Rother District Council

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Support

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 28470

Received: 30/01/2026

Respondent: Mr simon roberts

Representation Summary:

I support this on the proviso that the pitiful state of Stonestile Lane is improved. It is no better than a dangerous track right now and needs to be significantly improved to support the inevitable increase in traffic.

Full text:

Object

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 28866

Received: 26/02/2026

Respondent: Mr Robert Chase

Representation Summary:

Westfields school and GP is currently over subscribed
Parking in the village is at an all time low
The roads are dangerously worn through moat lane and rock lane and stonestile lane

Full text:

Westfields school and GP is currently over subscribed
Parking in the village is at an all time low
The roads are dangerously worn through moat lane and rock lane and stonestile lane

Object

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 28867

Received: 26/02/2026

Respondent: Mr Robert Chase

Representation Summary:

This site should never have been approved in June
The access roads to the site and terrible
Cottage lane is already dangerous and the turn in from a28 difficult
The area area prone to flooding will be worse. There is not the local infrastructure in gp and schools to host more in the little town we have now

Full text:

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 29246

Received: 12/03/2026

Respondent: Emily Knight

Representation Summary:

WS3. The increase of traffic on Westfield Road/Church Lane, by both residential and construction traffic, would greatly increase the chances of fatal accidents on an already extremely dangerous road.

The sharp bend in the road results in around 3-5 major accidents a year, with extra housing being supported by this road, this would increase tenfold. It puts the existing houses at greater risk, see the major accident at Kirklands in 2024.

Westfield’s lanes are not suitable for construction vehicles and would cause extreme disruption. Possibly even increase accidents as a large portion of the town are often occupied by elderly and families with children.

Furthermore, construction work would cause years of disruption, both in noise and traffic in an otherwise small quiet village.

The school cannot support any more children and the GP is already overloaded with patients. There is little infrastructure to support an 300-500 person population increase.

Full text:

Support

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 29322

Received: 11/03/2026

Respondent: Mr & Mrs [1st name not given] Foy

Agent: BATCHELLER MONKHOUSE

Representation Summary:

Representation regarding WS5 below:

Full text:

Dear Sir/Madam

ROTHER DISTRICT COUNCIL - LOCAL PLAN REGULATION 18 CONSULTATION 2026 FRESHFIELDS FARM, WESTFIELD LANE, WESTFIELD REPRESENTATIONS ON BEHALF OF MR AND MRS FOY

On behalf of my client, Mr and Mrs Foy, / write to make submissions to the Rother District Regulation 18 Local Plan consultation. My client has control over the land identified in policy WS5 which is known as Freshfields Farm, Westfield Lane, Westfield.

These representations relate in particular to the following parts of the Regulation 18 document, titled Rother Draft Local Plan 2025-2042:

Policy Reference WS5 Development Needs: Economy

Policy Reference: WS5 KEY SCALE 0 22.5 45 67.5 90 112.5m 1 : 2,000 N Site Boundary

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Reproduced from the Ordnance Survey mapping with the permission of the Controller of His Majesty's Stationery Office (Crown Copyright). Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings Rother District Council Licence No 100018643 2010 No further copies may be made Figure 1: Land identified as Policy Red: WS5 Source: Draft Rother Local Plan

The policy details are set out below:

'Site name: Freshfields Farm, Westfield Lane, Westfield Site identification: New site identified through HELAA

Greenfield/ Brownfield: Part Greenfield, part Brownfield Sub-area: Southern Rother and the Hastings Fringes

Allocated use and capacity: The site is allocated for employment development comprising: Some 2,000sqm of new business floorspace (Use Classes E(g) or B8)

Policy text: Development on this site must:

Use the existing vehicular access from Westfield Lane (A28) subject to the approval of the Highway Authority; Include appropriate pedestrian infrastructure inside and outside the site to link to the existing footways on the western sides of Westfield Lane; Be informed by a landscape sensitivity assessment to determine an appropriate layout, form and detailed design to ensure the conservation and enhancement of the landscape and character of the High Weald National Landscape; Be designed to be in keeping with the agricultural character of the site, including through the style of new buildings; Retain and enhance the existing trees and hedgerows on the boundaries; Provide a landscape buffer to the existing caravan park to the south; Include any necessary off-site highway works necessary to make the development acceptable; Include an assessment and evaluation of the site's archaeological potential and the implementation of any mitigation measures identified through the assessment.

