable travel and by internalising movements as far as possible through layout and design. There is also a specific section in the Circular on 'Engagement with plan-making'.

The vision-led approach to development now features in the updated National Planning Policy Framework (NPPF) (December 2024) - please see section 9. The updated NPPF also includes a requirement for Local Plans to look ahead over a minimum 15-year period from adoption. It is important to highlight this at this early stage because the time horizon for the Local Plan is relevant to the evidence that needs to be prepared to inform plan-making.

A key part of the vision-led approach, where appropriate, is monitor and manage. This is an important strategy for overseeing the appropriateness and phasing of identified highway mitigation to support the delivery of large developments. This would need to be informed by an Infrastructure Delivery Plan that should be kept live by regular monitoring during the implementation of the development strategy for the Local Plan.

We are happy to work with you on the development of appropriate policies that address the vision-led approach and monitor and manage.

Rother Local Plan 2025-2042 - Development Strategy and Site Allocations Draft (Regulation 18) Version, January 2026:
The draft Local Plan sets out proposed site allocations across the district along with some area specific policies.

We understand that 'Additional technical evidence will be prepared to ensure the potential impacts (including cumulative impacts) of the level of growth planned in Rother is appropriately considered, as well as to ensure new development is suitably located and can be adequately supported by infrastructure, and is viable, in line with national policy and guidance.'

We would encourage Rother District Council (RDC) to continue to engage with us in respect of the transport modelling and assessments in order to ensure that the approach is consistent with the guidance set out in DfT Circular 01/2022.

Furthermore, we suggest that the Local Plan considers cumulative impacts of development in neighbouring authorities. This is in line with DfT Circular 01/2022 paragraph 29 and the NPPF on strategic cross-boundary matters.

Infrastructure Needs:
We note that an updated Draft Infrastructure Delivery Plan (IDP) has been prepared in support of this Regulation 18 consultation and our comments on this document are detailed within a later section of this letter.

However, it is also important to note that we understand the draft IDP will require further revisions once the updated strategic transport modelling using the countywide model is complete. As such, the infrastructure needed to support the delivery of the Local Plan cannot be fully identified until this work is complete.

Development Strategy:
We note that following the first Regulation 18 consultation, several additional options for the development strategy have been identified, these included the 'A21 Corridor Option'.

We note that this option would have the most direct implications for the SRN. This option provides for development along the A21 trunk road within an identified corridor of settlements, together with a sustainable transport corridor (including improved sustainable travel options such as bus routes, cycling and walking infrastructure).

We would highlight that any proposed changes/improvements to any part of the SRN will require consultation with and approval from us.

Furthermore, the full impact of this option is required to be assessed as part of the updated modelling, to be undertaken in compliance with the guidance set out in DfT Circular 01/2022.

We strongly advise that RDC continue to engage with us regarding the updated modelling and preparation of the associated transport evidence base documents to ensure that any potential impacts on the SRN are appropriately assessed.

Development Strategy for Rother:
It is noted that Bexhill will be the key focus for sustainable residential and commercial growth with potential to deliver circa 4,764 dwellings and 54,672 sqm. of employment.

It is evident that the proposed development strategy will place additional strain on the SRN in this area and this will need to be fully assessed through the updated modelling work being undertaken to support the draft Local Plan.

RDC must consider Circular 01/2022 paragraph 29:
"there cannot be any presumption that such infrastructure will be funded through a future RIS [Road Investment Strategy]. The company will therefore work with local authorities in their strategic policy-making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy."

The draft Local Plan notes there are 'opportunities for sensitive development in the sub-area during the timeframe of the Local Plan, where sustainable and related to an existing settlement, including those alongside the A21. Longer term (beyond the timeframe of the new Local Plan), the delivery of significant improvements to create a sustainable transport corridor could open up opportunities for future development along the A21 corridor, which could be addressed in a plan review.'

RDC states that there is potential to deliver 996 dwellings and 4,350 sqm of employment floorspace across the Northern Rother sub-area.

