What happened to site WES2: former Moorhurst Care Home, from the last plan?
Whilst the proposed nursing home may not be suitable surely the land could be developed with assisted living options? With better public transport residents could still reach amenities in Hastings/st Leonards. The site already has access on to the A28.
The site could also include a much needed community hub for additional medical support or for clubs to use for social groups

The proposed allocations in Westfield are broadly supported as part of the Council’s strategy to deliver sensitive growth within villages that have access to services and facilities. However, there may be additional opportunities for small-scale development that could contribute positively to meeting the district’s housing needs. In this regard, the site at Land at Troyd Farm, Moat Lane, Westfield (HELAA reference WES0043) should be reconsidered as a potential allocation. The site is located between Moat Lane and the A21 trunk road and is contained by established wooded boundaries. As a result, the land has limited visibility from the surrounding public realm and does not form part of widely experienced views within the National Landscape. The enclosed nature of the site means that carefully designed development could be accommodated without materially affecting the wider enjoyment of the countryside. The land itself is currently of limited landscape quality and does not make a significant positive contribution to the character of the surrounding countryside. In terms of settlement pattern, development along Moat Lane currently follows a ribbon form. The site sits directly behind existing development along this lane and represents a logical rounding-off of the existing built form rather than an isolated incursion into open countryside. Sensitive design and landscaping could ensure that development integrates with the existing settlement pattern and respects the character of the High Weald National Landscape. The HELAA assessment also suggests that the site is not in a sustainable location due to a lack of services and pedestrian access. However, there is an established public footpath along Moat Lane which connects directly to Westfield village. This provides pedestrian access to local services including the village shop, public house and other facilities within approximately a 15-minute walk. The site also benefits from proximity to Hastings and its wider range of services and employment opportunities. The presence of existing residential development along Moat Lane, combined with pedestrian access to the village and the close relationship with Hastings, indicates that the site is capable of forming a sustainable small-scale extension to the settlement. With regard to surface water flooding, this is a matter that can be addressed through detailed site design and the incorporation of sustainable drainage systems, which are now standard practice in residential development. In light of the above, the site represents a suitable opportunity for modest, well-designed development that would respect the landscape setting of the High Weald National Landscape while contributing towards the district’s housing needs. It is therefore suggested that the site is reconsidered through the Local Plan process as a potential housing allocation.

ROTHER DISTRICT COUNCIL - LOCAL PLAN 2025-2042- DEVELOPMENT STRATEGY AND SITE ALLOCATION REGULATION 18 CONSULTATION 2026 REPRESENTATIONS ON BEHALF OF MR S FAULKNER

Land opposite St John the Baptist Church, Vicarage Lane, Westfield

On behalf of my client, Mr S Faulkner, / write to make submissions to the Rother District Regulation 18 Local Plan 2026 consultation. This follows representations previously made in June 2024. The site has not yet been assessed in the council's most recent HELAA despite the previous representations being made in 2024.

Since the last representations, high level pre application discussions have taken place with Rother District Council regarding development on site. As part of the pre application enquiry a Heritage Assessment and a Landscape Assessment were commissioned. These have been submitted alongside these representations to demonstrate that heritage and landscape matters on site can both be overcome with a sensitive, low density scheme.

Mr S Faulkner has control over land opposite St John the Baptist Church, Vicarage Lane, Westfield along with his family members Mr Timothy Faulkner and Lady Amanda White- Spunner. The land has been identified as WES0039 in the Council's HELAA online mapping system, see Figure 1 below. My client also owns the land identified as WES0035 and WES0053. The land most suitable for immediate development is WES0039 and half of WES0053 and these representations therefore focus on this parcel as identified in Appendix 1. This is also the parcel that has been subject to pre application discussions with the Council however the additional parcels are also available for development, should the council consider them suitable.

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It is proposed that the boundary of parcel WES0039 is extended as shown in Appendix

1 to give a larger quantum of land to facility landscaping measures and/or BNG

requirements.

WES0038 eld

WES0024

Westfield School + LET a WES0017

- WES0036

WES0012 T -

WES0037 South Terrace 1 E

WES0023

B WES0035

Play Space Moorsita

WE St John.The Westfield Baptist s.Church Tennis Club WES0053 Play Space WES0039 WES0003 189

WES0021 WES0031

WES0042

100 m 500 ft Summer 0 Nome 1

Figure 1: Extract of Westfield from HELAA

These representations relate in particular to the following parts of the Regulation 18

document, titled Rother Local Plan 2025-2042 - Development Strategy and Site

Allocation.

