The NR2 site I think makes sense. My comment relates to the builders yard site of 0.94 acres that is immediately adjacent to this - just on the opposite side of Coppards Lane (what used to be Jewsons before it closed). This is currently freehold for sale. I accept that if this site were to be re-developed for other commercial uses that would create local employment opportunities in the village, this would have priority - but I suspect the site will sit unused now for many many years. It's too small and too remote from major centres of population locally for most distribution/retail investors (all reasons why Jewsons left) - so I think the local plan should reflect a realistic assessment of its future commercial potential. If the most likely scenario is for this to remain undeveloped, this should surely be considered for residential development ahead of (or at least alongside) NR2. It is brownfield site, covered in concrete hardstanding - so transformation into residential with garden space would have environmental benefits in its own right, especially compared with NR2 which requires loss of Greenfield land. The Builders yard I mention is just under half the size of NR2, so could not replace NR2 entirely but would seem appropriate for c. 10-12 dwellings.

My comment is regarding site NR1.
I live in Hillyfields which is opposite the northern corner of the proposed development.
The road junction here is very busy and somewhat congested at morning and afternoon drop-off & pick-up at the nursery and primary schools. Vehicles park all along the A28 on both sides and B2088 on one side for about half an hour each time, which causes congestion and resticted vision for all traffic, both those for the school and vehicles just passing through.
We try to not drive in and out of Hillyfields at these times as our oncoming traffic vision can severly restricted in both directions.
This traffic situation should be actually viewed at the peak times by anyone planning this development.
A new road junction from NR1 exiting right into this area close to the triangular traffic island can only add to the risks for all road users. Installing a mini roundabout in place of the triangular traffic island would at least mean traffic from all directions has to slow down as no one would have priority.
In my opinion the new NR1 road junction should be at the southern end of NR1 and not the North.

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.

NR2
Policy Text
(6). Is not correct
It implies that NR2 is bounded by a hedge row to the north.
The northern boundary is a stock proof fence owned by the neighbour.

Northiam
NR2
- I object because the proposed development is outside the development boundary, which we have been held to in the past. Does this mean that they no longer exist, if so RDC should formally announce this.

- It distorts the symmetry of the village resulting in a significant distance from the village amenities i.e. school, recreation ground, doctors, church etc. I would have thought that something could have been done more centrally using unused properties or possibly a small portion of the village owned St Francis Fields.

- Any entrance to the site would have to be via Coppards Lane with the two notorious accident black spots at junctions to A28 and A268 both within a few tens of metres of any entrance.

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

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

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

Development Strategy

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Major Development

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

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

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

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

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

Proposed draft Site Allocations

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

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

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

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

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

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

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

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

Densities

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

Site Specific Policies

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

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

Individual proposed sites comments

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

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

Legislative Requirements

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

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

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

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

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


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

See attached.

