Relating to IK1 - I strongly object to this development. It's an ANOB. There is no shop in the village. The school does not have anymore capacity. There is considerable daily noise from Icklesham Joinery. I would concerned about having another road joining the A259, traffic is very fast along this straight section, motorbikes especially. We have always been under the impression there was a church covenant on this side of the road and no building was permitted.

IK1: 1.Land is protected by a church covenant. 2. It is with an AONB. 3. The local primary is full to capacity. 4.There is NO village shop. 5. A public footpath runs across the proposed site. 6.Water services for 5 x houses to the south run under the proposed site. 7. Effective sound-proofing of the adjoining joinery next door would need to be carried out. 8. It will create further motor and pedestrian traffic on an already busy A259. 9.There is NO pavement on the south side so EVERY RESIDENT would need to cross over this trunk road, subsequently the 40 mph speed limit would need to be reduced to 30 to avoid fatalities as there is speeding throughout the day and night, and sadly each year drivers and bikers have fatal accidents on that stretch. 10. Road calming measures should be put in place due to the extra 26 homes.

There is already a large number of families in the village. If you go ahead with IK1 and IK2 that is potentially another 60-70 families also joining the village. This is going to put significant pressure on the local icklesham primary school, who are already heavily oversubscribed. There is also not enough general infrastructure locally to support this many extra families. There is only 1 bus per hours. There are almost no activities locally for our children. Only one play area, one youth club. The only football clubs, etc are for the older age groups, nothing considered for the younger children. There has been no further money injected into the village in years. No new play areas, not enough rubbish and dog faeces bins for the residents we already have. There have already been issues with antisocial behaviour from some of the residents in Orchard Close, icklesham (the most recent new build development here), which has definitely affected local long-term residents. Not to mention the issues with siting and appearance of the proposed site. It is greenbelt land and should remain that way to protect the local wildlife and conservation of the surrounding area.

I submit this representation to formally object to Policy IK2 of the Draft Rother Local Plan (2025–2042, Regulation 18). The proposed allocation for 32 dwellings on Greenfield land at Land adjacent to Orchard Close is unsound, unjustified, and undeliverable in its current form.
The policy proposes vehicular access via Orchard Close, which is not feasible due to legal access rights, existing soakaway infrastructure, and safety concerns. The allocation is not deliverable.
The southern part of the site is subject to surface water flood risk. No Sequential or Exception Test evidence has been provided, contrary to NPPF requirements.
The site lies within a nationally protected landscape. No landscape sensitivity assessment has been provided to justify the allocation and orchard close was a Rural exception site with constraints put in place that nothing else could be built around on the surrounding land , even if these constraints were not in place these plans exceeds the maximum 15 homes permitted
The site borders Deciduous Woodland and Traditional Orchard Priority Habitats and supports multiple protected species. The policy does not demonstrate that 10% Biodiversity Net Gain is achievable, and bat boxes were installed on the homes of Orchard Close meaning any homes built will be affecting the flight path and noise Frequencies from plant machinery and tools will be affecting the roosting bats which are protected by law
Sewer capacity, pedestrian infrastructure, and A259 access constraints are unresolved As inadequate bus route as these buses are always cancelled no infrastructure in the village i.e no shops or post office, no doctors surgery, school is over capacity and wait list in please even for Current residents of the parish, the closest sewer connection is broad Street where there was already complaints of pollutions flRural exception site with constraints put in place that nothing else could be built around on the ooding a customer’s house due to being overwhelmed

Development would significantly harm the tranquility, privacy, and wellbeing for residents of Orchard Close, plans are to go through a private estate, which will pose a risk to the children as traffic will increase an minimum 150% , damage to the underground a soak away on the estate and over flow pipe that runs the middle of the land that proposed to be built on
Policy IK2 should be removed from the Local Plan as it doesn’t meet the requirements and proposing S106 agreements will not be sufficient as multiple S106 agreements were not upheld when Orchard Close was built

