I wish to object to the proposed allocation ID2 (Land at Street Field) on the grounds that the Plan has not adequately demonstrated that the site is either deliverable in the manner envisaged or sustainable, particularly when considered cumulatively with the already-permitted development at ID1 on the same stretch of Main Street.

Access and hedgerow retention

The allocation requires the retention and enhancement of the existing hedgerow along the western boundary with Main Street, except for the removal of a “short section” to facilitate access. However, the Plan provides no evidence to demonstrate that this assumption is realistic.

The hedge lies very close to the carriageway. Experience from the recently approved ID1 site (Land South of Elmsmead) indicates that the local authority applies Manual for Streets visibility standards on this section of road. If similar standards are applied at ID2, achieving compliant visibility splays would be likely to require the removal of a substantial length of hedgerow, potentially far in excess of what could reasonably be described as a “short section” or as being “minimised”.

In addition, the police consultation response for the ID1 development (Conkers), on the same stretch of road, includes explicit advice that planting should not impede natural surveillance and recommends low shrub heights (around 1m) where good visibility is required, in line with Secured by Design principles. The ID2 allocation assumes the retention of a tall, dense hedgerow along a public-facing boundary and potential access point, but does not explain how this would be reconciled with either highway safety requirements or crime-prevention advice.

This creates an unresolved tension between:

highway safety requirements,

crime prevention and natural surveillance principles, and

the stated intention to retain and enhance an existing hedgerow.

The allocation relies on what could be described as overly optimistic or “hopeful” assumptions, deferring the resolution of these conflicts to a later stage without demonstrating that they can realistically be resolved. This raises concerns about the effectiveness and deliverability of the allocation as currently framed.

It is also relevant that this hedgerow forms part of a historic field boundary, identifiable on historic mapping, such that its loss or substantial alteration would represent irreversible harm that has not been properly assessed at the plan-making stage.

Sustainability and proportionality

The sustainability of the proposed allocation is also questionable, particularly when considered cumulatively with ID1.

Iden is a very small village, with a population of approximately 245–250 at the last census. The addition of around 15 dwellings at ID1 and a further 10 dwellings at ID2 would represent a population increase in the order of 20% over a relatively short period, without any corresponding increase in local services, employment opportunities or infrastructure.

Local employment opportunities are extremely limited, public transport provision is weak (with bus services operating at roughly two-hour intervals), and there are no realistic alternatives to private car use for most journeys. Cycling to Rye is not a viable option for many residents due to the condition and character of the intervening rural roads, including poor surfacing, lack of street lighting and safety concerns.

Taken together, these factors suggest that additional housing at ID2 would be highly car-dependent and poorly aligned with the economic, social and transport dimensions of sustainable development set out in national policy. The Plan does not adequately demonstrate that this scale and pace of growth in Iden represents sustainable village development rather than a disproportionate increase driven primarily by housing numbers.

Conclusion

The Plan has not shown that allocation ID2 can be delivered in accordance with its own requirements, nor that it represents a sustainable or proportionate form of growth for a settlement of Iden’s size, particularly when combined with the already-permitted development at ID1 on the same section of Main Street.

The proposed site ID2 is of concern. Entrance to proposed ID1 is in conflict with ID2. There is a Covenant in place to protect existing properties in Playden Lane from noise and disruption. Contrary to the detail of the published plan, these existing houses are on the southern not the eastern boundary. The roadway is not of sufficient width to accommodate a footpath and maintain the existing hedgeing. Current services are barely sufficient for the current population. Iden is referred to as 'linear development' but Elmsmead and Parkwood, the last developments, are not linear. Iden has no dentist, school or doctor's surgery meaning that extra pressure will be exerted on Rye. ID2 is sloping and liable to flooding, in addition, any ecological survey will identify the presence of protected wildlife. Will a developer be able to provide 'affordable housing' as required by RDC (ID1 has already broken this requirement)?