These comments are made in respect of Rother District Council’s Local Plan Regulation 18 Consultation, taking into account the National Planning Policy Framework’s (NPPF) requirements which centre around the provision of sustainable development.
It is understood that the draft Local Plan Development Strategy and Site Allocations is based around a supporting evidence base, with all documents that it contains should have been available for the entire Regulation 18 Consultation period. However, the Housing and Economic Land Availability Assessment (HELAA) was not available for the entire period. This undermines clear and transparent policy making as required by the NPPF.
The draft Local Plan consultation began on 26th January for 8 weeks. The 2024 HELAA was only available to support the consultation for the first couple of weeks, with the latest updated HELAA being made available to the public on 11th February. In effect the 8 week consultation period has been shortened as all of the supporting evidence was not available to review for the entire period.
The NPPF at Paragraph 16 c) requires that “Plans should… be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;”
When preparing plan, Paragraph 32 states that “The preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.”
The draft Local Plan regulation 18 consultation has not been based on effective engagement, given that not all supporting documentation has been made available for engagement at all times; this fails the NPPF requirements.
Plan making regulations contained within The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended) specify that Local Plan, supplementary and evidence base documents need to be available for review for a period of at least 6 weeks. The HELAA was not available for review for 6 weeks, it was less than this required period.
When considering the housing allocations in Northiam the HELAA evidence base has consistently rejected described NOR2 site when reviewing call for sites due to its impact on the National Landscape, distance from the village and lack of access to services. The site assessment for NOR0026 at Egmont Farm in 2024 states: “This is a large field occupying almost the full length of Coppards Lane on its northern side. It is used as paddocks associated with development at the western end of the site. While the site is influenced by human activity, its relatively undeveloped nature, particularly at its eastern end, is important to the rural setting of the village. The whole site is separated from the main body of the village by Coppards Lane, and development here would extend the footprint of the village, to the detriment of the local landscape and character within the High Weald National Landscape. Furthermore, the site is some distance from services in the main village and lacks pedestrian connections to nearby bus stops meaning it is not ideally placed to encourage sustainable transport.”
In addition it is prudent to point out that this site is open to views from the north and has historically been open fields looking back through historic maps; it has always remained open as a countryside setting to the village. The fields are open and exposed to the wider landscape, with mature trees and field boundary along Coppards Lane, which would be harmed should allocation and housing development occur. The land is raised above Coppards Lane, making it even more prominent within the landscape. The site provides a countryside setting to the village and its development would appear as a prominent encroachment into the countryside. It is not adjacent to the limits to built development of Northiam and would represent development within the open countryside, which policy is against.
The NPPF stipulates that sustainable development is pursued in a positive way, both through plan making and decision taking, with a presumption in favour of sustainable development being at the heart of the Framework. Sustainable development is achieved through three overarching objectives; economic, social and environmental. An allocation at NOR will not achieve any of these objectives.
The economic objective is “to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;”
NOR2 is not located within the right place to support growth. It is located outside of the village with no access to services. This is echoed within the social objection, which requires development to “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being;”
NOR2 will not provide future residents with accessible services, given that the main reliance for these will be for a car. Alongside these objections is the overriding failure of the environmental objective “to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.”
Development at NOR2 would erode the High Weald National Landscape character, the village setting as it encroaches into the open countryside and would negatively impact the historic environment by developing historic field scapes that have been open (Early Post-Medieval fields AD 1500– AD 1599). It would also not provide development close to the village centre which offers amenities and services which would aid in mitigating and adapting to climate change; it would propose housing again where occupiers would be primarily reliant upon a car. This does not support a low carbon economy.