Supporting text:

This site comprises two fields that form part of a larger network of fields, located in the countryside to the south of Westfield village. There are existing buildings within the site used for agricultural, business and retail purposes and the site is suitable for an expansion of the existing business uses. It is within the High Weald National Landscape and therefore a sensitive form of development is required in line with Local Plan policies. While the site is separated from Westfield village, further employment development here accords with national planning policy which supports the sustainable growth and expansion of business in rural areas, both through conversion of existing buildings and well-designed, new buildings, recognising that sites to meet local business needs in rural areas may have to be found adjacent to or beyond existing settlements. Notwithstanding this, connections to the existing footway infrastructure on Westfield Lane will encourage active travel, as detailed above.'

We agree with the proposed allocation for expanding the employment floorspace on site however suggest that the allocation is increased to allow for a larger scale provision to meet longer term requirements. The allocation confirms that a number of upgrades will need to be required to deliver the employment space, including highway and pedestrian access upgrades within the site and significant landscaping works. Given the values currently available for employment space, a larger floor area may be required to be able to make the delivery of high- quality units, alongside significant site upgrades, financially viable. A larger scale allocation also allows for longer term planning for the site to ensure the council can still demonstrate adequate employment space even if some other draft allocations or unimplemented planning consents fall away.

The uses included within the allocation are:

E(g): Offices, research & development and light industry

B8: Storage and distribution

This is supported however it is also suggested that some level of retail is also approved given the presence of some existing retail units on site. The supporting text states: There are existing buildings within the site used for agricultural, business and retail purposes and the site is suitable for an expansion of the existing business uses.' This therefore suggests that retail is also included however use class E(a) which caters for retail has not been included in the proposed uses in the policy wording itself.

Westfield Parish Council do not have a neighbourhood plan however the Settlement Spatial Survey on the Westfield Spatial Plan which was requested by the Parish Council in order to feed into their representation on the emerging Local Plan identifies the priorities of the local residents in terms of growth. Supporting local shops and facilities was identified as a priority item when planning future development. It is understood that there has been no need for additional retail floor space to be allocated however the draft plan is clear that in mixed use developments some retail floorspace may be appropriate and the lack of allocation does not prevent applications for retail uses coming forward. Given there is some retail on site and a range of employment uses have been proposed at Freshfields Farm, adding retail as an optional use within the allocation would provide more flexibility within the allocation and would allow the site to evolve and respond as needs and demands in the district changes. It is therefore proposed that the policy is amended to include use class E(a) which provides for the display or retail sale of goods, other than hot food, principally to visiting members of the public.

Based on the supporting evidence, Rother's employment requirement up to 2040 is 74,189sqm of new floorspace. While the plan has identified an excess provision of 97,774sqm of floorspace, this includes 66,924 of existing allocations and sites that already have planning permission and only 30,850 sqm of proposed new allocations. Nearly 70% of the total provision is therefore on existing allocations or sites with planning permission. There is an element of uncertainty over these sites as not all sites with planning permission will come forward for development with some being delayed, consents expiring unimplemented, sites proving unviable, or being secured for alternative uses. The motivations for seeking planning permissions can vary dependent upon the type of site with many planning permissions sought simply to increase value. Therefore, not all permissions will be implemented, and sites may become unavailable or simply retain the existing uses. It is therefore considered that the extent of reliance on existing permissions, with their inherent uncertainty as regards delivery, weakens the strength of the proposed supply of employment space. This further justifies the need to look at larger floor areas within existing draft allocations where the landowners have expressed a clear intention to deliver.

The employment requirement comprises a mix of office, industrial and storage and distribution units. The site already includes a mix of retail and commercial units and could easily provide further office, light industrial, retail and storage and distribution units in excess of the 2,000sqm proposed. There is ample land to allow for further expansion without having a detrimental impact on the farm or surrounding uses. Significant landscaping is proposed in the draft policy to minimise the impact of further development on the High Weald National Landscape and the nature of the uses allows for buildings that are agrarian in design and layout, meaning they are compatible with what would be expected within a National Landscape location. Buildings of this style, even at a significant scale, would have a less urbanising effect on the National Landscape than residential development and landscaping and good design would lessen the impact further.

The existing access to Freshfields Farm is large and established, on a stretch of straight road just before entering the village of Westfield from the direction of Hastings and there is significant existing hardstanding already in place. The location, next to Westfield and just 6 miles north of Hastings on the A28, with footpaths from the site in each direction, mean the site is a well-connected and sustainable location for this type of use. Westfield is identified as moderately sustainable in the Settlement Study, with 4 out of 5 essential services available and a regular bus service to a number of highly sustainable settlements. It is therefore considered a logical and sustainable site for larger scale growth of employment floorspace.