Please see attached for full representation:

- Full representation on Draft Rother District Local Plan 2025-2042 Consultation (including underlined text and hyperlinks that do not appear in text copied out below)
- Supporting document: Southern Water input to Rother District Council’s 2026 IDP review
- Supporting document: IDP feedback provided for the Regulation 18 consultation deadline 23rd July 2024

Q5 We attach our separate IDP response to Rother as part of our feedback to this Regulation 18 consultation on the Local Plan, requesting update of the IDP in accord with the information and explanations provided. This also includes our feedback from the previous 2024 Regulation 18 consultation, in addition to a full explanation of how Southern Water plans investment for adopted local plans. Included within this explanation are our key AMP8 (2025-2030) investment plans for the Rother district. Some plans extend into AMP9, but for the reasons we explain in our IDP response, most AMP9 schemes are not known at this time.

There is considerable investment planned for the district in this 2025-2030 AMP8 period, supported by a range of technical disciplines. This represents the latest investment information and therefore supersedes the DWMP content referred to (as this DWMP work was concluded in 2023).

Q8 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q9 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q10 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q17 Q17 - all BX sites.

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording to all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to critical assets running beneath sites.”

Southern Water’s initial checks indicate that a number of the new/changed sites (BX6, BX7, BX22, 23, 24, 27, 28, BX31, 34, 36, 37, 38, 39 and BX41) may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and all those we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BX9 and may require easements or diversion. For this site, and any we’ve previously requested layout wording please include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q19 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

26 CR1 to CR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

However, we note that for site CR2 in particular, there is no wording in the site allocation policy to address the site’s proximity to an operational wastewater treatment works. In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site CR2 is within 500m of Battle wastewater treatment works and we therefore request the additional wording –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

28 GU1 & GU2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for site GU2 at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Southern Water infrastructure crosses GU2 and may require easements or diversion.”

30 GU4 & 5

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site GU5 and may require easements or diversion. For GU5, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

31 GU6

Southern Water has identified no constraints for this site at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

32 IK1&2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site IK1 and may require easements or diversion. For IK1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

34 WS1 WS2, WS3 WS4 WS5

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that sites WS2 and WS3 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site WS3 and may require easements or diversion. For WS3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

36 BT1 to BT11 (BT3, BT4, BT5, BT6)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to this site is within 500m of Battle wastewater treatment works and we therefore request the additional wording – The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

Southern Water’s initial checks indicate that sites BT1, BT2, BT7, BT9, BT10 and BT11 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BT11 and may require easements or diversion. For BT11, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

38 CT1 CT2 CT3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure may cross sites CT2 and CT3 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

39 NE1 & 2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

40 SD10 SD11 (SD1 to SD9)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site SD11 (and as previously advised the for the existing site allocation SD7) is within 500m of Sedlescombe wastewater treatment works and we therefore request the following additional wording in these policies–
The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

42 BC1 (BC2) BC3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site BC3 and may require easements or diversion. For BC3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

43 (BR1) BR2 BR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

44 CM1 to CM3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

45 (ID1) ID2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site ID2 and may require easements or diversion. For ID2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

46 NR1 and NR2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for this site (NR2) at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

Additional policy wording is needed for each site to address it’s proximity to operational wastewater treatment works. The proposed boundary of each site is within 500m of an operational wastewater treatment works (Mill Corner Northiam WTW, and Quickbourne Lane Northiam WTW) and we therefore request the additional wording for each site policy –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses site NR2 and may require easements or diversion. For NR2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

47 PE1, 2 & 3 (PE4 & PE5)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

49 (RY1 to RY1, RY7&8) RY5, RY6 & RY9

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that sites RY5 and RY9 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses sites RY5, RY6 and RY9 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

50 RH1

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

53 BW1 to 4

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that site BW1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Please note that Southern Water wastewater sewers cross all BW sites (BW1 to 4) and may require easements or diversion (so please note that whilst we agree that consultation with Southern Water will be required, it may not be necessary for the developer to deliver a package treatment plant as currently stated in part Xi of the policy. Were the developer to want to deliver such plant they will first need to consult with the Environment Agency). For these sites, and any we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

54 BWC1 and 2

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

55 EC1 to 3

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site EC1 and may require easements or diversion. For EC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

56 (HG1&2) HG3 & 4

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that site HG4 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses site HG3 and may require easements or diversion. For HG3, and any sites we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