The NPPF goes on to say at Paragraph 11 that for plan making to apply a presumption in favour of sustainable development “a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas , unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
NOR2 would not promote a sustainable pattern of development, it would encroach beyond the village envelope, outside the LBD and within an area which is open countryside and provides a strong sense of place within the High Weald National Landscape. It is also apparent that NOR2 is an Early Post-Medieval fields AD 1500– AD 1599 which has always been open. These are an important aspect of the High Weald National Landscape which needs protection. NOR2 would not only encroach into an area of protected landscape within the countryside, it proposes to do so on a major development scale. The NPPF suggests that a National Landscape is a protected area which should restrict the scale, type or distribution of development in the plan area. Proposing to allocate a major development within the High Weald National Landscape therefore goes against plan making policies in itself, regardless of the statutory protection given to these landscapes.
Whilst it is accepted that Northiam as a whole and a large part of the District is located within the High Weald National Landscape, this dictates that careful decision and plan making is required and new development should be located within areas that are well enclosed, will not negatively impact upon landscape character, surrounded by housing within the limits to built development, brownfield land and are readily accessible. NOR2 is none of these things and would represent harmful encroachment into an open field area, highly visible within the protected landscape which is far removed from services.
When applying NPPF policy in relation to conserving and enhancing the natural environment, for plan making to create appropriate policies, Paragraph 187 states “Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);” Paragraph 189 goes on to clarify that “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues.”
The proposed allocation at NOR2 will not contribute to or enhance the environment, it will not protect or enhance a valued landscape which has and demands the highest level of protection in terms of landscape and scenic beauty. There are other opportunities for housing to be provided within urban areas, areas already enclosed by built form and not within the open countryside
Paragraph 190, albeit setting out the parameters for considering applications, states “When considering applications for development within National Parks, the Broads and National Landscapes, 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. Consideration of such applications should include an assessment of:
a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.” The same principle should be applied now; seek to avoid major allocations or development within National Landscape and ensure that needs can be met for this in another way.”
It is considered that a major housing allocation should not be provided where it simply cannot conserve or enhance the National Landscape. Development should be allocated close to the village centre within areas that are surrounded by housing that do no encroach into the countryside. Such allocations could be provided at NOR0022, NOR0036, NOR0027, NOR0031, NOR0020, NOR0018 and NOR0009 in smaller amounts. These are all central to the village, adjacent to or surrounded by built form and particularly NOR0036, NOR0032 and NOR0022 do not encroach into any countryside as they are completely surrounded by housing. These allocations would conserve and enhance the National Landscape as policy dictates at both the plan making and decision taking stage.
NOR0034, which is directly opposite NOR2 was and still is considered as part of the HELAA as being “The site is an open field with a strong rural character and sense of place. It is a probable medieval assart and adjoins a small area of ancient woodland. Adjoining development is largely screened from the site, meaning the site has a rural and largely unspoilt character, the only detracting feature being electricity lines crossing it. Development here at the scale considered through the HELAA would appear as encroachment into the countryside and would be harmful to the landscape and character of the National Landscape. Furthermore, the site is some distance from services in the main village and lacks pedestrian connections to nearby bus stops meaning it is not ideally placed to encourage sustainable transport.”
If an open field directly opposite the proposed allocated at NOR002 is considered as being inappropriate for development due to any allocation being an encroachment into the countryside, harmful to the landscape and character of the National Landscape, as well as recognising that the site is some distance from services in the main village and lacks pedestrian connections or access to sustainable transport, then exactly the same planning constraints, policy objections and principles apply to NOR2 given that it is in the same location. It is strongly suggested that different allocations are considered for Northiam that are closer to the village centre and smaller in scale, with larger and major allocations being more suited to urban and sustainable locations that are not situated within and in such prominent positions in the National Landscape.