The Housing and Economic Development Needs Assessment (HEDNA) indicates that there is sufficient capacity to meet identified needs in full in office and industrial uses, however, there is a shortfall for storage and distribution floorspace and this is something that can be delivered at Freshfields Farm alongside other commercial uses. The 2024 revisions to the NPPF have placed a greater emphasis on emerging economic sectors and activities, and the need for planning policies to respond positively to the modern economy. This includes activities associated with the transport and handling of goods (including freight, logistics and warehousing). The substantial existing access off the A28 and the geographical proximity to Hastings makes this site a logical location for logistics and warehousing and it is therefore proposed that the allocation is extended to include a larger element of floorspace to accommodate this growing demand.

The larger scale employment allocations in the district are located in Bexhill on Sea and Rye Harbour, leaving a geographical gap in the centre of the district which could be met with a higher quantum of employment space at Freshfield Farm. Additionally, since the HEDNA was produced, 3 large sites in Rother that had outline planning permission for employment uses, have dropped out of the supply pipeline for various reasons. It is possible others will also fall away and therefore identifying more floorspace across the district than the minimum need would be prudent in ensuring there isn't an under delivery over the next plan period.

It is therefore proposed that the allocation is extended and squared off as shown below to allow for more commercial units to be provided on site while still providing an adequate separation between the holiday park, the entrance to the holiday park and the commercial site. The provision of the landscape buffer required in the draft policy wording would further soften the impact, as would sensitive, agrarian architecture to reflect the agricultural setting within the National Landscape.

Please see attached representation regarding draft policy WS5

Attachments:

Representation regarding draft policy WS5 (298.31 KB)

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.

Attachments:

Final HWNL response RDC Local Plan Site Allocations Reg 18 consultation.pdf (697.13 KB)
Appendix 1 - individual site comments (226.61 KB)

Attachments:

Regulation 18 Consultation Response_WS3 Landowner Representation 2026.03.22_Redacted.pdf (1.12 MB)

Support

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 31394

Received: 23/03/2026

Respondent: Westfield Parish Council

Representation Summary:

WS3
There are several areas where the wording could be strengthened. The site should be landscape and active travel vision led, prioritising pedestrian and cycle movements across the site, making safe connections into existing footways and facilitating use of public transport.
The requirement for a “a new hedge on the southern boundary” is unlikely to be sufficient. The development should avoid the loss of existing mature trees.
It is agreed that vehicular access must be from Westfield Lane to avoid additional vehicle movements through the centre of the village.
The inclusion of green infrastructure is consistent with community priorities. The location provides opportunities to ensure connected Green Infrastructure corridors around the perimeter of the site.
The village play area is highly likely to be used by residents of the new development.
The current WS3 wording does not appear to include explicit reference to a drainage strategy or sustainable drainage systems.

Full text:

1. Introduction
1.1 This report is prepared for Westfield Parish Council in response to the Rother District Council (RDC) Local Plan Regulation 18 consultation (2026).

1.2 This response considers the overall RDC spatial strategy and then provides detailed commentary
on the proposed site allocation policies WS3, Land at Moor Farm, WS4 Land on east side of Cottage Lane, and WS5 Freshfields Farm, Westfield Lane, as these sites are considered to have the most direct relationship with, and potential impact on, the core village of Westfield.

1.3 While the Parish Council has reviewed all the proposed allocations within the parish area, it considers that the sites identified on the Hastings Fringes as WS1 and WS2 are broadly acceptable in principle given their relationship to the Hastings urban area and their more limited interaction with the historic and functional core of the village.

1.4 By contrast, the proposed allocations under Policies WS3, WS4 and WS5 have a direct influence on the character, function and infrastructure of the village itself. These sites sit within or directly adjacent to the established settlement pattern of Westfield and therefore raise more substantive considerations in terms of village form, landscape setting, access, infrastructure capacity and the overall scale of growth appropriate to the parish.

1.5 For these reasons, the Parish Council’s response will concentrate on providing a detailed assessment of these three policies and the sites they relate to. This will include consideration of the specific constraints and opportunities associated with each site, together with a review of alternative sites previously identified through the Land Availability Assessment that may provide different options for accommodating any future growth affecting the village.

1.6 Site allocations must be sound, sustainably located, environmentally responsible and compliant with national policy. As such, this response is also informed by the draft National Planning Policy Framework (NPPF 2025) which is clear that policies which are inconsistent with the National Decision-Making Policies (NDMPs) contained within it will be given very limited weight. Therefore, to ensure the enduring application of the RDC Local Plan post adoption, the Parish Council is mindful of both existing and emerging national policies.