57 RB1, RB3, RB4 (RB2, RB5) to RB6a & RB6b

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to sites R3 and R4 (and also as will have been previously advised the boundary to existing site allocation RB2) are all within 500m of Robertsbridge wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses sites RB3, and RB5 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

58 SC1 & 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site SC1 and may require easements or diversion. For SC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

59 FW1 to FW3

Southern Water’s initial checks indicate that site FW2 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure crosses site FW2 and may require easements or diversion. For FW2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

60 TC1 (or 2)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water’s initial checks indicate that site TC1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure also crosses site TC1 and may require easements or diversion. For TC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

62 SG1 or 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundaries to each site are within 500m of Stonegate wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Southern Water infrastructure crosses these sites and may require easements or diversion. For these sites please therefore also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q64 GYP1 to GYP6

Southern Water’s initial checks indicate that some of the GYP sites are proposed within 500m of operational wastewater treatment works. For example, the boundary to site GYP6 is within 500m of Robertsbridge WTW.

We therefore request Rother consult us on planning applications for all sites so that we can share the results of more detailed checks with the authority. Southern Water also request the addition of the following wording for all sites –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

And for each site proposed within 500m of operational wastewater treatment works (eg GYP6) please include the following additional wording;
“The layout of ‘sensitive residences’ for any site allocation within 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Q69 Any other issues or comments?

All site allocations should be proposed in locations where utilities can provide for the forecasted needs of the development without prejudicing existing or future utility provision necessary to support growth. Southern Water therefore requests the following additional policy wording in the Regulation 19 draft of the Local Plan:
The utility network should be protected and development proposals that would compromise existing utilities infrastructure, or encroach on future connections for utilities, will be refused. Opportunities should be sought to safeguard the provision of utilities wherever possible.

Main Street in Iden is a through run between Tenterden and Rye so there is a lot of traffic. The proposed entrance to both ID1 and ID2 are on bends and clear vision is very limited. Iden is also a very old village in the High Weald National landscape it’s important to protect its character. There are 5 listed buildings in the vicinity one right beside the proposed entry for ID1. The disruption to local housing during development will be considerable.

1.The entrances to the proposed sites are opposite each other on a busy road and it will be hazardous to pull out onto the main road. 2.There will be an impact on several listed buildings which are very close to the proposed sites and also detrimental to the 'Domesday' character of the Village which is mentioned on the village sign- it is important to preserve the character of the village.
3. The village has no gas supply and very limited public transport so there isn't sufficient infrastructure for the development.

1. Junction Main Street/Playden Lane is already dangerous because of poor visibility when emerging. This is an increasing problem. The development would exacerbate it.
2. Street Field is/has been a sheep grazed orchard. It has never been cultivated. The plant ‘Birds’ Foot Trefoil’, which is plentiful, is an indicator of ancient meadow land. Orchids have grown in the field in some years. Development would be a severe blow to preserving the natural landscape of the High Weald area.
3. Iden has a very limited bus service, an over-subscribed primary school outside the village, frequent power cuts and water outages, no gas supply and an extremely badly maintained main road! Further development here would also upset the balance of older (some listed) housing and new build at this end of the village.

In Iden we cannot understand why the brownfield site (former apple farm)has been rejected twice. We feel strongly that this would be a far safer and more sensible site. Some years ago we were told that the council would be happy to discuss proposed building in the villages to ensure everyone was happy. To my knowledge no one has been to Iden and we are NOT happy. Speed is a big problem with limited vision around bends. Pavements are regularly used by walkers, mother with strollers, young children and ponies from the riding school. This is a dangerous road. Why on earth is a second site being proposed almost opposite the Conkers site, is this good planning from Rother? We are a small rural village with few facilities. would Rother Planning please give some thought as to how all this extra traffic on Main Street would affect our village life.

I object to the plan proposing to offer residential building developers Site ID 2, Street Field, Main Street, Iden.
In 2024, I objected and do not expect my submission to be swept away even though the Council appears to have done so.
For many years Iden Parish Council issued local plans setting boundaries which do not include development on fields lying east of Main Street because they embed the charm and identity of our heritage. and obscure our historic farming fields
Development of ID2 would harm the impact this view has upon visitors and residents alike.
To interfere would be to destroy.
With regard to ID 1, it seems that your Planning Committee approved development, albeit somewhat half-heartedly, I suspect.
The overwhelming view of future development in Iden is that Orchards Farm Wittersham Road Iden Rye East Sussex TN31 7XB would be acceptable.