NR1 and NR2 - While I support providing homes for people and families to stay in the rural village of Northiam, 24 sites were put forward in the Call for Sites but only two chosen, when I believe many sites were as good, if not better, than these two. While central government wants to 'Build build build!' - it simply doesn't happen further down, local government puts the brakes on everything

In respect of NR2- Copy of representations will be sent via the email

I object to Policy Reference. NR2 Egmont Farm for the following reasons the site is outside of the village boundary and remote from the village services and facilities there are other sites closer to the village centre which have been considered and discounted these sites should be reconsidered the site is within the High Weald National Landscape and is not approiate for development of 25 houses as it would impact on the rural character of the area concern over suitable access to site and amount of traffic on minor road

I would like to support the decision that site N0R 0023 Ballard Station Road Northiam has been considered unsuitable for development This large site outside of the village boundary would not be appropriate for development due to its sensitive rural nature .location within the High Weald Special landscape and impact on the landscape of the Rother Valley.

These comments are made in respect of Rother District Council’s Local Plan Regulation 18 Consultation, taking into account the National Planning Policy Framework’s (NPPF) requirements which centre around the provision of sustainable development.
It is understood that the draft Local Plan Development Strategy and Site Allocations is based around a supporting evidence base, with all documents that it contains having been available for the entire Regulation 18 Consultation period. However, the Housing and Economic Land Availability Assessment (HELAA) was not available for the entire period. This undermines clear and transparent policy making as required by the NPPF.
The draft Local Plan consultation began on 26 January for eight weeks. The 2024 HELAA was only available to support the consultation for the first couple of weeks, with the latest updated HELAA being made available to the public on 11 February. In effect, the eight‑week consultation period has been shortened as all of the supporting evidence was not available to review for the entire period.
The NPPF at paragraph 16(c) requires that “Plans should… be shaped by early, proportionate and effective engagement between plan‑makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees.”
When preparing plans, paragraph 32 states that “The preparation and review of all policies should be underpinned by relevant and up‑to‑date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.”
The draft Local Plan Regulation 18 consultation has not been based on effective engagement, given that not all supporting documentation has been made available for engagement at all times; this fails the NPPF requirements.
Plan‑making regulations contained within The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended) specify that Local Plan, supplementary and evidence base documents need to be available for review for a period of at least six weeks. The HELAA was not available for review for six weeks, as it was available for less than the required period.
When considering housing allocations in Northiam, the HELAA evidence base has consistently rejected the site described as NOR2 when reviewing call‑for‑sites submissions, due to its impact on the National Landscape, distance from the village, and lack of access to services. The site assessment for NOR0026 at Egmont Farm in 2024 states: “This is a large field occupying almost the full length of Coppards Lane on its northern side. It is used as paddocks associated with development at the western end of the site. While the site is influenced by human activity, its relatively undeveloped nature, particularly at its eastern end, is important to the rural setting of the village. The whole site is separated from the main body of the village by Coppards Lane, and development here would extend the footprint of the village, to the detriment of the local landscape and character within the High Weald National Landscape. Furthermore, the site is some distance from services in the main village and lacks pedestrian connections to nearby bus stops, meaning it is not ideally placed to encourage sustainable transport.”
In addition, it is prudent to point out that this site is open to views from the north and has historically been open fields, as shown through historic mapping; it has always remained open as a countryside setting to the village. The fields are open and exposed to the wider landscape, with mature trees and field boundaries along Coppards Lane that would be harmed should allocation and housing development occur. The land is raised above Coppards Lane, making it even more prominent within the landscape. The site provides a countryside setting to the village, and its development would appear as a prominent encroachment into the countryside. It is not adjacent to the limits to built development of Northiam and would represent development within the open countryside, which policy is against.
The NPPF stipulates that sustainable development is pursued in a positive way, both through plan‑making and decision‑taking, with a presumption in favour of sustainable development at the heart of the Framework. Sustainable development is achieved through three overarching objectives: economic, social and environmental. An allocation at NOR2 will not achieve any of these objectives.
The economic objective is “to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure.”
NOR2 is not located in the right place to support growth. It is located outside the village with no access to services. This is echoed within the social objective, which requires development “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well‑designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well‑being.”
NOR2 will not provide future residents with accessible services, given that the main reliance will be on private vehicles. Alongside these objections is the overriding failure of the environmental objective “to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low‑carbon economy.”
Development at NOR2 would erode the High Weald National Landscape character and the village setting by encroaching into open countryside, and it would negatively impact the historic environment by developing historic fieldscapes that have remained open. It would also fail to locate development close to the village centre where amenities and services exist to help mitigate and adapt to climate change, instead proposing housing where occupiers would be primarily car‑dependent. This does not support a low‑carbon economy.
The NPPF goes on to state at paragraph 11 that for plan‑making to apply a presumption in favour of sustainable development, “all plans should promote a sustainable pattern of development” and that strategic policies should provide for objectively assessed housing needs unless protected areas justify restricting the scale, type or distribution of development.
NOR2 would not promote a sustainable pattern of development. It would extend beyond the village envelope, outside the limits to built development and into open countryside that provides a strong sense of place within the High Weald National Landscape. NOR2 proposes major development within a protected landscape, which the NPPF clearly identifies as a strong reason to restrict the scale and distribution of development.
While it is accepted that Northiam, like much of the district, lies within the High Weald National Landscape, this demands careful decision‑making. New development should be directed to contained sites within the settlement, on brownfield land or land surrounded by existing built form, with ready access to services. NOR2 meets none of these criteria.
Paragraph 187 of the NPPF requires planning policies to protect and enhance valued landscapes, and paragraph 189 states that great weight should be given to conserving and enhancing landscape and scenic beauty in National Landscapes. The proposed allocation at NOR2 fails these tests.
Paragraph 190 states that major development in National Landscapes should be refused other than in exceptional circumstances and where it is in the public interest. The same principle should be applied at the plan‑making stage by avoiding major allocations within National Landscapes where needs can be met elsewhere.
It is therefore considered that major housing allocations should not be provided where conservation or enhancement of the National Landscape cannot be achieved. Development should instead be allocated close to the village centre, within areas surrounded by housing and not encroaching into the countryside. Smaller allocations could be accommodated at NOR0022, NOR0036, NOR0027, NOR0031, NOR0020, NOR0018 and NOR0009. These sites are central, enclosed by built form, and would not result in countryside encroachment.
NOR0034, directly opposite NOR2, is assessed within the HELAA as an open field with a strong rural character and sense of place, where development would be harmful to the National Landscape and unsuited to sustainable transport. If this site is unsuitable for these reasons, then identical constraints and objections apply to NOR2 given its shared location and context.
It is therefore strongly suggested that alternative, smaller‑scale allocations closer to the village centre are pursued for Northiam, with larger and major allocations directed to urban and sustainable locations that are not within, or in prominent positions within, the National Landscape.