2. Summary of Response
2.1 Westfield Parish Council supports the overall spatial strategy set out in the Regulation 18 Draft Local Plan, particularly the principle of directing growth towards the most sustainable locations within the district, including the Hastings Fringes where the southern part of Westfield Parish benefits from proximity to Hastings and access to services, employment and transport connections.

2.2 The Parish Council also recognises the need to balance the delivery of new housing with the protection of the district’s significant environmental assets, including the High Weald National Landscape, and considers that the strategy broadly reflects this balance, particularly in its application to Westfield.

2.3 However, the Parish Council is mindful that the draft Local Plan identifies a substantial shortfall between the Government’s standard method housing need and the level of housing currently proposed to be delivered through the Plan period. While it acknowledges the constraints faced by the district and the protection afforded to the National Landscape in current and emerging national policy, this shortfall may give rise to further consideration of development opportunities during the later stages of plan preparation or at examination. In that context, it is important that the Local Planning Authority has a clear understanding of community views regarding the relative suitability of sites and the potential direction of any future growth within Westfield.

2.4 Westfield Parish Council does not object to the inclusion of sites WS3 and WS5 but has provided what it hopes is considered helpful commentary in reviewing the proposed policy wording and supporting text for each. The Parish Council maintains its objection to the inclusion of WS4. Notwithstanding the planning consent on the site, the current position in respect of the live re-stocking order and the pending appeal in late 2026 in relation to this means that the site should not be considered available for the purposes of plan making. This is on top of the significant community objection to the site and the Parish Council’s own objections.

2.5 In acknowledging the shortfall of housing provision across the proposed Local Plan in 2.3, the Parish Council has additionally included a review of those sites previously identified through the Land Availability Assessment (HELAA) but not progressed within this iteration of the draft Local Plan. The purpose of this review is not to promote additional development, but to assist, by providing Rother District Council with an informed view of local priorities, constraints and community preferences regarding how any future growth in the parish might best be accommodated should additional housing provision be required.

2.6 Through this approach, the Parish Council seeks to contribute constructively to the plan-making process by ensuring that, if additional development opportunities need to be considered at later stages, the Local Planning Authority is already aware of the relative acceptability of sites from the perspective of the local community and the parish’s long-term spatial character.

3. Settlement Spatial Planning
3.1. This response is informed by a Settlement Spatial Plan (SSP) prepared for Westfield Parish Council through a commissioned piece of work with specialist consultants ONH Planning for Good. This was designed to assist the Parish Council in proactively exploring how future growth in Westfield could be managed and shaped in a coordinated and locally informed way.

3.2. This scenario planning approach allows the potential effects of different growth patterns to be tested against infrastructure capacity, environmental constraints and settlement character, helping the Parish Council and residents consider how development might be accommodated in a coordinated and sustainable way, assessing a range of possible future outcomes, understanding the implications of different growth patterns and identifying a preferred and sustainable growth strategy.

3.3. Importantly, scenario planning moves beyond a narrow, site-by-site assessment that can result in the selection of the ‘least constrained’ sites in isolation. Instead, it promotes a holistic understanding of growth, allowing consideration of when and where a step change in supporting infrastructure may be required and ensuring that infrastructure provision is planned as an integral component of development rather than as an afterthought.

3.4. Westfield Parish Council undertook community engagement during late 2025 on the SPP work. This engagement formed part of the Parish Council’s “Future Westfield” initiative, which aims to proactively consider the implications of future development pressures and ensure that any response to the Local Plan reflects informed community preferences.

3.5. Residents were invited to review a series of five illustrative spatial growth scenarios that explored different ways the village might expand to 2050. These scenarios tested potential development around the northern, eastern and southern edges of the village, as well as more dispersed growth patterns, with each scenario broadly capable of accommodating around 150 dwellings, considered to be an appropriate/likely number to be delivered over the next 25 years – i.e. beyond the emerging Local Plan period and considered to be plausible in terms of existing social and community infrastructure limits (such as school places capacity)

3.6. Residents were asked to provide feedback through an online survey and rate each scenario on a scale from 1 (very unsuitable) to 5 (very suitable). In total, 64 responses were received. The analysis of responses shows that growth to the south of the village, was favoured over other directions and this supports the inclusion of WS3 – Land at Moor Farm.