I wish to object to the proposed allocation of site ID2 Street Field (West) Iden for 10 dwellings within the emerging Rother Local Plan 2025-2042.
Whilst I recognise the need for new housing, the allocation of this site raises significant concerns relating to landscape protection, heritage impacts, cumulative development, and highway safety.
1. Impact on the High Weald National Landscape.
Iden lies within the nationally protected High Weald National landscape. Under the National Planning Policy Framework great weight must be given to conserving and enhancing landscape and scenic beauty in such designated areas.
Street Field forms part of the open agricultural landscape that contributes to the rural character and historic field pattern of the High Weald. Development of the site would introduce suburban housing into a currently open field, eroding the rural edge of the settlement and diminishing the landscape qualities that the designation seeks to protect.
2. Harm to the Settings of Listed Buildings
The proposed site lies directly opposite three listed buildings Eastview, Danesbury and Deacons. The field also backs onto the curtilage and rural setting of two further listed buildings on Playden Lane: Lambs Orchard and Mr Catts House.
These heritage assets currently enjoy a rural agricultural setting which contributes significantly to their historical significance. Development of the site would introduce modern housing immediately adjacent to and opposite these buildings, resulting in harm to their settings.
The National Planning Policy Framework requires great weight be given to the conservation of designated heritage assets and that any harm to their significance should be clearly justified. In this case the allocation of ID2 risks causing avoidable harm.
3. Cumulative Impact with Proposed Development at ID1 (Conkers)
There is already a proposed development of 16 dwellings at site ID1 (Conkers) on the opposite side of the road.
If both sites are developed this would result in approximately 26 new dwellings concentrated within a very small area of the village. Such a level of development would significantly alter the character of the village and extend the built form along this stretch of the road in a way that appears suburban rather than rural.
The combined impact of these two sites has not been adequately considered within the site allocation process.
4. Highway Safety and Traffic Concerns
Main Road through Iden is a narrow rural road that already experiences traffic constraints typical of historic rural villages.
If both ID1 and ID2 are allocated, there could be two new access points opposite each other serving a combined total of 26 dwellings. This would significantly increase the number of vehicle movements entering and exiting onto Main Road.
Additional traffic movements from residents, visitors, and service vehicles would increase the risk of congestion and conflict on a road not designed for this level of access activity.
The cumulative impact of these developments on highway safety should therefore be carefully reconsidered.
5. Loss of Agricultural Land and Village Edge Character
Street Field is currently agricultural land that forms part of the historic rural landscape surrounding Iden. It provides an important transition between the built village and surrounding countryside.
Development would erode this transition and weaken the clear settlement boundary leading to unnecessary encroachment into the countryside.

ID2 .
We think this is a step in the right direction. We are very lucky to have a minimal amount of housing being proposed compared to our neighbouring villages. With this increase in houses, will come people and supporters for our village assets, such as the Bell Pub, Iden Stores, All Saints Church, the Village Hall and the Bowls Club. Hopefully in time this will also help with the support we need for the pavilion and the children's play area. In the past this village was always known for its friendly and busy community with several big events. Unfortunately as time has moved on, we are all getting older and so a lot of the community based events have dropped to the side-lines. As long as the building developers are sensitive to the environmental concerns and that the road onto Main Street is well laid out with maximum visibility to crossing traffic - again I can not see there being a problem. As for any impact on existing property I am only concerned for Number 4 Main Street - which would boarder the proposing development site - and I would hope that their thoughts and feelings and comfort while the housing is being built are given priority. It is very unlikely even with a fantastic bus service that people in this generation would not have at least 1 car per household - which is the way of the world and I would hope that off road parking would be a large part of the proposal. Also I would like village detectorists to be allowed to check the site before works start - as we are a village full of history. KEEP THIS VILLAGE ALIVE