Paragraph 6.85 of the draft Local Plan states:

'The A21 provides road connections between the villages north and south. In the long- term, the A21 could become a sustainable travel corridor with buses given priority, linked to walking, cycling and wheeling routes. The Transport for the South-East (TfSE) Strategic Investment Plan identifies bypasses on the A21 at Flimwell and Hurst Green as necessary transport interventions to decarbonise transport in the south-east by 2050. However, these are not currently funded and there is a lack of evidence they will come forward at any point, including during the timescale of the Local Plan.'

Introducing a sustainable travel corridor along the A21 aligns with DfT Circular 01/2022 policy by encouraging walking, wheeling, cycling and public transport use as the natural first choice. However, we would again reiterate that the need for any SRN mitigation must be considered after all options have been assessed to maximise the accessibility by sustainable transport modes. There cannot be any presumption that SRN-related infrastructure to mitigate Local Plan impacts will be funded through a future government's Road Investment Strategy (RIS). Funding and delivery of necessary SRN infrastructure to support planned growth is a matter for the Local Planning Authority (LPA) to lead on through the Local Plan process.

Furthermore, it is also important to note that while RIS3 has yet to be published, the interim statement (2025/2026) highlights that RIS3 will be focused on maintenance and renewal (para.4.3):

'While RIS3 has yet to be agreed, it is likely that investment will be increasingly focussed on maintaining and renewing the existing Strategic Road Network, including replacing and renewing major bridges, viaducts and other structures.'

Site Allocations:
We note that there are circa 162 site allocation policies (some are area specific and can also encompass more than one site).

Our review has sought to identify immediately apparent site-specific matters of interest to us, which are:
- Sites which would require a new access onto the SRN (this includes sites that do not abut the SRN but would require a new access onto the SRN as part of their wider transport strategy)
- Sites which propose to use an existing SRN access Sites which abut the SRN but would take access onto the Local Road Network
- Sites located near the SRN.

Sites requiring a new access onto SRN All sites seeking a new access onto the SRN must demonstrate evidence of: Policy compliance regarding new accesses on the SRN as per DfT Circular 01/2022, in particular paragraphs 18 to 25 Design Manual for Roads and Bridges (DMRB) compliance and Stage 1 Road Safety Audit (RSA), Walking, Cycling and Horse-riding Assessment and Review (WCHAR) etc.

In relation to policy compliance, we would highlight paragraph 19 of the Circular (our emphasis):

"19. On this basis the principle of creating new connections on the SRN should be identified at the plan-making stage in circumstances where an assessment of the potential impacts on the SRN can be considered alongside whether such new infrastructure is essential for the delivery of strategic growth. Moreover, the company will need to be satisfied that all reasonable options to deliver modal shift, promote walking, wheeling and cycling, public transport and shared travel to assist in reducing car dependency, and locate development in areas of high accessibility by sustainable transport modes (or areas that can be made more accessible) have been exhausted before considering options for new connections to the SRN. There may also be limited opportunity for new connections to be considered as part of public funding programmes to support new development, although necessary infrastructure in up- to-date plans and strategies should be favoured in such instances."

We would therefore expect an appropriate assessment to be undertaken and included - either within the Local Plan transport evidence or as part of the explanation of the development strategy - demonstrating how this has been addressed through plan-making by RDC. It may be the case that it can be drawn from other existing sources that form part of the Local Plan evidence base.

It is important that RDC demonstrates that they have followed this process as any new connections on the SRN can create additional risk to safety and reduce the reliability and efficiency of journeys.

In respect of these sites, it is also strongly advised that individual site-specific advice be sought from us as soon as possible.

Sites proposing to utilise an existing SRN access:
All sites which propose to utilise an existing SRN access will need to fully assess any impacts arising from the proposed development traffic.

It is important to note that we would not support the intensification of use of an existing SRN access where there would be a detrimental impact on safety.

Any proposed upgrade/improvement of an existing SRN access would need to be fully assessed in line with the relevant guidance set out in DfT Circular 01/2022 and DMRB.