3.7. Across all scenarios, several consistent themes emerged from the consultation. Residents emphasised:

3.7.1. The importance of ensuring that infrastructure improvements precede or accompany development.
3.7.2. The need to protect the rural character of the village and its setting within the High Weald National Landscape (HWNL) by avoiding large urban-style estates and ensure that any development is carefully designed and integrated into the existing settlement. An ongoing concern linked to this is the worry that Westfield will be subsumed into Hastings and lose it’s distinctive identity and rural characteristics which are also strongly linked to being situated within the HWNL.
3.7.3. Respondents also highlighted the need for development to deliver tangible community benefits, such as improved walking routes, parking solutions, green space and traffic management measures.

3.8. Overall, the engagement indicates that while residents recognise that some level of future growth may be inevitable, this should be carefully managed to respect village character and supported by appropriate infrastructure improvements.

4. Proposed Allocation WS3 Land at Moor Farm

4.1 There is broad support for the Policy wording, however there are several areas where this could be strengthened to ensure the site better connects to the existing community and its setting whilst minimis. The site should be landscape and active travel vision led, prioritising pedestrian and cycle movements across the site, making safe connections into existing footways and facilitating use of public transport.

4.2 The requirement for a “a new hedge on the southern boundary of the site” is unlikely to be sufficient in terms of providing screening and mitigating impacts on the setting of the National Landscape and stopping ongoing ‘creep’ into the HWNL. This should be strengthened with a requirement for strong defensible boundaries to the site, with a combination of dense mixed-native hedgerows and native tree planting creating a strong and distinctive boundary. The development should avoid the loss of existing mature trees (unless they are proven to be a health and safety risk) and any which are lost should be replaced on a two for one basis, with native species to increase canopy cover across the site and reduce its visibility in the wider landscape.

4.3 It is agreed that vehicular access must be from Westfield Lane (A28) to avoid additional vehicle movements through the centre of the village. This access should also include provision for a bus stop complete with appropriate street furniture sympathetic to a rural setting, to serve the new development. There should also be a safe crossing point over the A28 to enable residents using the local bus service to use the north bound service on the western side of the carriageway. This, along with 4.6 and 4.7 (below) would be considered appropriate to include within bullet point ix “Include any necessary off-site highway works necessary to make the development acceptable”

4.4 The inclusion of green infrastructure is consistent with community priorities; however, the policy could provide greater clarity regarding the purpose and function of this space. Residents have highlighted the importance of maintaining green space as a means of avoiding the perception of urbanisation within the village.

4.5 Whilst the proposed policy wording seeking to predominantly locate this in the southern half of the site is agreed, the location provides opportunities to ensure connected Green Infrastructure corridors around the perimeter of the site, linking into the existing mature tree belt along the western boundary and the dense vegetation along Stonestile Lane. The policy again should ensure boundaries are enhanced and strengthened.

4.6 The village play area is located around 400m from the site accessed via the footway along the A28 and is therefore highly likely to be used by residents of the new development. As such this footway need to be of sufficient width to allow safe passage for wheeled access (including pushchairs). This means improvements on the existing footpath along the A28 and good footpaths within any development on site.

4.7 The Council welcomes the inclusion of the requirement of the development to include pedestrian access onto the Public Right of Way (Westfield 44) that crosses the site. However, this footpath should be upgraded to an all-weather permeable surface. The Council also agrees with the requirement to “Include appropriate pedestrian infrastructure inside and outside the site to link to the existing footways, including new footways to link the new development to the existing Westfield Lane and Moor Lane footways.” This is a critical of the allocation and must result in providing a preferrable and safe access to the village centre, including the Primary School away from the A28.

4.8 Residents also raised concerns about drainage and surface water management during the engagement process. The current WS3 wording does not appear to include explicit reference to a drainage strategy or sustainable drainage systems. The Strategic Flood Risk Assessment identifies recorded incidents of sewer flooding affecting Westfield, indicating that the village has experienced local drainage and surface water related flooding in the recent past. The presence of recorded sewer flooding incidents highlights the importance of ensuring that new development incorporates robust surface water management and sustainable drainage measures.
5. Proposed Allocation WS4 Land on east side of Cottage Lane
5.1 Whilst there is an outline consent for 20 dwellings (RR/2022/1118/P), the Parish Council object to the inclusion of this site, the current position in relation to the live restocking order means this site is not considered deliverable for 10 years. With the appeal not being heard until the end of 2026 it is unlikely the site could be included. The site was opposed by residents on a wide range of issues including:
5.2 Overdevelopment & policy conflict: The scheme is considered too large for a rural parish within the AONB, conflicting with local and national planning policies and risking urbanisation of the countryside.
5.3 Unsustainable location: Poor connectivity to village services, no safe or viable footpath network, and reliance on cars make the site unsuitable for development.
5.4 Harm to AONB landscape: Significant visual impact, loss of green space, light pollution, and damage to the character and scenic beauty of the protected landscape.
5.5 Affordable housing mismatch: Proposed housing mix does not reflect local need, particularly lacking smaller (1–2 bed) homes.
5.6 Ecological concerns: Inadequate surveys, potential presence of protected species, loss of habitats and hedgerows, and unclear biodiversity net gain.
5.7 Highway safety issues: Increased traffic on narrow country lanes, dangerous junctions, lack of safe pedestrian access, and insufficient transport mitigation.
5.8 Flooding risk: Existing drainage and surface water problems likely to worsen; mitigation proposals considered insufficient.
5.9 Loss of agricultural land: Development would remove productive farmland and existing rural business use without justification.
5.10 Procedural and environmental concerns: Site clearance before determination, possible biodiversity loss, and potential regulatory breaches raise concerns about proper assessment.