ID2 . We think this is a step in the right direction. We are very lucky to have a minimal amount of housing being proposed compared to our neighbouring villages. With this increase in houses, will come people and supporters for our village assets, such as the Bell Pub, Iden Stores, All Saints Church, the Village Hall and the Bowls Club. Hopefully in time this will also help with the support we need for the pavilion and the children's play area. In the past this village was always known for its friendly and busy community with several big events. Unfortunately as time has moved on, we are all getting older and so a lot of the community based events have dropped to the side-lines. As long as the building developers are sensitive to the environmental concerns and that the road onto Main Street is well laid out with maximum visibility to crossing traffic - again I can not see there being a problem. As for any impact on existing property I am only concerned for Number 4 Main Street - which would boarder the proposing development site - and I would hope that their thoughts and feelings and comfort while the housing is being built are given priority. It is very unlikely even with a fantastic bus service that people in this generation would not have at least 1 car per household - which is the way of the world and I would hope that off road parking would be a large part of the proposal. Also I would like village detectorists to be allowed to check the site before works start - as we are a village full of history. KEEP THIS VILLAGE ALIVE

Revised Regulation 18 Representation
This representation should be read as supplementary to my earlier submission on the Regulation 18 consultation. It addresses additional matters and provides further detail on the issues previously raised.
Site Allocation ID2 – Land at Street Field (West), Iden
I wish to object to the proposed allocation ID2 – Land at Street Field, Iden at this Regulation 18 stage.
I recognise the significant pressure on Rother District Council to allocate housing land, and I am aware from recent decision-making locally that the Council is placing considerable weight on housing delivery in the context of a substantial five-year supply shortfall. However, this makes it all the more important that site allocations are genuinely deliverable, properly evidenced, and consistent with key national and local policy constraints.
In my respectful view, ID2 is not currently justified as a suitable allocation, and the draft requirements contain fundamental unresolved conflicts.

1. Highway safety and deliverability – hedgerow retention versus visibility standards
The allocation requires that the existing hedgerow along the western boundary with Main Street should be “retained and enhanced”, with only a short section removed to provide access and sightlines, which should be minimised.
In practice, this requirement appears unrealistic. The hedgerow is substantial (approximately 2 metres high) and lies immediately adjacent to the carriageway. Experience from the permitted ID1 development on the same stretch of road suggests that Manual for Streets visibility standards are applied locally.
Achieving safe access visibility splays is therefore likely to require removal or significant reduction of a far longer section of hedge than envisaged in the allocation wording. This creates a direct tension between the Plan’s stated landscape/boundary retention requirement, and the highway authority’s likely safety requirements.
Given the NPPF’s clear position that development should only proceed where safe access can be achieved (NPPF paragraph 116), this is not a minor detail to be left to later stages. It goes to whether the allocation is genuinely deliverable as drafted.

2. Police design advice and further pressure on boundary removal
Consultation responses from Sussex Police on the ID1 site (Conkers) emphasised the importance of boundary treatments and landscaping that do not impede natural surveillance, with planting kept low where visibility is required.
A tall, dense hedge at the principal access point to ID2 may raise similar concerns, potentially creating additional pressure for hedge removal or reduction beyond what the allocation suggests.
This reinforces the concern that the Plan is relying on aspirational wording about hedgerow retention that may not be achievable once technical consultees are engaged.

3. Heritage Impact – The Site Is Surrounded by Listed Buildings
The heritage sensitivity of ID2 is substantial and has not been properly assessed.
The following Grade II listed buildings lie immediately opposite or directly adjoining the site:
On Main Street (directly opposite the frontage):
East View (1234895)
Deacons (1234755)
Danesbury (1234896)
Adjoining the southern boundary (rear gardens on Playden Lane):
Lamb’s Orchard (1234905)
Mr Catt's House (1275977)
ID2 is therefore not simply “near heritage” — it is effectively surrounded by designated heritage assets.
Under Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990, the Council must give special regard to preserving the setting of listed buildings. That duty applies at plan-making stage as well as at application stage.
The NPPF requires great weight to the conservation of heritage assets. Harm to setting must be clearly and convincingly justified.
No proportionate heritage setting assessment accompanies the allocation. There is no analysis of
the cumulative impact on five listed buildings,
the effect of suburban frontage development opposite a cluster of historic properties,
the loss of the existing transitional rural character contributing to their setting.
Allocation without that assessment risks embedding harm into the Plan before it has been properly evaluated.
Given the concentration of heritage assets, this omission is serious.