Housing Need

Proposed Strategy: Overall Development Strategy

Vision for Southern Rother and the Hastings Fringes

Housing Need

The key objective to significantly boost the supply of housing remains a focus of

planning policy at all levels. Paragraph 61 of the NPPF states that to support this aim it

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is important to ensure a sufficient amount and variety of land can come forward where it is needed.

In addition, paragraph 11b of the NPPF states:

'Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. 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;

or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.'

The Regulation 18 consultation identifies the housing need in the district as 15,504 homes for over the plan period 2025 to 2042. This figure was derived using the Standard Method, as required by the NPPF and accompanying Planning Practice Guidance (PPG). This amounts to 912 dwellings per annum. It is not clear from the Regulation 18 consultation whether this figure includes a 20% buffer to be applied as a result of under delivery as set out at paragraph 78 of the NPPF. If the 20% buffer has yet to be applied, housing requirement would increase to 1094 dwellings per annum -18,598 dwellings over the plan period.

In any event, the Council have confirmed they do not in fact intend to meet their full housing need (as calculated by the standard method) for a number of reasons most notably the significant landscape, flooding and heritage constraints which exist across the district. We accept that footnote 7 of paragraph 11 of the NPPF allows for a reduction in housing delivery in areas restricted by certain designations, including National Landscape, of which a significant part of the Rother District falls within. However, we do not consider the lower housing figures offered in the Regulation 18 Consultation have been justified or that sufficient reason has been given for not meeting the higher housing need figure required by the standard methodology.

The history of under delivery of housing since the adoption of the Core Strategy is well documented (as set out paragraph 3.3 of the Regulation 18 Plan) which makes all the more pressing case for the Council to be taking a more radical approach to positively plan for a higher level of housing.

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The Council have made a brief reference in the Regulation 18 plan to a few reasons as to why they cannot meet their housing need figure calculated using the standard methodology including:

Landscape constraints Constraints resulting from areas lying within flood zones Heritage Assets Internationally and nationally designated habitats sites, covering roughly 7 per cent of the district, that must be conserved. Highest proportion of ancient woodland (compared to land area) in South-East England.

Beyond a passing reference to the above constraints the Council has not set out in detail why they cannot meet their full identified housing need. We would note that under the previous Regulation 18 Consultation, heritage assets and the extent of ancient woodland in the district were not cited as reasons for limiting the level of housing to be provided. It is unclear as to why these are now considered to be constraints on the level of housing that can be developed. In our experience of development sites, nearby heritage assets and ancient woodlands are usually constraints that can be worked around with appropriate buffers/mitigation and design so we do not consider them to be a constraint on the quantum of development that can be delivered across the district.

The land subject of these representations lies within the High Weald National Landscape but is well-screened by mature vegetation, some of which is Ancient Woodland and would therefore not be highly visible from wider ranging views. The land also lies within Flood Zone 1 so it is not constrained the flooding constraints cited by the Council as a reason to not meet full identified housing need being entirely within flood zone 1.

The Church Place development, which lies to the south-east contains a statutorily listed building known as Church Place Farm. There are however a number of former outbuildings which have been converted to residential uses including holiday lets physically separating the listed building from the subject site. The church, which lies opposite the site, is also listed however this is physically separated from the site by the road, church yard and informal parking area. Whilst these listed buildings are within the vicinity of the site, they are not considered to be a constraint to the development of the site as detailed further in the heritage section below. Similarly, whilst there is ancient woodland on the secondary parcels identified, the required buffers will not impact the developable area of the primary parcel being promoted for immediate development. This is discussed further in the landscape section below.

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There is an existing field access into the site which would be closed as part of the proposed development and a new access would be created further along Vicarage Lane to improve visibility in both directions. Existing informal parking which occurs immediately outside the site would also be formalised to continue to provide parking for those using the church facilities. There is also an option of creating a new footpath link to Church Lane to enhance sustainable transport options.

Proposed Strategy: Overall Spatial Development Strategy

The Regulation 18 draft local plan identifies a number of spatial strategies across the district to respond to different circumstances, including some additional development within Westfield.

We support the principle of employing a number of spatial strategies to provide the flexibility to respond to differing circumstances and as a village with good sustainability, in addition to connectivity to higher tier settlements, Westfield makes a logical focus for additional growth.

Vision for Southern Rother and the Hastings Fringes

The vision for Southern Rother and the Hastings Fridges states that there is potential to deliver 382 dwellings across the sub-area. Westfield is identified as a settlement within this sub area however despite Westfield being defined as having good sustainability, only 70 dwellings are currently proposed via draft allocation, on two old allocations that have to date, failed to deliver any housing. To have so little housing proposed within a settlement identified as having 4 out of 5 of the key services considered in their sustainability matrix indicates that the Council have not taken serious steps to seek to meet their housing requirements and indicate that the plan has not been positively prepared.