5.11 Whilst the Parish Council disagrees with the inclusion of the site, it has still reviewed the proposed policy wording in the event that the site remains within the Local Plan as it progresses. As such the policy must allow for these concerns to be addressed/mitigated at the reserved matters stage should the restocking order not be upheld and the site released for development.

5.12 Whilst the policy requires the inclusion of “appropriate pedestrian infrastructure inside and outside the site” and “pedestrian access onto the Public Right of Way (Westfield 27) that is adjacent to the southern boundary”, the wording does not provide sufficient clarity or certainty in terms of ensuring that residents will be able to walk, safely, on foot, from the development site into the village centre and the surgery.

5.13 As the S106 agreement requires an upgrading of footpath 28 and the inclusion of a safe crossing point across the A28 to access the bus stops. This must be reflected in the policy wording, with the inclusion of the requirement for a signalised crossing point given the lack of visibility as you emerge from footpath 28 onto the main road.

5.14 The footway on the short stretch of the A28 on the southbound carriageway of the road between the crossing point, bus stop and village surgery entrance will also require widening to prevent pedestrians being struck by passing traffic given the limited width of the current path.

5.15 The appropriate pedestrian infrastructure should also include some way of prioritising pedestrian movements between footpath 27 and 28 along Cottage Lane to ensure drivers do not come into conflict with those on foot.