4. High Weald National Landscape – Statutory and Policy Weight
The site lies within the High Weald National Landscape.
NPPF paragraph 189 requires great weight to be given to conserving and enhancing landscape and scenic beauty in National Landscapes.
ID2 forms part of the rural settlement edge. Development would:
urbanise the Main Street frontage,
erode characteristic hedged enclosure,
extend built form into sensitive countryside transition.
The Sustainability Appraisal identifies negative or uncertain effects in landscape terms. In a nationally designated landscape, that is not a minor matter.
The Council must demonstrate that allocating this site — rather than less sensitive alternatives — is justified and necessary. At present, that case has not been made.

5. Sustainability Performance
The local authority's own Sustainability Appraisal does not identify ID2 as a strong-performing site and scores Iden “overall as having low sustainability”
It does not materially enhance settlement sustainability and increases reliance on private car use.
The suggested mitigations , “Improve public transport” and “seek opportunities for shops” are not measures a developer of 10 dwellings can realistically deliver.
If the Council is pursuing a strategy of concentrating development in more sustainable locations, allocation of ID2 appears inconsistent with that objective.
The burden is on the Council to justify why this site is preferable to more sustainable alternatives.

6. Deliverability and Legal Constraints
Residents are aware that part of the site is subject to a restrictive covenant benefiting adjoining properties on Playden Lane.
Correspondence from a developer confirms that:
development would contravene the covenant,
modification or discharge would be required,
financial consideration has been offered to secure its removal.
While restrictive covenants are private law matters and not determinative in planning terms, they are directly relevant to whether a site is genuinely available and deliverable within the plan period.
If development depends upon:
agreement from multiple covenant beneficiaries, or
potentially complex legal proceedings to modify the covenant,
then there is clear uncertainty as to timing and achievability.
The Council should confirm whether this legal encumbrance has been factored into its deliverability assessment. If it has not, the allocation rests on incomplete evidence.
At Regulation 18 stage, the Plan should not rely upon sites whose deliverability is materially uncertain.

Conclusion
ID2 presents:
unresolved highway safety conflicts,
demonstrable and unassessed heritage sensitivity involving five listed buildings,
location within a nationally protected landscape requiring great weight,
and credible uncertainty regarding deliverability.
In its current form, the allocation of ID2 is not evidence-led and cannot be regarded as justified.
I request that the Council remove ID2 from the emerging Local Plan.

It is difficult to understand why Rother Planning dept. continues to push for ever more homes in East Sussex when South East Water said recently that they could not supply all these new homes with water, the infrastructure is just not there. A few years ago we were told
that in Iden that there was not enough adequate infrastructure to supple any more homes here, nothing has changed. Southern Water has enough problems supplying this area already. The planning department should take this into account before allowing more development, espcially two sites in Iden almost opposite each other, very bad planning.

Objecting on ID2.

East view has bad visibility from the short drive onto Main Street. The conkers site will give yet another entry and with the proposed ID2 building the traffic on a small country road will be extremely dangerous.
10 houses opposite east view would mean a lot more light pollution and would ruin the identity and character of a domesday village.
There is no mains gas in the village and the Closest hospitals, doctors etc are at breaking point.

Regarding proposals for area ID2;
1. Is there a need for 10 houses on this green field site?
Have brown field alternatives been considered?
2. Has the proposal considered new local authority housing at affordable rents to replace former LA housing in Elmsmead and Park Wood sold into the private ownership?
3.The addition of around 100 extra inhabitants including ID1 would overwhelm the already inadequate drainage and sewerage system.
4. Poor quality road B2082 with no pedestrian footpaths to the south of Playden lane junction and poor sight lines to cross to pedestrian footpath northwards to village centre would constitute a hazard risk.
5. Loss of rural outlook for existing domestic and some listed property would have an adverse impact on the High Weald landscape.