For all sites where SRN access is critical to the deliverability of the development, the required assessments should be undertaken as soon as possible, in advance of the Regulation 19 submission.

Sites which abut the SRN:
All sites which abut the SRN will need to consider any boundary issues, eg drainage, lighting, geotechnical, boundary treatments, in consultation with us.

Sites near the SRN:
For sites located near to the SRN, it will be particularly important that they are supported by an appropriate Transport Assessment at the planning application stage and are advised to seek early engagement with us at the pre-application stage. However, this does not preclude the need for Transport Assessments for sites which are located further away which are of a development quantum which could have a material traffic impact on the SRN.

We note that the cumulative traffic impact of all proposed site allocations is to be assessed as part of the updated modelling based on the East Sussex Countywide model.

Evidence-base: Strategic transport modelling It is important that plan-making is informed by proportionate up-to-date evidence.

In respect of transport, we expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Rother District, with our focus being on the SRN. We note that the transport evidence which has been published as part of the
current consultation dates from 2023 and therefore is not able to specifically consider the impacts of the specific sites identified in the main Regulation 18 consultation document.

We understand that the intention is to utilise the East Sussex Countywide Transport Model (ESCWTM/ 'countywide model') in advance of subsequent consultation stages to 'underpin and develop a detailed Shared Transport Evidence Base'.

This needs to set out current and future baseline (end of plan period + extant permissions) information on the performance of junctions across the highway networks. We understand that this will be informed by updated transport modelling using the Countywide strategic model.

Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the site selection process and needs to be produced in advance of the detailed Regulation 19 Local Plan to inform its preparation.

We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues at East Sussex County Council who are responsible for the Local Road Network (LRN).

Once established, the strategic transport model can then be used to test development strategy options being considered by the council for the Local Plan.

Evidence base: Infrastructure Delivery Plan (IDP) January 2026. The IDP is a useful piece of evidence to identify what, where and when in terms of the infrastructure needed to support the development strategy in the Local Plan. It can identify schemes, estimated costs, and when the mitigation will be phased alongside the build-out of the development strategy.

We have reviewed the IDP Part A and Part B (The Schedule) and would note the following points:

Strategic Corridor Improvements The A21 and A259 corridors have been identified as requiring capacity management and selective enhancements to accommodate forecast growth. The IDP confirms that any improvements along this corridor should be aligned with National Highways' RIS3 (2026 - 2031), and the LTP4 Investment Plan priorities. We would note that RIS3 is yet to be published, however, the outlined approach would be acceptable in principle. It is important to appreciate that the focus of RIS3 will be on maintenance and renewal; there is uncertainty about the future of RIS3 pipeline projects identified in RIS2. The current position on the A21 Safety Package scheme is available from our website: https://nationalhighways.co.uk/our-roads/south-east/a21-safety-package/

Integration with multi-modal travel: We welcome the statement in Paragraph 3.40 of the IDP which outlines that road interventions must support sustainable travel choices, with new and upgraded infrastructure planning alongside priority measures, cycle lanes, and pedestrian infrastructure. Such improvements should be designed in accordance with appropriate DMRB standards with any proposals submitted to us for approval.

Phased delivery and prioritisation: We agree that road network improvements should be phased in line with housing and employment delivery to ensure new capacity and infrastructure is in place at the right time as development comes forward.

Financial & delivery requirements: It should be noted that any improvement schemes on the SRN would be expected to be delivered via a s.278 (Highways Act 1980) agreement between the developer and National Highways. We do not accept developer contributions, with priorities for the SRN set in the government's RIS.

It is also important to note that RIS3 has yet to be published and as such there should be no reliance on any schemes that may be included within it. As highlighted above, there is uncertainty about RIS3 pipeline projects identified in RIS2.