Rother Local Plan 2025 - 2042 (Regulation 18) – Representation on behalf of Jarvis Homes
(South-East) Limited
Site NR2, Northiam (formerly HELAA Site NOR0026)

I write on behalf of Jarvis Homes (South-East) Limited in support of the allocation of Site NR2 within
the emerging Local Plan.

This representation is made in the context of a materially increased housing requirement, significant
environmental constraints across the district, and the clear need for the Council to identify robust and
deliverable sites. Against that background, the inclusion of Site NR2 is not only appropriate, but
necessary to ensure that the Plan is positively prepared, justified and capable of being found sound.

- Plan Context

In preparing this draft plan, the Council’s evidence clearly establishes a significant housing
requirement of c. 912 dwellings per annum, driven in part by the revised standard method.

At the same time, Rother faces exceptional constraints, including c. 83 per cent of the District falling
within the High Weald National Landscape, alongside extensive environmental and heritage
constraints.

As acknowledged within the evidence base, this creates a clear structural tension between housing
need and land availability. In this context, it is necessary for settlements such as Northiam, despite
their location within the National Landscape, to accommodate an appropriate proportion of
development where this can be achieved without unacceptable landscape, environmental or heritage
harm.

The Council’s evidence confirms a substantial uplift in housing need, materially exceeding historic
delivery rates. At the same time, the Plan recognises that a very large proportion of the district is
subject to policy and environmental constraints, most notably the High Weald National Landscape.

This combination of high need and constrained supply is fundamental. It requires a realistic and
balanced approach, identifying sites that are capable of delivering development without unacceptable
harm, rather than seeking idealised or unconstrained opportunities which do not exist in sufficient
quantity.

Within this context, the strategy of directing growth to sustainable settlements, including Northiam, is
both logical and necessary. Site NR2 is a key component of that strategy.

- HELAA Progression

The progression of the site from HELAA reference NOR0026 to proposed allocation NR2 is important
which should be given full weight.

The HELAA methodology applies a staged filtering process, including:

• initial site identification and availability
• assessment against constraints (including landscape, heritage, access and flood risk)
• consideration of suitability and achievability
• identification of sites capable of contributing to supply

The site has successfully progressed through each of these stages, which demonstrates that, when
assessed against the Council’s own criteria, the site is:

• not subject to overriding constraints
• capable of development in principle
• deliverable within the plan period

The subsequent site selection process has progressed NOR0026 to a proposed allocation. Given that
only two sites are identified within Northiam, and that NR2 is the only new strategic allocation, it is
clear that the site performs strongly in comparative terms and represents one of the most suitable and
deliverable opportunities available to the Council within this settlement.

This is directly relevant to the test of soundness. The Plan must demonstrate that it has selected the
most appropriate sites when considered against reasonable alternatives. The evidence indicates that
NR2 meets that test, as explored later in this representation.

It is also relevant that a significant number of sites assessed through the HELAA process in and
around Northiam were discounted due to greater landscape sensitivity, weaker relationship to the
settlement, or technical constraints. Against that context, the identification of NR2 reflects a clear
comparative advantage over those alternatives and reinforces that it is one of the most appropriate
sites available for allocation.