I have concerns that our main road will be impacted by any development. There is really only 1 road through the centre of Iden and this plan proposes building directly next to it

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

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

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

Development Strategy

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Major Development

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

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

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

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

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

Proposed draft Site Allocations

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

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

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

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

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

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

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

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

Densities

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

Site Specific Policies

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

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

Individual proposed sites comments

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

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

Legislative Requirements

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

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

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

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

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


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

I object to ID2. My concerns are, it has poor visibility for entry and exit to the site, especially with another proposed building site opposite. There is not any allocation for affordable housing. Iden lies within the high Weald national landscape, where conserving Beauty of open countryside is very important.

If proposed new plans for ID2 go ahead houses along Main Street will be sandwiched between two new developments of houses. Iden is a village going back to domseday times and the whole definition of a village is, it is small and preferably has a pub, church and a shop which Iden has. We turned down a gas supply as we turned down street lights, we did not want them. We wanted to know our neighbors and our wildlife. Some good neighbors bought our lovely playing field and the bowls green was also donated, more good neighbours bought the land where we now have Elmsmead and Parkwood. Quite apart from practical reasons like out medical Centre can barley cope we have no school and what about drainage?

I strongly OBJECT to this ID2 development as:-
a) Another new access onto Main Street would be dangerous and the access for ID1 has yet to be constructed almost opposite.
b) The existing BUS service is limited and infrastructure at capacity.
c) No "affordable" housing is mentioned.
d) Permanent change to the setting of FIVE LISTED buildings in Main Street.
e) IDEN is a "DOOMSDAY" village and it's character will be impaired.
f) Lack of thought to "High Weald" landscape.

I OBJECT to this RIBBON development ID2 as this is a DOOMSDAY Village and cannot understand why you want to encroach on Greenfield sites when the main infrastructure is insufficient, when there are services to Brownfield sites already in place.
As far as access to Main Street is involved being virtually opposite to ID1 making visability even worse than now.
The Construction Taffic is likely to have detrimental effects to the road and buildings, particularly those listed.

Dear Sir or Madam,

I am writing to object to the proposal to build ten new houses along Main Street, Iden.

New housing can and should be provided by making better use of the large stock of under‑used and vacant buildings across the country, bringing them back into productive residential use instead of consuming more greenfield land. Converting and repurposing existing buildings protects historic farmland, avoids unnecessary loss of countryside, and supports more sustainable patterns of development in places that already have services and infrastructure. This approach also helps to maintain the separate identity and rural setting of small villages, rather than allowing them to sprawl into surrounding fields.

The application site forms part of the historic farmland that frames Iden and is fundamental to its character as a small, largely unspoilt Sussex village. Allowing a modern estate on this land would tip the balance towards Iden becoming yet another rural settlement swamped by standardised, profit‑driven housing, eroding the special qualities that current planning policy is meant to safeguard. The village’s appeal and sense of place depend on the close relationship between its traditional built form and the surrounding open fields, not on continual outward expansion.

The development would also cause serious harm to the setting of five Grade II listed buildings in and around Main Street. These listed properties gain much of their significance from their historic relationship with open farmland and the traditional village streetscape. Inserting a dense cluster of new houses into this setting would fundamentally change how these buildings are experienced, contrary to the statutory duty to give special regard to preserving listed buildings and their settings.

Traffic and highway safety are further concerns. Main Street is already one of the most neglected roads in East Sussex, with a poor surface and frequent potholes and no proposal to resurface. Adding traffic from ten new homes, alongside heavy construction vehicles during the build phase, will clearly worsen road conditions and raise safety risks for pedestrians, cyclists, and existing residents on a route that already struggles to cope with current usage.

Crucially, there is already a separate scheme for 15 new houses on land at Main Street, Iden, which has been progressing through the planning process. That level of growth is already a significant change for a village of Iden’s size and character and more than meets the planned housing contribution for the settlement in the current plan period. In this context, the additional ten houses now proposed are not necessary to meet locally identified need and would represent clear overdevelopment.

For these reasons—the availability of better options for new homes through re‑use of existing buildings, the loss of historic farmland and village character, the harm to the setting of multiple listed buildings, the impact on an already substandard road, and the fact that 15 new houses are already planned for the village—I respectfully request that the Council refuse this application.