Of the 2 residential allocations within the village, one site has been allocated since 2019 for 20 dwellings. An outline application made in 2022 was finally granted in June 2025, see reference RR/2022/1118/P: outline planning permission for up to 20 dwellings with new access from Cottage Lane. The other was also allocated previously for 40 dwellings, which has now increased to 50, but instead has a refused application for a 64 bedroom care home. There is also no guarantee that with a valid planning consent that the sites will still be delivered. There is therefore no clear indication that either site is likely to meet the 70 dwellings proposed in the emerging plan and therefore it is essential that additional sites within Westfield, where the owners have made it clear that they intend to bring forward development immediately, are allocated within the emerging Local Plan.

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The vision states that sensitive small-scale development will be delivered in villages, at densities consistent with the surrounding area, where it is sustainable to do so and does not negatively impact the setting of the High Weald NL. We contend that this site is exactly the type of site that should be delivered to accord this this vision as it is small scale, immediately adjoins the existing settlement boundary of a sustainable settlement and could deliver housing in line with the existing building line without having any additional impact on the High Weald NL.

The land at WEA0039 could bring forward an immediate planning application for a sensitively designed small scale housing scheme delivering quality family housing in the short term. Paragraph 70 of the NPPF recognises that small scale developments can deliver housing at a faster rate. The land is owned outright by the Faulkner family and so there are no third party ownership issues which might prevent or delay delivery. It is anticipated that a small-scale development here could be delivered at a relatively quick rate to help meet local housing needs swiftly.

In accordance with the Government's objective of significantly boosting housing supply we contend the Council should pursue a higher growth strategy to fully meet the full identified housing need for the plan period. Adopting this approach will allow the Council to develop a long-term sustainable growth strategy which provides flexibility to adapt to changes in demand and allow for the inevitable cases where development does not come forward for some reason or under delivers. This is particularly the case given the history of under delivery in the district, especially within Westfield. It would also allow for a more consistent delivery rate, allowing for a wider range of smaller sites, such as the land identified as WES0039, to be delivered while the infrastructure is put in place to serve larger developments.

Site Specific Considerations

The submitted land identified at Appendix 1, immediately adjoins the current development boundary of Westfield which has been identified as a moderately sustainable settlement.

Footpaths within the vicinity of the land provide access to a range of facilities within Westfield, with a footpath running through the churchyard opposite directly into the village. Whilst these footpaths are not formal rights of way, the landowner has liaised with the Chichester Diocese has received written confirmation that if the site is developed, residents are welcome to use the paths to access the village. The correspondence with the Senior Church Buildings and Pastoral Reorganisation Officer states:

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'I understand that there are several pathways across the churchyard at Westfield, connecting the church, hall and vicarage to each other and the surrounding roads. Although there are no formal rights of way, the churchyard is open to the public and the parish have confirmed that they are very happy for local people to use their footpaths. We very much hope that the church will continue to play an important role at the centre of the community for many years to come, and don't anticipate the situation with the footpaths changing in the future.' Full email correspondence can be provided on request if required.

The evidence base document Settlement Study identifies Westfield as being moderately sustainable, however it has 4 out of the 5 essential services used in the scoring matrix. It states that the main factor holding back Westfield from being considered more sustainable is the lack of employment sites however the local plan does not seek to allocate any sites for new housing which again indicates the plan has not been positively prepared. Furthermore Westfield is just 6 miles north of Hastings on the A28 meaning most employment opportunities within Hastings would also be available to residents of Westfield.

Westfield village offers a range of shops and facilities including a pub, a primary school, a restaurant and a church as well as a local store with a Post Office, a hairdresser, a beautician, a butcher and a pet grooming shop. All these are within walking distance of the proposed site on Vicarage Lane. Also within the Parish is the Carr Taylor vineyard and a business park for 13 small rural enterprises as well as Freshfields Farm which comprises a range of commercial and retail uses. Bus stops within walking distance of the site provide regular services to Hastings, Battle and Bexhill all of which have train stations providing services to London amongst other locations.

Landscape

The land subject of these representations lies within the High Weald National Landscape but is well-screened by existing mature vegetation, some of which is Ancient Woodland and would therefore not be highly visible from wider ranging views. A landscape assessment has been undertaken which is submitted alongside these representations.