- Site Characteristics and Settlement Integration

In spatial terms, the site represents a coherent extension to the settlement. It is physically well related
to existing development and sits alongside an established commercial yard and surrounding housing,
forming a logical rounding off of the built form rather than isolated or sporadic encroachment into the
countryside. The site is capable of being contained within a clearly defined edge, assisted by
highways, reinforcing the existing settlement pattern.

Equally important is what the site is not. It is not located within the more exposed northern edge of
Northiam, nor within the more open and sensitive landscape to the west and south-west. Those areas
are materially more vulnerable to harm and would present greater challenges in plan-making terms.

The land itself is flat, with no evident abnormal constraints, and benefits from access to utilities either
on or adjacent to the site. These are all factors that the HELAA process is designed to identify, and
which support a conclusion that the site is both suitable and achievable.

The draft allocation policy suggests a density of 25 dwellings per hectare. This is considered
appropriate for an edge of settlement location, providing an effective balance between meeting
housing needs and responding sensitively to the National Landscape context.

- Previously Developed Land

The site’s current use as equestrian land, including paddocks, built development and associated
infrastructure, strongly aligns with the definition of previously developed land set out in Annex 2 of the
NPPF.

The site forms part of an established equestrian use, with associated structures and operational
infrastructure, and the paddocks are functionally and physically related to that use. In these
circumstances, and having regard to Annex 2 of the NPPF, the land should reasonably be treated as
previously developed land rather than undeveloped greenfield land.

The appeal decision APP/Y0435/W/17/3178790A (29 November 2017) provides a detailed and
reasoned interpretation of this issue in the context of an equestrian holding. It confirms that paddocks
and land reasonably associated with an equestrian use can fall within the scope of previously
developed land where they form part of the established use and are not separate or unrelated open
countryside.

Whilst each case must be considered on its own facts, the principle established is directly applicable
and weighs in favour of the site. This is particularly relevant when considered against national policy
objectives promoting the effective use of land, including paragraphs 124 and 125(c) of the NPPF.
This is an important factor which differentiates the site from more sensitive and clearly undeveloped
greenfield locations.

It is therefore requested that the Council reviews and updates the site’s classification within the policy
assessment from greenfield to brownfield to reflect its status as previously developed land. Further
supporting information can be provided if required.

- Landscape Considerations and National Landscape Context

The site lies within the High Weald National Landscape and this is appropriately recognised as a key
consideration. National policy requires that great weight is given to conserving and enhancing
landscape character. However, this does not preclude development in such locations, provided that it
can be accommodated without unacceptable harm.

Paragraph 189 of the NPPF confirms that great weight should be given to conserving and enhancing
National Landscapes, and that development should be limited in scale. In this instance, the proposed
density of approximately 25 dwellings per hectare, together with the site’s containment and
relationship to the existing settlement, represents an appropriate and proportionate form of
development. It strikes a balanced response to both the sensitivity of the designation and the need to
deliver housing.

Paragraph 190 of the NPPF addresses major development within National Landscapes. Whether
development constitutes “major development” is a matter of planning judgment, having regard to its
nature, scale and setting, and the extent of its impact on the purposes of the designation.
In this case, the proposal represents a modest extension to the settlement, contained within an
existing landscape framework and closely related to the built form. It is not of a scale or character that
would justify being treated as major development in this context.

Without prejudice to that position, if the development were to be considered “major development”, the
requirements of paragraph 190(a) are met. There is a clear and significant need for housing, and a
demonstrable constraint on land supply across the district, with a substantial proportion of land falling
within the National Landscape or subject to other environmental and heritage designations. In these
circumstances, the allocation of suitable and deliverable sites such as NR2 is necessary in the public
interest.

The HELAA and site selection process has already concluded that development of this site can be
accommodated without unacceptable harm. That conclusion is supported by the site’s characteristics.
The site benefits from established boundary hedgerows and sporadic mature trees, which provide a
strong existing landscape framework. There is clear opportunity to retain and reinforce these features
as part of a comprehensive scheme. Whilst there are localised views from adjacent highways, the site
is not prominent in medium or long-distance views and does not form part of a wider open or sensitive
landscape.

The draft allocation policy requires the retention of boundary hedgerows and enhancement of the
pond feature within the site. These measures are both feasible and appropriate and would contribute
positively to landscape character and biodiversity.