Regards
Lucy Jordan

Sight ID2
Highway safety. Visabilty is limited at the junction with Playden lane. There is no parking. I think that the whole development would be a danger.
Impact on 5 grade listed buildings opposite or next to field.
Harm on the high Weald landscape. This is a place of natural outstanding beauty and would impact on it greatly.
Limited public transport, no mains gas and few services.
Not much genuine local need for these houses.
The proposal refers to biodiversity measures but no detailed ecological assessment has been published

Ref ID2:
Increasing the number of houses would add a lot more vehicles to a narrow road and add considerable risk to the existing houses, especially at the junction with Played Lane which has limited visibility. As the Council itself says new housing would be heavily car dependent. Existing houses along this street already have problems with delivery vehicles and parking their cars, and adding more houses would considerably increase these problems.
The High Weald Landscape is increasingly threatened with development. If built, these houses would encroach on open countryside and transform the character of the southern end of this Domesday village. Hedgerows would be destroyed. There are five listed buildings sitting across from or next to the proposed site and new buildings would completely alter their setting. No amount of mitigation could replace the open countryside that would be destroyed.

On 23rd July 2024 I submitted a lengthy submission to you in response to the HELAA proposals regarding this strip of land setting out a number of detailed objections. I note that the current proposal ID2 is identical to that contained in the 2024 HELAA document (IDE00010) which leads me to the inevitable conclusion that Rother Planning Department has decided to proceed with this proposal regardless of the views of local objectors and without needing to address valid reasoned objections. I am nevertheless resending objections in the post, as they remain as before.

With regards to the planned development in Iden my objections are as follows
1 The safety of the junction with Playden Lane with the excess traffic
2 The properties would not be ‘affordable’ housing and will consequently be purchased as second homes or for use as
Air b and b’s as is becoming common place in Iden and therefore add absolutely no benefits to the village.
3. The Main road into Iden from Rye is virtually completely wrecked and is unfit to drive on now, therefore with added
Construction traffic it will be rendered in driveable.

Objection to ID2.

The ID2 site entrance does not appear to provide safe access/egress, due to the limited visibility and uncontrolled traffic speed (like other driveways and side roads in Main Street). This could create a danger point with 10-20 additional cars pulling in and out of the site regularly, which would also create more damage to an already poor quality road surface.
Unless any proposed new buildings are kept strictly in-keeping with the surrounding area, the heritage of nearby listed buildings may be permanently affected. Development on the ID2 site would also affect the heritage of the local area and landscape, including some of the less common or protected wildlife, like badgers (are there any plans to preserve the nearby ponds and pond-life too, like newts).

I'm not sure how a development like this could ever be approved, in an AONB and, where the residents object.

This proposed development is a further example of extending the village boundary into green belt land. and should be opposed.
The site line from the site onto the road is dangerous and will further make that end of the village to cluttered with road junctions.

We wish to object to the inclusion of ten or more houses on the site in Main Street, Iden known as ID2.
Whilst we accept that, eventually, there may be some housing development on this site we object very strongly to the scale of the present proposal for the following reasons. Main Street, Iden is almost completely characterised by individual detached family houses, many with quite large gardens. This draft plan implies that there would probably be a solid row of 10 or more terraced, or otherwise linked properties, completely out of character with almost all the existing homes in the village neighbourhood. In addition, such a development would detract from the setting of numerous listed buildings, several of which are of considerable architectural interest and merit.
Please may we ask for this element of the Local Plan to be re-considered on the grounds that it currently represents a massive over-development of the land available in this particular village situation.

Building that number of houses in a linear fashion is not in-keeping with any other building development in the village (I live in one of the two small terraces of four homes), uses a green field site when brown field sites aren't being considered and ribbon development would spoil the rural aspect of Iden (see Peasmarsh where no fields are visible from the road) which is not in keeping with our being in the High Weald National Landscape. Removal of the any part of the hedge for access and a pathway is an unacceptable loss of habitat in our village. I am also concerned that any "affordable housing" will not come to fruition and would like assurance that none will be second homes.