We would also highlight paragraph 29 of DfT Circular 01/2022 (our emphasis):

'New connections and capacity enhancements to the SRN which are necessary to deliver strategic growth should be identified as part of the plan-making process, as this provides the best opportunity to consider the cumulative impacts of development (including planned growth in adjoining authorities) and to identify appropriate mechanisms for the delivery of strategic highway infrastructure. However, there cannot be any presumption that such infrastructure will be funded through a future RIS. The company will therefore work with local authorities in their strategic policy- making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy.'

We welcome the reference to the 'vision and validate' approach (also known as 'monitor and manage') in Paragraph 10.9 of the IDP.

We consider that it could be beneficial to discuss the suitability of a 'Monitor and Manage' approach for individual proposed developments on a case-by-case basis at the appropriate time during the planning process, as part of a collaborative approach involving us, the LPA, developers and ESCC.

The IDP Part B (the Schedule) lists a number of schemes which directly impact the SRN.

We note that we have been identified as a 'Delivery Partner' for some of these schemes. As previously noted, Paragraph 10.21 of the IDP states that a 'Delivery Partner' is defined as: 'any strategic stakeholder (public or private) involved in the planning, design, technical approval, or funding of infrastructure; they are not necessarily the body that directly delivers the infrastructure itself.'

Based on RDC's definition, we would be a 'Delivery Partner' for all schemes on the SRN as technical approval from us would be required. Any proposed changes to the layout or operation of the SRN will need to be approved by us, with the changes designed in accordance with appropriate DMRB standards and assessed in compliance with DfT Circular 01/2022.

For the avoidance of doubt, unless otherwise specified by us, any identified SRN schemes necessary to support planned growth will not be funded or delivered by National Highways.

With regard to the Schedule itself, it would be useful to have additional information presented in relation to the presented schemes, where applicable, particularly for those classified as critical or essential:

Scheme drawing number reference LPA planning application reference(s) if scheme is linked/conditioned to development(s) Any identified trigger points (development thresholds) at which scheme is required.

We have not undertaken a detailed review of all SRN schemes included within the Schedule as we understand that the transport modelling evidence for the draft Local Plan, based on the latest site allocations, may result in changes to infrastructure requirements. As such, we anticipate that there will need to be a further update to the IDP once the modelling is completed. We have no further comments at this stage.

National Highways will need to participate in discussions involving East Sussex County Council (ESCC) and RDC, to ensure that the agreed modelling scope, specifications, and assumptions are appropriate and proportionate to the needs of the emerging Local Plan.

The IDP is a useful piece of evidence for documenting the outputs from the monitor and manage strategy which needs to form part of the implementation of the Plan. It would benefit from a chart plotting the phasing of essential transport infrastructure alongside the build-out of the development strategy to ensure identified mitigation is delivered at the right time in the development cycle. We are happy to be engaged with the development of further updates to the IDP and the monitor and manage strategy.

Expectation management: We must be clear that the funding and delivery of mitigation to the SRN that is necessary to support the development strategy in the Local Plan are matters for the LPA to decide and manage through the Local Plan process, including during its implementation.

Priorities for investment in the SRN are set in the government's Road Investment Strategy (RIS). There cannot be a presumption that improvements to the SRN necessary to support planned growth in the Local Plan will be funded and supported through a future RIS. RIS3 (2026-2031) will be focused on maintenance and renewal.

We are happy to be engaged in the process of assessing proposed mitigation, e.g. safety and design standards, but will not be responsible for funding or delivery.

Keep informed: We hope these comments are clear and helpful. We are happy to work with Rother District Council on an on-going basis as the Local Plan, including the evidence base, progresses.

Please keep us informed about the development of transport related evidence and the next stage of the Draft Rother Local Plan.

We would also like to share with you our 'Planning for the future - A guide to working with National Highways on planning matters' (October 2023), which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.

We have also prepared a short explainer video outlining how we engage with planning. This video is available from our website under the heading 'Our support for plan-making and decision-taking': https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road- network-in-england/. In addition, we have prepared a Local Plan brochure outlining how we engage with plan-making which is available from the same section of our website.

Should you or any others have any queries regarding our response, please contact us.