A sensitively designed residential scheme, incorporating native planting and landscape-led design
principles, would mitigate potential effects and enable the development to be successfully assimilated
into the settlement.

In practical terms, this is a site where landscape effects can be appropriately mitigated and where
development can be accommodated without undermining the character or scenic quality of the
National Landscape.

- Sustainability and Connectivity

The site is well related to the services and facilities within Northiam, consistent with the Plan’s
objective of directing growth to sustainable locations.

Footways and bus stops are located in close proximity on Station Road, providing convenient access
to the village centre and connections to nearby settlements. The draft allocation policy also supports
the provision of a pedestrian and cycle link between the site and Station Road. This is a short and
achievable connection which would further enhance accessibility, subject to agreement with the
Highway Authority.

Northiam is identified within the draft Local Plan as a settlement capable of accommodating an
appropriate level of growth. The site’s location immediately adjacent to the existing built form ensures
that it integrates with, and supports, this established role rather than extending development into less
sustainable or more isolated locations.

Paragraph 6.74 of the draft Local Plan confirms that Northiam supports a reasonable range of
services and facilities and has been identified as suitable for limited growth, with only a small number5
of sites considered appropriate due to landscape sensitivity. This reinforces the importance of
allocating those sites which are capable of delivering development without unacceptable harm.
In addition, paragraph 6.68 recognises Northiam’s role in supporting the sustainability of nearby
settlements, including Beckley. This wider functional role further supports the appropriateness of
directing development to this location.

It is also relevant that the proposed reinstatement of the heritage Rother Valley Railway between
Robertsbridge and Tenterden via Northiam has the potential to enhance accessibility and strengthen
connections to the wider area. Whilst not relied upon as a prerequisite for development, nor as a
commuter option, this represents a positive future change in the settlement’s connectivity profile over
the plan period.

- Deliverability

Jarvis Homes confirms that the site is available, free from ownership constraints and capable of
delivery within the plan period. There are no known technical, infrastructure or viability barriers that
would prevent early progression.

The site is capable of contributing to housing delivery within the early part of the plan period, without
reliance on significant infrastructure provision or long lead-in times. This distinguishes it from more
complex or longer-term allocations and strengthens its role within the overall housing trajectory.

Given the scale of housing need and the limited number of suitable and deliverable sites, allocations
such as NR2 are not optional components of the supply. They are integral.

The removal or downgrading of such sites would materially undermine the Plan’s ability to
demonstrate a deliverable supply of housing land and would create a clear risk of the Plan failing the
tests of effectiveness and soundness at examination.

- Soundness

The allocation of Site NR2 is necessary to ensure that the Plan meets the tests of soundness:

• Positively prepared: The Plan must meet a housing requirement of c. 912 dwellings per
annum. Given the extensive environmental constraints across the district, this cannot be
achieved without the inclusion of sites such as NR2.

• Justified: The HELAA and site selection process demonstrates that NR2 performs favourably
when considered against reasonable alternatives, many of which have been discounted due
to greater landscape, heritage or access constraints.

• Effective: The site is available, deliverable, and capable of contributing within the early part of
the plan period. It therefore represents a reliable component of the housing trajectory.

• Consistent with national policy: The allocation supports sustainable development, efficient
use of land, and appropriate growth of rural settlements in accordance with the NPPF.

In the absence of allocations such as NR2, there is a clear risk that the Plan would fail to demonstrate
a deliverable supply of housing land and therefore fail the test of effectiveness.

- Conclusion

Site NR2 has been identified through a robust evidence base, has progressed through the HELAA
and site selection process, and represents one of the limited deliverable opportunities within
Northiam.

It is well related to the settlement, capable of being accommodated without unacceptable landscape
harm, and supported by a clear and early deliverability position. It therefore makes an important and
necessary contribution to meeting the district’s housing requirement.

The allocation is integral to a sound and deliverable strategy. Its removal or downgrading would
materially weaken the Plan and create a clear risk of it being found unsound at examination.

In these circumstances, Site NR2 should be retained and progressed to the Regulation 19 stage
without amendment.