5.16 In addition, there are unresolved issues around surface water management. Whilst the Policy recognises the surface water flood risk through clause v) “Include no built development in the southern part of the site which is shown to be at risk of surface water flooding”, there should be a specific policy clause ( included within condition 7 of the consent ) to require the submission of an appropriately designed surface water drainage system to ensure satisfactory drainage of the site and to ensure flood risks are not increased elsewhere.
6 Proposed Allocation WS5 Freshfields Farm
6.1 WS5 proposes the allocation of land at Freshfields Farm, Westfield Lane for approximately 2,000 sqm of business floorspace (Use Class E(g) or B8), using the existing access from the A28 and requiring pedestrian links, landscape sensitivity assessment within the High Weald National Landscape, design reflecting agricultural character, retention of boundary trees and hedgerows, and a landscape buffer to the neighbouring caravan park.
6.2 The Parish Council does not object to this allocation on the basis that WS5 may provide an opportunity to support local employment growth, which aligns with wider Local Plan objectives for supporting the rural economy.
6.3 However, the policy wording should be stronger in terms of responding to the setting of the site and needing to ensure a landscape led design. Whilst there is reference to agricultural character, the policy does not explicitly address height, massing, external materials or lighting impacts. Given the sensitivity of the High Weald National Landscape, clearer design parameters would help ensure development integrates into the landscape rather than appearing industrial or urban in form. It is therefore suggested that a small number of clauses could be amended.
6.4 Clause iii) should be expanded as follows:
“Development proposals must demonstrate a landscape-led design approach that conserves and enhances the character and appearance of the High Weald National Landscape, informed by a Landscape Sensitivity Assessment. Buildings must be modest in scale and carefully integrated into the landscape, with height, massing and footprint limited to ensure that development remains visually subservient to the surrounding rural setting”
6.5 Clause iv) should be strengthened to state:
“Buildings should be designed to reflect the form, scale and materials of traditional agricultural buildings or farmstead groups typical of the High Weald, avoiding large industrial forms or extensive uninterrupted roof spans”.
6.6 Clause v) should be enhanced with the following:
“Development proposals must include substantial structural landscaping and retention of existing trees and hedgerows to provide effective screening and integration with the surrounding landscape. External lighting should be minimised and designed to protect the dark night skies characteristic of the National Landscape.”
6.7 Strengthening the policy wording in these areas would help ensure that the site allocation responds more fully to the concerns expressed by the community when responding to the Settlement Spatial Plan work and better protect the character of Westfield and its setting within the High Weald National Landscape.
6.8 Finally, given the potential for the identified use classes for E(g) or B8 uses to generate heavy goods vehicle traffic and the concerns raised by the community in respect of traffic generation from development, the policy could be strengthened by requiring a detailed Transport Assessment.
7 Existing Allocation
7.1 The Parish Council notes that site WES0002 (Former Moorhurst Care Home), which was previously allocated in the Development and Site Allocations Plan, for housing with care was granted on appeal in September 2025 (APP/U1430/W/24/3354261)
7.2 Evidence from the Parish Council’s community engagement exercise indicates that this site would be more appropriately used for residential development. The site represents previously developed and already allocated land that is better related to the existing village and closer to services than most of the alternative greenfield sites considered. Redevelopment of such land aligns more closely with community preference than expansion into open countryside.
7.3 In this context, the Parish Council considers that the site could reasonably be identified within the emerging Local Plan as suitable for residential development (Use Class C3). As such it would be considered appropriate to reallocate the site in the emerging Local Plan for both C2 and C3 use. Whilst this would only modestly increase the overall level of development proposed for the parish, it would provide flexibility in how the site is developed, should the consented scheme not come forward for any reason, enabling the site to contribute to meeting local housing needs while reflecting community preferences and supporting the efficient reuse of previously developed land. Any residential redevelopment should be subject to appropriate safeguards including traffic and parking mitigation, contributions to local infrastructure, and improvements to pedestrian connectivity, including a safe crossing point and access to the existing footpath and footway networks and bus stops.
8 Rejected sites
8.1 The Parish Council Settlement Spatial Plan community engagement material was expressly designed to test broad spatial options for future growth in the village rather than simply react to individual sites. It assumed that some growth was likely, that all scenarios would sit within the National Landscape, and that the exercise should help identify the most logical places for any future development. It also assumed that development on the Hastings Fringe to the south of the parish may already be brought forward through the Local Plan.
8.2 A PDF copy of the Settlement Spatial Plan community engagement material is provided for reference. The resident survey showed that the strongest support was for Scenario 4 (Southern Growth +) and Scenario 5 (Distributed Pockets), with Scenario 3 (Southern Growth) close behind. Scenario 1 (Northern Growth) had very limited support, and Scenario 2 (Eastern Growth) attracted minimal support. Across all options, the strongest recurring themes were that growth should be limited, infrastructure-led, sensitive to village character, and should avoid urban-style expansion. Residents consistently prioritised traffic and road safety, drainage and flooding, school and GP capacity, and protection of the High Weald landscape and village setting.
8.3 Taken together, the community preference is for carefully managed, modest form of growth. As such, if more land is ever needed, sites that are well related to the southern village edge, accessible to the village centre, and capable of being planned with strong landscape buffers are more likely to align with community evidence than more remote or exposed alternatives. This also fits with the current position that WS3 is conditionally acceptable in principle, subject to stronger safeguards on design, infrastructure and landscape treatment.
8.4 Second, there is support for a limited “distributed pockets” approach, but only in a very restrained sense. This scenario performed strongly because it was seen as balanced and flexible, allowing modest growth while protecting the core village character.
8.5 In HELAA terms, this indicates that sites that are either previously developed or already allocated land close to services, or very modest edge-of-settlement opportunities capable of being landscape-led and supported by pedestrian and highway improvements would be preferred by the community.

8.6 The clearest example is WES0002 (Former Moorhurst Care Home), which the Parish assessment identifies as better suited to housing than many greenfield options because it is previously used/allocated land, closer to services, and less intrusive in landscape terms than most alternatives.