I submit this representation to formally object to Policy IK2 of the Draft Rother Local Plan (2025–2042, Regulation 18). I object to the proposed allocation of 32 dwellings on Greenfield land adjacent to Orchard Close because it is unsound, unjustified, and undeliverable.
The policy proposes vehicular access through Orchard Close, which is not feasible due to legal access restrictions, essential soakaway and drainage infrastructure, and significant safety concerns. This makes the allocation undeliverable. The southern part of the site also lies within an area of surface water flood risk, and no Sequential or Exception Test has been provided, contrary to NPPF requirements.
The land lies within a nationally protected landscape, yet no landscape sensitivity assessment has been produced. Orchard Close was built as a Rural Exception Site with clear constraints preventing further surrounding development, and the proposal exceeds the recognised maximum of 15 homes for such schemes.
The site borders Deciduous Woodland and Traditional Orchard Priority Habitats and supports protected species. There is no evidence that 10% Biodiversity Net Gain can be delivered. Bat boxes installed on existing Orchard Close homes show established bat roosts and flight paths that would be directly affected by construction works, noise, lighting, and machinery, breaching wildlife protection law.
Significant infrastructure issues remain unresolved, including limited sewer capacity—Broad Street has already experienced pollution and flooding—poor pedestrian links, an unreliable bus service, and insufficient village facilities. There are no shops, no post office, and no doctor’s surgery. The local school is already over capacity with a waiting list for current residents.
The proposed development would also harm the tranquillity, privacy, and wellbeing of Orchard Close residents. Routing construction and residential traffic through a private estate would severely increase vehicle movements, pose risks to children, and jeopardise the integrity of the estate’s underground soakaway and overflow system.
Considering these issues, alongside previous Section 106 obligations for Orchard Close that were not upheld, I strongly object to Policy IK2. For these reasons, I request that this policy be removed from the Local Plan.

I object to this as the school is already overscribed and would not cope, no medical facilities or infrastructure to support additional housing and its needs. Poor drainage. Destruction of green belt land. Would destroy wildlife and plant life. Ruin current residents. Be detrimental to village life and social cohesion. Road ways infrastructure is lacking. Sewage and mains utilities not able to cope. I am extremely against this and the impact the works would have on the local community.

I do not believe option IK1 should be granted as this sets a precedent for building on this side of the road.
IK2 is just an addition to what has already been approved and should be granted.

Greenfield land should be protected in AONB. 58 new homes would lead to more light pollution, bring 100 plus more cars to the village and impact wildlife. No infrastructure to support more housing - no shops, doctors and the school is oversubscribed. Drainage & sewage already struggling.

IK1 and IK2. We are designated as an area of outstanding natural beauty. Light pollution, more traffic, and damage to wild life. I object to any more building in the Village of Icklesham.

I object to both developments in Icklesham as we are in an area of AONB. The A259 is already a busy road without adding to it. This area is seasonally under pressure from tourism. Without more reservoirs in place, as residents we will be more deprived of basic facilities. Hose pipe bans each summer as an example. Without a village shop, everyone travels out for essentials, more building puts more pressure on an already busy road. The local school is full, there are no more doctors or dentists and the local hospital has had most of its services transferred to Eastbourne. The last thing needed is more people.

I apologise to all parties for this objection which is made on protected wildlife grounds.
I object to both IK 1 and IK 2 proposed developments due to the presence of Great Crested Newts which are strictly protected under UK and European law (Conservation of Habitats and Species Regulations 2017 and the Wildlife and Countryside Act 1981). These Acts make it an offence to kill, injure, capture, disturb or possess Great Crested Newts, or damage their breeding sites and habitats.
There currently exists a healthy breeding population of Great Crested Newts in the garden pond of Fieldings which is the property east of ICK2 and north of ICK 1, shown on the plans. Great Crested Newts breed in ponds in the spring and typically range 250-500m terrestrially throughout the remainder of the year; this is considered as a ‘Protection Zone’ and falls well within the proposed developments.

IK1
We object to the proposed allocation on the basis that development to the south of the village has consistently been opposed by the local community through previous consultations and planning processes. This longstanding position reflects established community concerns regarding the suitability of expansion in this location, including its impact on the character, setting, and spatial form of the village.

IK2
Access and Drainage: The proposed sites present potential issues with the access road and the effectiveness of soakaway drainage systems. These matters could lead to safety risks and exacerbate surface water management challenges in the area.

Overdevelopment and Infrastructure Pressure: The scale and density of both developments are considered excessive relative to the village’s existing infrastructure. In particular, drainage capacity and other local services are unlikely to accommodate such additional pressure without substantial and potentially unsustainable upgrades.

Development Beyond Established Boundaries: Both sites lie outside the current defined development boundary. Allocating these sites could set a precedent, potentially encouraging further development beyond the village boundary.

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.

Objection to Proposed Development of 26 Dwellings on Site IK1 – High Weald National Landscape

I live near the IK1 site on the north side of Main Road. I wish to object to this development for the reasons outlined below.

1. Unsuitable Ground Conditions-
The field regularly becomes saturated and extremely muddy during the winter months, suggesting high groundwater levels. These conditions raise substantial concerns about the viability and long‑term stability of any residential development on this land.

2. Harm to the High Weald National Landscape-
The site lies within the High Weald National Landscape (formerly AONB), a protected area designated for its historic, natural and scenic qualities. This land contributes directly to the area’s rural character, and development of this scale would diminish the qualities the designation is intended to safeguard.

3. Loss of Publicly Enjoyed Open Space-
For many years, this land has been used informally by residents for daily dog‑walking and as a natural play space for local children. Its loss would remove a valued area of informal recreation that contributes to local wellbeing and community life.

4. Impact on Biodiversity and Ecological Networks-
The site contains several mature habitats: species‑rich hedgerow, wildflower meadow, scrubland and a ditch that supports wildlife year‑round. Species observed include deer, bats, swifts, buzzards, marsh harriers and the birds‑foot trefoil flower. The proposed development would destroy or severely fragment these habitats and break a significant biodiversity corridor along Main Road.

5. Unacceptable Loss of Privacy and Residential Amenity-
Properties positioned on this plot would rise above the existing hedgeline (as seen in the existing new development towards Guestling end of the village) and overlook our home directly. This would lead to a serious loss of privacy in our bedroom and living areas, as well as obstructing our long‑enjoyed views across the open countryside.

6. Incompatibility with Existing Settlement Pattern-
The village has historically developed along the north side of Main Road, forming a clear boundary with the countryside and helping retain its rural setting. The proposed density of 26 dwellings is inconsistent with surrounding development and would push the village westwards, weakening its established structure and character.

7. Pedestrian Safety Issues-
There is no footway on the development side of Main Road. Although a pavement exists on the opposite side, the road is fast, prone to speeding, and situated on a bend with restricted visibility. Crossing is already difficult and hazardous and would become even more unsafe with increased pedestrian movement from a new estate.

8. Noise Concerns from Adjacent Timber Yard-
Icklesham Joinery, which adjoins the site, generates significant operational noise. Introducing housing directly beside this long‑standing business risks future noise complaints and potential operational conflicts.

9. Light Pollution and Loss of Dark Skies-
The village currently benefits from dark skies due to the absence of street lighting. A development of this scale is likely to require internal road lighting and extensive exterior illumination, resulting in substantial light pollution and loss of the clear night skies enjoyed by residents.

10. Erosion of Countryside Character-
The land’s semi‑wild appearance—having naturally regenerated over many years—adds to the area’s rural charm and sense of openness. It is bordered by nature on several sides, with Guestling Woods nearby. Development would permanently alter this landscape and remove an important rural buffer.

For all these reasons, I strongly object to the proposed development of site IK1. Thank you for considering my representation.

I'm a resident living near the IK1 proposed development site, on the north side of Main Road. I wish to object to the proposed IK1 and IK2 site on the following grounds:

Objection to IK1:
- Enjoyment of home: a development on the site would screen my view of the countryside from south facing windows
- Removal of countryside: The site is very clearly part of the countryside and has beautiful landscape character. Having not been used for farming in many years it has become quite wild and varied, with connection to nature on three sides and Guestling Woods a short distance away
- Impact to nature: The site features several mature habitats including species rich hedgerow, wildflower meadow, scrubland and ditch. It is home to a great number of notable species including deer, swifts, marsh harriers, buzzards, bats and birds foot trefoil flower. The development would remove or severely degrade these habitats, and indoingso sever a long biodiversity hedgerow corridor along the south side of Main Road
- Loss of public amenity: At least 10 local residents (including myself) enjoy walking their dogs here each day - a well-loved local amenity would be removed were the development to go ahead
- Lack of pedestrian connectivity: The site is unsuitable for large development as it has no adjacent footway. Though there is a footway on the north side of Main Road, it is an extremely fast road (often with speeding vehicles) on a bend with limited visibility. Crossing the road here is very difficult and dangerous
- Lack of respect to local built environment character: The village is predominantly arranged along the north side of the Main Road, effectively forming a barrier to development, allowing all residents a fantastic closeness to the countryside and preventing sprawling of development into the countryside. The proposed dwelling numbers are of an excessive density not seen elsewhere in the village. Development at the west end of the village would further decentralise the village centre, making the built fabric of the village even less coherent
- Unsuitable ground conditions: The field becomes extremely muddy each winter due to the high groundwater and would be unsuitable for development
- Noise from adjoining timber yard: The neighbouring Icklesham Joinery generates a lot of noise and could cause a nuisance to new residents
- Impairment of dark skies: the village enjoys fantastic views of the night sky, due mainly to the lack of street lighting. The new development (of a density likely to need its own site road) would make a substantial contribution to light pollution

Objection to IK2:
I also object to site IK2 for the following reasons:
- It further disrupts the character of the village
- The density of dwellings suggested is completely unsuitable
- It will impact neighbouring homes and their enjoyment of their homes and gardens
- It will be highly visible on the ridge from across the valley, and degrade an otherwise beautiful view of the countryside
- Site IK2 is part of the countryside - i do not support further loss of countryside

For these reasons i am objecting to both development sites IK1 and IK2. Thankyou for your consideration

Ive lived in icklesham for many years . This would destroy the village

We strongly object to both of these sites being used for Development ,for the following reasons .
Both are in the HWNL which is subject to the highest level of Landscape protection.
This area is full of protected species.
I have already sent the LPA confirmation of exactly where both these species are .LPA have it on record for IK2 especially .
I have already noted that High Hedges are not a solution to Landscape protection from Development as they are only a temporary solution .
IK2 is particularly bad because of its proximity to the back gardens of properties along Main RD .The amenity and Countryside character of these properties will be damaged .The openness of the Landscape of the HWNL is of utmost priority. Please check the material history for applications down Broad St especially recent Appeal decisions.

The proposed development threatens to permanently change the character and future of our small village. What is currently a peaceful, close-knit rural community would be replaced by increased traffic, noise, and pressure on local infrastructure that was never designed to support such expansion. The scale of the development is completely out of proportion with the size and nature of the village, risking the loss of its historic identity and tranquil environment.
Our village is not a location on a map; it is a community shaped by generations of residents, local traditions, and the surrounding countryside. The fields, green spaces, and views that define the village landscape are an essential part of its heritage and wellbeing.
In addition to environmental damage and loss of countryside, the development would place significant strain on already limited services, including roads, schools, healthcare access, and drainage systems. Such pressure would fundamentally alter daily life for current residents and erode the qualities that make this village a special place to live.

The proposed development would significantly harm the character of our small village and the wellbeing of the people who live here. The scale of the project is far greater than the village can reasonably support, placing pressure on already limited roads, services, and infrastructure. For local residents, this would mean increased traffic, noise, and disruption to everyday life. A large influx of new housing would also quickly change the close-knit nature of the community, making it difficult to maintain the village’s identity and way of life. Overall, the development risks overwhelming the village and negatively affecting the people who have long called it home.

The village can not support extra housing, the drainage is diabolical, especially up towards Orchard Close,
If housing start going up on the south side of the A259, it will open up the flood gates, as many people are waiting to build on their land that side.
The local primary school, cannot accommodate for the extra pupils.

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.

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

See attached.

IK1
This site has a Public footpath running through it.
It is probably one of the wettest fields in Icklesham.
There is no infrastructure: if these proposed houses have children, where they go to school? Icklesham, Winchelsea and Guestling are all full.
Where will the drainage go?
The Village doesn’t have a shop.
Our water suppliers inform us there is a water shortage, the proposed houses will require a water supply.
Building a local reservoir would be much more beneficial to us all, that live in Rother.

IK2
Where will the proposed drainage go?

I object to both IK1 and IK2 for the following reasons:
Both sites would attract families with primary school aged children, Icklesham school is small and full to capacity. The only public transport that serves the village is an hourly bus service to either Rye or Hastings, which cannot be relied on to arrive on time. There are very few amenities in Icklesham, no shop, post office, doctors surgery etc.
The sites proposed are both in an AONB area.

I object to both proposed developments IK1 & IK2 in the village of Icklesham. Both sites are in an area of AONB and on greenfield land which should remain so to protect wildlife. Brown field sites should be utilised before considering ruining the beautiful countryside. The infrastructure is insufficient to support these developments, especially sewage and drainage. The village school is near to its capacity. Employment opportunities are very limit in the immediate area.

I strongly object to IK1 & IK2 proposals for reasons already pointed out by others ie no shop, school has no capacity, no local jobs, sites are too far from recreation ground & village hall, few facilities for children, impact on wildlife, AONB, light pollution, poor infrastructure and the list goes on!
The amount of new houses proposed by the government is ridiculous, they should consider schemes to enable derelict buildings to be renovated/rebuilt, compulsory purchase if necessary to bring these eyesores back to life and provide homes for families. More could be done to help people get on the property ladder and provide smaller first time buyers dwellings rather than 4 bedroom properties of which there are many standing empty and some unfinished as they are unaffordable.
Please use brownfield sites rather than destroy more of our beautiful countryside, our villages should be protected from over development.

We strongly support the inclusion of IK1 within the Plan. The landscape based assessment submitted with the call-for-sites demonstrates that this site has a lower sensitivity and high capacity for housing development. There is already development to the south of the A259 and public transport links directly outside of the site. With only two sites promoted for housing within Icklesham, and this being a significant settlement within the Hastings Fringe, it is important that the site is developed to as high a density as the site specific analysis demonstrates is feasible at the planning application stage. The site is currently deliverable and developable in the immediate 1-5 year period. We recommend a higher density of development on the site and welcome its inclusion as a site allocation in the plan.

My name is [personal details redacted] and i’m a resident living adjacent to and overlooking the IK1 proposed development site, on the north side of Main Road. I wish to object to the proposed IK1 site on the following grounds:

- Enjoyment of home: a development on the site would significantly impact the view from the front of my house by removing open countryside. The site is part of the countryside and connected to many public footpaths and open spaces which are important in this rural setting, it is has beautiful landscape character. Having not been used for farming in many years it has become quite wild and varied, with connection to nature on three sides and Guestling Woods a short distance away
- Impact to nature: The site features several mature habitats including species rich hedgerow, wildflower meadow, scrubland and ditch. It is home to a great number of notable species including [protected species redacted], deer, swifts, marsh harriers, buzzards, bats and birds foot trefoil flower. The development would remove or severely degrade these habitats, and in doing so sever a long biodiversity corridor along the south side of Main Road, it also is a vital wildlife corridor and connection between the guestling woods side and across to broad street and the breed valley.
- Loss of public amenity: At least 10 local residents Including myself) enjoy walking their dogs here each day - a well-loved local amenity would be removed were the development to go ahead. The village green is a 15 minute walk away from our house and this side of the village lacks any other open amenity in the locality.
- Lack of pedestrian connectivity: The site is unsuitable for large development as it has no adjacent footway. Though there is a footway on the north side of Main Road, it is an extremely fast road (often with speeding vehicles) on a bend with limited visibility. Crossing the road here is very difficult and dangerous
- Lack of respect to local built environment character: The village is predominantly arranged along the north side of the Main Road, effectively forming a barrier to development, allowing all residents a fantastic closeness to the countryside and preventing sprawling of development into the countryside. The proposed dwelling numbers are of an excessive density not seen elsewhere in the village. Development at the west end of the village would further decentralise the village centre
- Unsuitable ground conditions: The field becomes extremely muddy each winter due to the high groundwater and would be unsuitable for development
- Noise from adjoining timber yard: The neighbouring Icklesham Joinery generates a lot of noise and could cause a nuisance to new residents
- Impairment of dark skies: the village enjoys fantastic views of the night sky, due mainly to the lack of street lighting. The new development (of a density likely to need its own site road) would make a substantial contribution to light pollution and this will affect night pollinators and the owl population

For these reasons i am objecting to this development site. Thank you