The landscape assessment confirmed that a scheme could be delivered that would not have a detrimental impact on the location within the National Landscape. It states that whilst the proposal would inevitably change the character of the site as it would take on a developed character, the site sits in a gap between The Vicarage and The Parlour/Church Place Farm, and development already extends along Vicarage Lane, which lies at the edge of the settlement. It states that 'The proposal is consonant with the existing settlement pattern; development traditionally extended along existing lanes,

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and this form of development is more likely to conserve and enhance the character of the National Landscape than development based on culde-sacs.' This relates to a proposal where housing would face the road in a linear layout, reflecting the building line to the northwest.

It is therefore clear that whilst the character of the field would change if developed, it would not necessarily have a negative impact and could be designed in a way to work well within the wider context. The report goes on to state that the surrounding context includes the church, Church Place Farm and Vicarage Lane, which together create a sense of local identity. Whilst there are some views to the surrounding countryside the site lies at the edge of the village, and there is a settled character. It confirms that a linear infill development at this site would not disrupt that character, confirming that 'the locally distinctive features mentioned above would remain in place and would continue to contribute to the character of the National Landscape. The church and churchyard form a focus for the southern part of the village, but it is important to note that the churchyard is effectively contained within the settlement and is overlooked by existing housing. Vicarage Lane is a characterful historic route. Historic lanes however are not necessarily undeveloped. Development tended to occur historically along existing routes, and this can be part of their character, as is the case with Vicarage Lane.' The assessment demonstrates that new development does not need to automatically be considered inappropriate or detrimental purely due to its location within the National Landscape and or due to the proximity to heritage assets, which are discussed more below.

Heritage

Westfield does not feature in the Council's Heritage Background Paper. Paragraph 215 of the NPPF states that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use. The site subject of these representations is well screened from views of the listed church by existing vegetation along its southern boundary. Whilst it is acknowledged that the extent of screening is likely to change seasonally, the heritage assessment states that the church is of squat design and its tower is relatively short. It therefore does not function as a landmark building within its immediate landscape and cannot be perceived in medium and long-distance views.

It goes on to state that due to the landscaping and boundary treatment of the churchyard, as well as the presence of graves and other objects associated with the church, it can be argued that the setting of the church is restricted to the churchyard itself, and that the surrounding roads, Churchfield to the north, the A28 to the east, and Vicarage Lane to the south and west, fracture the setting of the church from its wider

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context. Additionally, this wider context of the church has been compromised by later development, especially to the east and north. Any historic (functional or ownership) association of the church with the Church Place Farmhouse or the Vicarage has been lost, and these buildings are no longer appreciated together.

The submitted heritage assessment also considered the setting of Church Place Farmhouse which it concludes has been compromised by a number of modern additions within its immediate setting, with the modern buildings acting as a visual buffer between the proposed development site and the listed building. On this basis, the contribution the development site makes to the setting of Church Place Farmhouse is considered to be minimal.

This confirms that the proximity to the Grade 1 listed church and the grade 2 listed farmhouse should not be a reason to discard this site from the emerging local plan, despite the draft plan identifying heritage assets as a barrier to delivering the required housing within the district in the local plan period.

Conclusion

Professional reports have already confirmed that small scale housing could be delivered on the site without having a detrimental landscape or heritage impact and would have no impact on the Ancient Woodland assuming 15m buffers are retained, which is entirely achievable. The site is flood zone 1 and not within an identified protected habitat. Therefore, all the barriers to delivering the true housing needs identified by the council have been demonstrated to not apply to this site. In light of this, and the fact the site immediately adjoins the settlement boundary of a sustainable settlement identified for growth, there is no clear planning reason for not allocating this site for housing in the emerging local plan. Small-scale development on the submitted site would relate well to the existing built form of Westfield and would be well-screened by existing development and swathes of ancient woodland.

/ trust that the enclosed information is clear and / look forward to receiving confirmation of receipt of this submission.

In the meantime, should you require any further information, please do not hesitate to contact me.

Yours faithfully

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Harriet Richardson BA (Hons) MSc MRTPI

Enc. Heritage Assessment

Landscape Assessment

APPENDIX 1

Land proposed for immediate allocation

z Beeches LB

Fairways 28.3m Path Rowane Greensleeves Play Churchfield Pump Cottage Area 0 Watendlath Vicarage Gas Gov Lane Path (um) Path St John the Church Lane

Church View Ba Church 31.4m . Westfield The Vicarage Tennis Club Shelter Hall Play Area 37.4m Westfield Recreation Ground War Memorial "

40.3m Jubilee Tree Champagne 5 Pond Pippins

The Parlour

/ Church Place Barn Pond

Church Place Farm

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8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

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.

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.

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.