8.7 A second example is WES0042 (land west of the A28). Both the HELAA and the Settlement Spatial Plan assessment indicate that this site could only ever be appropriate, if at all, as a small, high-quality, landscape-led scheme. The HELAA says it could potentially offer such an opportunity, including improved pedestrian infrastructure, but also notes that it is highly visible at the village entrance and in long views from Hastings, and that its landscape and access impacts require further consideration. The Parish assessment reaches the same conclusion: only very limited development could be contemplated, and larger or standard estate-style development would conflict with community priorities.
Locations that should generally be avoided
8.8 The following sites conflict with multiple community priorities including landscape protection, sustainability, access, and infrastructure capacity.
8.8 Countryside encroachment and isolated locations:
8.8.1 WES0043 – Troyd Farm, Moat Lane
8.8.2 WES0044 – Thala Farm, Mill Lane
8.8.3 WES0022 – Thornyridge field
8.8.4 WES0039 – Land opposite church, Vicarage Lane
8.9 These sites:
8.9.1 Extend development into open countryside
8.9.2 Harm High Weald landscape character
8.9.3 Have poor or unsafe access
8.9.4 Are remote from services
8.9.5 Increase car dependency
8.10 Parish conclusion: These locations are not supported by community opinion and comments or the proposed Local Plan policies and should not be prioritised.
8.11 Environmentally constrained or unsustainable sites:
8.11.1 WES0023 – Tanyard Farm (previously assessed unsuitable)
8.11.2 WES0024 - Land north of Fishponds Lane and east of Workhouse Lane (locally sensitive site as close to a ghyll and subject to significant surface water and flooding)
8.11.3 WES0036 – Land north of Wheel Lane (Local Wildlife Site)
8.11.4 WES0037 – Land north of Churchfield (loss of open space)
8.11.5 WES0041 – Woodside, Moat Lane (isolated and flood risk)
8.12 These sites raise significant concerns relating to:
8.12.1 Biodiversity and habitat loss
8.12.2 Landscape harm
8.12.3 Unsustainable access
8.12.4 Loss of community green space
8.13 Parish conclusion: These sites are not appropriate for development and conflict directly with resident priorities and clearly harm the protected National Landscape.
8.14 The combined evidence it is clear that open countryside, isolated sites, ribbon-development locations, sites allowing ongoing encroachment into the HWNL and environmentally constrained land should be avoided for Westfield Parish to maintain it’s rural character and to protect to local landscapes and the areas of unique environmental sensitivities.
9 Conclusion
9.1 Westfield Parish Council broadly supports the overall spatial strategy of the Regulation 18 Draft Local Plan, particularly the principle of directing growth towards the most sustainable locations while recognising the constraints associated with the High Weald National Landscape.
9.2 The Parish Council does not object in principle to the proposed allocations WS3 and WS5. However, the policy wording should be strengthened to ensure development is landscape-led giving clear and new boundaries not allowing ongoing ‘creep’ into the HWNL, well integrated with the existing settlement, and supported by appropriate infrastructure, particularly safe pedestrian connectivity, drainage measures and high-quality design that reflects the rural character of the village.
9.3 Evidence from the Settlement Spatial Plan work and community engagement indicates that residents accept that some level of growth may occur but strongly favour development that is modest in scale, infrastructure-led and sensitive to the village’s landscape setting.
9.4 Should additional housing provision need to be considered at later stages of the plan-making process, the evidence suggests that the most appropriate opportunities would be previously developed or already allocated land, or sites closely related to the southern edge of the village capable of being delivered in a coordinated and landscape-led manner. Conversely, more isolated or environmentally sensitive sites would conflict with both HELAA findings and community priorities.
9.5 The Parish Council hopes that this response will assist Rother District Council in refining the Local Plan and ensuring that any future development in Westfield is delivered in a sustainable manner that respects the character of the village and reflects community priorities.

Object

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 31395

Received: 23/03/2026

Respondent: Westfield Parish Council

Representation Summary:

WS4 Land on east side of Cottage Lane
The Parish Council disagrees with the inclusion of the site. it has reviewed the proposed policy wording.
The policy requires the inclusion of “appropriate pedestrian infrastructure..' the wording does not provide clarity for ensuring that residents will be able to walk, from the development site into the village centre.
The S106 agreement requires an upgrading of footpath and the inclusion of a safe crossing point across the A28 to access the bus stops. This must be reflected in the policy wording.
The footway on the A28 on the southbound carriageway between the crossing point, bus stop and village surgery entrance will also require widening.
There are unresolved issues around surface water management. There should be a specific policy clause to require the submission of an appropriately designed surface water drainage system.

Full text:

Support

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Representation ID: 31396

Received: 23/03/2026

Respondent: Westfield Parish Council

Representation Summary:

WS5 Freshfields Farm
The Parish Council does not object to this allocation on the basis that WS5 may provide an opportunity to support local employment growth.
The policy wording should be stronger in terms of responding to the setting of the site and needing to ensure a landscape led design. It is suggested that a small number of clauses could be amended (see full submission). Strengthening the policy wording in these areas would help ensure that the site allocation responds more fully to the concerns expressed by the community when responding to the Settlement Spatial Plan work and better protect the character of Westfield and its setting within the High Weald National Landscape.
The policy could be strengthened by requiring a detailed Transport Assessment.

Full text: