BW2/3/4 all front onto Shrub lane.
This is a very narrow road which always has problems with parked vehicles.
There is no footpath at all and even with the proposed footpath behind the hedges there is no way to connect it to the footpath from strand meadow up to the village.

BW2 aside from the footpath issue has a parking problem from Greenfield road. As a private road from 120 years ago there is not enough parking for each house and most park their second car on Shrub lane alongside 101 Shrub lane. This already causes problems when pulling out of Greenfield Road and it would be more of an issue if there is another entrance to 6 houses.
Safety is my primary concern.

The proposal would damage the environment and is unsustainable disregarding irreparable damage to the biodiversity on the site plus historical remains. The dark skies policy would be endangered too in an area of outstanding natural beauty . There is insufficient infrastructure in Burwash to support the increased population. There is insufficient transportation hence Shrub Lane would need to cater for car based families. Access would be required as in 2017 when a similar proposal was declined.

Re site BW1: creating housing next to a Priority Habitat and one of our few remaining Ancient Woodlands will have a significant detrimental effect on biodiversity and the special nature of the National Landscape. The woodland will no longer have an ecologically valuable ecotone into grassland along the majority of its boundary, but will be enclosed by roadway and buildings along three sides, reducing the ability of fauna/flora to spread into similar nearby habitats and so reducing population resilience. Should residents be given access to the woodland (which currently has no public rights of way), the extra footfall and disturbance will necessarily have a high impact on biodiversity. There will also be significant visual creep of development to the north and west of existing village housing. BW2, 3 & 4 are therefore all far preferable, as infilling existing ribbon development, and having no potential impact on a Priority Habitat.

These developments would damage the environment, biodiversity and National landscape. The character of a well visited area would be changed and adversely affected.
No access exists for BW1 and ancient woodlands and the National Landscape would be damaged.
BW2 is already partially developed and would not adversely affect the area, but BW1,3 and 4 would cause problems with infrastructure and local services. The additional cars required to live in these developments would put considerable pressure on the area and the road structure. The dark skies policy would also be affected.

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.

Affordable houses for villagers must be prioritised.
BW1 to BW4: For all Shrub Lane sites, planners really must go and look at the top 50 metres of the lane, where it emerges onto the main road: they must surely agree that the exit is congested and quite dangerous.
BW2: I support only this site of the four. 6 houses would be bearable. The site is clustered with other houses and is anyway is not very pretty.
BW1: Object. There is no access and creating it by demolishing a characterful house would be a pity. There would be serious damage to ancient landscape. 35 houses is a very significant increase and would affect traffic in Shrub Lane to an unacceptable level.
BW3 and 4: Object. This is open greenfield land and would blatantly be ribbon development. Also the number of houses is excessive.

Development without planning infrastructure isn't sustainable. NDP didn't take account of pro development views. Burwash sites need to consider new school & access to main road. 12 good, 13 pos for school/housing with new road connecting Strand Meadow/Shrub Lane to A265 opp Glebe House, due to issues of Shrub Lane parking. Not sure about pedestrian access from school to village though. 10 & 31 then make sense as pedestrian access to village isn't via no footway in the road. All good position for new sewer. 19 (top half only) needs to be used for more village centre car parking, and bungalows and flats for sale for older folks. 01 Was a terrible error by our representatives due to unsuitable access (planning inspector in 1985 said it would cause a danger to existing residents; before vehicle numbers doubled.) Access should've been with Rosemary Gardens/Fire Station & Parking for Shrub Lane+Beechwood Close.

The proposed 64 house allocation for Burwash Village is entirely around Shrub Lane, all on greenfield sites. Its top end is full of Bankside parked cars. Overspill from Strand Meadow now that 30 Watercress Field houses are being built: ca 90 cars. No exit shown from the Denton site (ca.100 extra cars). There are no footpaths below Strand Meadow and the road is already dangerous to pedestrians. How is Shrub Lane supposed to cope with the extra commercial vehicles, ambulances, dustcars, fire engines etc., etc? How is the additional traffic to join the busy A265 or cross the river at the bottom of the road? How is the already overloaded infrastructure to manage: school, surgery, water, sewers etc. etc. One feels that no consideration or thoughts have been given. Has the Strategic Planning Team actually visited the site or simply checked a Google site: "That'll do!"?

BW1 development of this size will have a substantial adverse impact on Landscape and is a site likely to both cause and be subject to flooding
BW2,3 and 4 - Infill developments on a narrow lane already blighted by parked cars.
No pedestrian access to village centre.
Questionable whether local services will cope with the total numbers of persons generated by the numbers proposed.
Affordability - New houses built recently have not sold demonstrating the need for houses which are affordable to those in need of housing- first time buyers and those downsizing.

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

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

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

Development Strategy

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Major Development

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

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

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

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

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

Proposed draft Site Allocations

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

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

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

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

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

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

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

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

Densities

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

Site Specific Policies

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

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

Individual proposed sites comments

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

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

Legislative Requirements

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

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

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

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

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


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

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

BW1 This site is currently surrounded by horrible Leylandii trees but when houses are bought on the site many new residents are likely to take down the trees to see the view. At this point the development will be viewable from everywhere across the valley. As a resident of Shrub Lane I am also concerned by the extra traffic and the lack of pavements and appropriate access.
BW2 This is a better site. I worry about the extra traffic and the fact that there is no pavement from the site going up Shrub Lane towards the village. It is a long way from the village centre.
BW 3&4 Ribbon development which only leads to the next development, and the next and ..There is no pavement and no room to put one in.

Significant harm to the National Landscape. RDC rejected the site in their Decision Notice (20-10-17) because of the impact on the High Weald Area of Outstanding Natural Beauty.
● No access from Shrub Lane to the site. Inquiries made and the access which was available when planning permission was applied for in 2017 (RR/2017/456/P) is no longer available.
● Site is within multiple ownership.
● As the HELAA reports dated April 2024 and January 2026 states there is an Ancient Woodland and Priority Habitat to the west.
● As the HELAA report dated April 2024 and January 2026 states there is surface water flooding in the east and west boundaries.
● Significant development would increase traffic access onto and along Shrub Lane, a narrow lane with no footpath from the site to the village.
● Visible from footpaths, the train and distant ridges albeit currently screened by, non-native, mature leylandi.

Site BW2 (formerly BUR0010) – Land at 101 Shrub Lane, Burwash
Deserving consideration for allocation/development
● There would be minimal damage to the National Landscape.
● The development would be using an existing residential site rather than adding to ribbon development.
● There is no footpath and it is 0.80 miles from the village centre (Village Shop and entrance to car park).
● This site is within the Burwash development boundary.
● It was previously found to be suitable in the SHLAA (2013), for redevelopment for at least 6 dwellings

Site BW3 (formerly BUR0031) – Land east of Shrub Lane (north), Burwash
We consider this site is NOT suitable for allocation/development
● There would be significant damage to the National Landscape. This location is part of the historic field system which is a High Weald landscape heritage asset.
● The site represents an important green field break between housing which protects the rural settlement pattern and prevents the suburbanisation of a historic route way. As the draft Plan states: “4.61. Large gaps in the street create ‘leakage’ of space and diminish sense of enclosure which may not be appropriate in more urban areas or in village centres.
● It is outside the village development boundary. The site is 0.75 miles from the village centre and there is no footpath to the village. Highway Authority comments have raised concern that any footway would not be continuous and that Shrub Lane may be of an insufficient width to otherwise accommodate a footway.
● The housing is described as ribbon development which it is suggested would be a positive feature in completing the ribbon development of twentieth century housing on the other side of the lane. Ribbon development is not a positive High Weald rural settlement feature; it is a harmful, suburbanising feature and in this case would damage the existing green gap of historic fields which are, in turn, bordered by Ancient Woodlands and a local wildlife site. It intensifies the suburbanising feature of the largely mid-twentieth century housing on the west side of the lane.

Site BW4 (formerly BUR0032) – Land east of Shrub Lane (south), Burwash
We consider this site is NOT suitable for allocation/development
● There would be significant damage to the National Landscape. This location is part of the historic field system which is a High Weald landscape heritage asset.
● The site represents an important green field break between housing which protects the rural settlement pattern and prevents the suburbanisation of a historic route way. As the draft Plan states: “4.61. Large gaps in the street create ‘leakage’ of space and diminish sense of enclosure which may not be appropriate in more urban areas or in village centres.
● It is outside the village development boundary. The site is 0.66 miles from the village centre and there is no footpath to the village. Highway Authority comments have raised concern that any footway would not be continuous and that Shrub Lane may be of an insufficient width to otherwise accommodate a footway.
● The housing is described as ribbon development which it is suggested would be a positive feature in completing the ribbon development of twentieth century housing on the other side of the lane. Ribbon development is not a positive High Weald rural settlement feature; it is a harmful, suburbanising feature and in this case would damage the existing green gap of historic fields which are, in turn, bordered by Ancient Woodlands and a local wildlife site. It intensifies the suburbanising feature of the largely mid-twentieth century housing on the west side of the lane.
Note: Burwash Parish Council discussed the above two sites BW3 and BW4 with RDC in 2016 and received this response from [person details redacted], Principal Planning Officer on 26th April 2016:
“You asked if there was a possibility that the “gaps” along the south-eastern side of Shrub Lane (forming the northern part of the large SHLAA site BU10 that relates to much of the valley) could be infilled. I am aware that one of those gaps have been filled with an "exception site” and was chosen because it related better to the village centre and there was a footway back to the village at this location (i.e. Morris Close). Further east along Shrub Lane the landscape character becomes increasingly rural. The rural setting and character of the village, landscape setting and lack of footways all weigh against development in the gaps further east to the Exception site. The gaps along Shrub Lane provide short and medium views into the valley, which serve to emphasise the rural location.”

Site BW1 (formerly BUR0042) – Land north of Shrub Lane, Burwash

We consider this site is NOT suitable for allocation/development

● Significant harm to the National Landscape. Rother District Council rejected the site in their Decision Notice dated 20th October 2017 because of the impact the proposed development would have on the High Weald Area of Outstanding Natural Beauty (now the High Weald National Landscape). Previously refused permission – see below

● There is no access from Shrub Lane to the site. Inquiries have been made and the access which was available when planning permission was applied for in 2017 (RR/2017/456/P) is no longer available.
● The site is within multiple ownership.
● As the HELAA reports dated April 2024 and January 2026 states there is an Ancient Woodland and Priority Habitat to the west.
● As the HELAA report dated April 2024 and January 2026 states there is surface water flooding in the east and west boundaries.
● Significant development would increase traffic access onto and along Shrub Lane which is a narrow lane with no footpath from the site to the village.
● The site is visible from footpaths, the train and distant ridges albeit currently screened by, non-native, mature leylandi.

BW1: harm to the NL. Proximity to ancient woodland. Greenfield development. Large development site for village which will inevitably be car-based.The site is problematic due to the wall of Leylandii trees which have an ominous, enclosing effect and would inevitably have to be removed to allow for foundations, attenuation tanks / package plant as previously identified. The specatacular and far-reaching views across the valley cut both ways and would take many tens of years to begin to screen from any new broad-leaved tree planting.

BW3 and BW4 both object (insufficient space above). Highly inappropriate ribbon development on green field frontages which create harmful suburbanising effect on the rural setting. Close proximity to large Local Wildlife Site / ancient woodland. Negative impact on biodiversity, green corridors - linkage to other green areas / ancient woodland across Shrub Lane. Visible from lane, A265. Destroys a green/field break with frontage strips. Harmful to other settlements. Destroys sense of rural settling and tranquility and part of medieval field boundaries. No footway to Village / services / public transport other than walking in the lane.
BC1 object. Harm to HWNL, greenfield development, harm to biodiversity / hedgerow. Car-based. Ribbon development. Potential run-off.

BW1: OBJECT
This should automatically be discounted as it is a greenfield site next to Ancient Woodland and Priority Habitat. Great-crested newts, grass snakes and slow worms have been identified as well as evidence of bats using habitat features on site. The site will be car-based and lacks a footpath to services.
BW2: SUPPORT
This is acceptable as it has already been developed. However, there is no footpath to the village, so it would be car-based.
BW3 and BW4: OBJECT
Both sites are greenfield and form part of the historic landscape field pattern. They currently provide a green field break/ green corridor with hedgerows and link with the Local Wildlife Site / Ancient Woodlands at Park Wood. Ribbon development urbanises the rural lane and adds traffic pressure as the site would be car-based and lacks a walkway to services. Harm to Biodiversity.

BW1: OBJECT
Greenfield site including Ancient Woodland and Priority Habitat, with three ponds and a stream. A previous planning application was turned down by RDC for "substantial harm to the landscape character and scenic beauty of the High Weald AONB (now NL). Presence of great-crested newts, grass snakes and slow worms, plus evidence of bats using habitat features on site and other protected wildlife. Car-based and lacks a footpath to services.
BW2: SUPPORT
In principle support as the site is already built on. No footpath to the village and it would be car-based.
BW3 and BW4: OBJECT
Both sites are greenfield, form part of historic landscape field pattern and provide a vital green field break/ green corridor with hedgerows and link with the Local Wildlife Site / Ancient Woodlands at Park Wood. Ribbon development, urbanisation and traffic in rural lane as car-based. No walkway to services. Harm to Biodiversity.

See attached representations and supporting documents from Burwash: Save Our Fields in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 53, 54, 61, 64, 65, 66, 67, 68 and 69.

See attached representations and supporting documents from Burwash: Save Our Fields in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 53, 54, 61, 64, 65, 66, 67, 68 and 69.

To Rother District Council,
We have completed the online consultaion but send this additionally as background where we have had to edit comments to meet the word count.

A copy of this is attached. If it can be added in support of those comments, we would be most appreciative.

Wild About Burwash (WAB) response to Rother District Council Draft Local Plan: Consultation Stage Reg 18
WAB is a community group with more than 230 members, the majority of whom are residents in Burwash Parish. The group’s aims are to support and encourage the protection of, and improvements to, the natural environment of the parish. This includes talks, walks and other events. WAB volunteers do a lot for the local environment, including:
• Active recording of flora and fauna biodiversity through the National Biodiversity Records Office
• Monthly monitoring of the water quality and the state of the riverbanks of the River Dudwell, with support from the Environment Agency (this project is now expanding to the River Rother in association with other Wild About groups)
• Regular maintenance of St Phillips Church churchyard in association with the Sussex Botanical Recording Society to record and protect wildflowers in the churchyard + development of a wildflower verge in association with the Parish Council
• Light pollution monitoring in and around Burwash in association with the High Weald NL and nine other local parishes to apply for International Dark Skies Reserve status
• Apple picking in elderly residents’ gardens and local ancient orchards to create WAB apple juice. In 2025 we produced 1,200 bottles. Income from the juice goes to orchard restoration and development
• Active engagement with Scouting group and Burwash school on Dark Skies, Orchards and Rivers projects.
WAB’s suggestions for all future developments in Burwash
WAB suggests that any new development in Burwash parish should:
a. Be built on brown/grey field sites and not on greenfields
b. Not cause environmental / biodiversity harm that then requires to be "recovered" .
c. Be within walking distance of shops and services
d. Be screened to ensure the buildings are not harmful in the landscape
e. Have good local public transport links
f. Meet the local rural housing needs for starter and retirement homes.
All developments, if agreed, should meet environmentally-friendly energy requirements, be dark skies compliant in terms of windows and external lighting and support wildlife (e.g. swift bricks) .
QU 15: Vision for the Countryside
Whilst the reference to countryside here describes areas outside defined development boundaries, for rural parishes like Burwash the countryside is inseparable from the overall community; development invariably backs onto or is surrounded by countryside. The stated Vision for the future of the Countryside is worrying. The value of the countryside appears to be defined at point 6.97 solely in terms of economic productivity - either from food or tourism or the opportunity to conserve it. There is no reference to the inherent beauty of landscape - the High Weald represents one of the best-preserved remaining examples of a medieval landscape in western Europe - no reference to topography, hedgerows, trees, woodland and rivers. Even more alarmingly there is no mention of flora, fauna or even a nod to protecting biodiversity and nothing to describe remoteness, tranquility and a sense of place.
BW1: OBJECT
This is a greenfield site which includes Ancient Woodland and Priority Habitat, with three ponds and a stream. From a previous planning application which was turned down by RDC for representing "substantial harm to the landscape character and scenic beauty of the High Weald AONB (now NL), the presence of great-crested newts, grass snakes and slow worms were identified along with evidence of bats using habitat features on site and other protected wildlife. The site will be car-based and lacks a footpath to services.
BW2: SUPPORT
In principle support as the site is already built on. There is no footpath to the village and it would be car-based.
BW3 and BW4: OBJECT
Both sites are greenfield and form part of the historic landscape field pattern. They currently provide a green field break/ green corridor with hedgerows and link with the Local Wildlife Site / Ancient Woodlands at Park Wood. Ribbon development urbanises the rural lane and adds traffic pressure as the site would be car-based and lacks a walkway to services. Harm to Biodiversity.
BC1: OBJECT
Greenfield, also part of the medieval field pattern with historic hedgerow therefore harms biodiversity as well as the rural landscape. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.
BC2: SUPPORT
In principle support as this is the site of an old nursery, so close to brownfield status. If the trees are retained for both screening and to retain Biodiversity the impact is reduced. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.

To Rother District Council,
We have completed the online consultaion but send this additionally as background where we have had to edit comments to meet the word count.

A copy of this is attached. If it can be added in support of those comments, we would be most appreciative.

Wild About Burwash (WAB) response to Rother District Council Draft Local Plan: Consultation Stage Reg 18
WAB is a community group with more than 230 members, the majority of whom are residents in Burwash Parish. The group’s aims are to support and encourage the protection of, and improvements to, the natural environment of the parish. This includes talks, walks and other events. WAB volunteers do a lot for the local environment, including:
• Active recording of flora and fauna biodiversity through the National Biodiversity Records Office
• Monthly monitoring of the water quality and the state of the riverbanks of the River Dudwell, with support from the Environment Agency (this project is now expanding to the River Rother in association with other Wild About groups)
• Regular maintenance of St Phillips Church churchyard in association with the Sussex Botanical Recording Society to record and protect wildflowers in the churchyard + development of a wildflower verge in association with the Parish Council
• Light pollution monitoring in and around Burwash in association with the High Weald NL and nine other local parishes to apply for International Dark Skies Reserve status
• Apple picking in elderly residents’ gardens and local ancient orchards to create WAB apple juice. In 2025 we produced 1,200 bottles. Income from the juice goes to orchard restoration and development
• Active engagement with Scouting group and Burwash school on Dark Skies, Orchards and Rivers projects.
WAB’s suggestions for all future developments in Burwash
WAB suggests that any new development in Burwash parish should:
a. Be built on brown/grey field sites and not on greenfields
b. Not cause environmental / biodiversity harm that then requires to be "recovered" .
c. Be within walking distance of shops and services
d. Be screened to ensure the buildings are not harmful in the landscape
e. Have good local public transport links
f. Meet the local rural housing needs for starter and retirement homes.
All developments, if agreed, should meet environmentally-friendly energy requirements, be dark skies compliant in terms of windows and external lighting and support wildlife (e.g. swift bricks) .
QU 15: Vision for the Countryside
Whilst the reference to countryside here describes areas outside defined development boundaries, for rural parishes like Burwash the countryside is inseparable from the overall community; development invariably backs onto or is surrounded by countryside. The stated Vision for the future of the Countryside is worrying. The value of the countryside appears to be defined at point 6.97 solely in terms of economic productivity - either from food or tourism or the opportunity to conserve it. There is no reference to the inherent beauty of landscape - the High Weald represents one of the best-preserved remaining examples of a medieval landscape in western Europe - no reference to topography, hedgerows, trees, woodland and rivers. Even more alarmingly there is no mention of flora, fauna or even a nod to protecting biodiversity and nothing to describe remoteness, tranquility and a sense of place.
BW1: OBJECT
This is a greenfield site which includes Ancient Woodland and Priority Habitat, with three ponds and a stream. From a previous planning application which was turned down by RDC for representing "substantial harm to the landscape character and scenic beauty of the High Weald AONB (now NL), the presence of great-crested newts, grass snakes and slow worms were identified along with evidence of bats using habitat features on site and other protected wildlife. The site will be car-based and lacks a footpath to services.
BW2: SUPPORT
In principle support as the site is already built on. There is no footpath to the village and it would be car-based.
BW3 and BW4: OBJECT
Both sites are greenfield and form part of the historic landscape field pattern. They currently provide a green field break/ green corridor with hedgerows and link with the Local Wildlife Site / Ancient Woodlands at Park Wood. Ribbon development urbanises the rural lane and adds traffic pressure as the site would be car-based and lacks a walkway to services. Harm to Biodiversity.
BC1: OBJECT
Greenfield, also part of the medieval field pattern with historic hedgerow therefore harms biodiversity as well as the rural landscape. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.
BC2: SUPPORT
In principle support as this is the site of an old nursery, so close to brownfield status. If the trees are retained for both screening and to retain Biodiversity the impact is reduced. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.

To Rother District Council,
We have completed the online consultaion but send this additionally as background where we have had to edit comments to meet the word count.

A copy of this is attached. If it can be added in support of those comments, we would be most appreciative.

Wild About Burwash (WAB) response to Rother District Council Draft Local Plan: Consultation Stage Reg 18
WAB is a community group with more than 230 members, the majority of whom are residents in Burwash Parish. The group’s aims are to support and encourage the protection of, and improvements to, the natural environment of the parish. This includes talks, walks and other events. WAB volunteers do a lot for the local environment, including:
• Active recording of flora and fauna biodiversity through the National Biodiversity Records Office
• Monthly monitoring of the water quality and the state of the riverbanks of the River Dudwell, with support from the Environment Agency (this project is now expanding to the River Rother in association with other Wild About groups)
• Regular maintenance of St Phillips Church churchyard in association with the Sussex Botanical Recording Society to record and protect wildflowers in the churchyard + development of a wildflower verge in association with the Parish Council
• Light pollution monitoring in and around Burwash in association with the High Weald NL and nine other local parishes to apply for International Dark Skies Reserve status
• Apple picking in elderly residents’ gardens and local ancient orchards to create WAB apple juice. In 2025 we produced 1,200 bottles. Income from the juice goes to orchard restoration and development
• Active engagement with Scouting group and Burwash school on Dark Skies, Orchards and Rivers projects.
WAB’s suggestions for all future developments in Burwash
WAB suggests that any new development in Burwash parish should:
a. Be built on brown/grey field sites and not on greenfields
b. Not cause environmental / biodiversity harm that then requires to be "recovered" .
c. Be within walking distance of shops and services
d. Be screened to ensure the buildings are not harmful in the landscape
e. Have good local public transport links
f. Meet the local rural housing needs for starter and retirement homes.
All developments, if agreed, should meet environmentally-friendly energy requirements, be dark skies compliant in terms of windows and external lighting and support wildlife (e.g. swift bricks) .
QU 15: Vision for the Countryside
Whilst the reference to countryside here describes areas outside defined development boundaries, for rural parishes like Burwash the countryside is inseparable from the overall community; development invariably backs onto or is surrounded by countryside. The stated Vision for the future of the Countryside is worrying. The value of the countryside appears to be defined at point 6.97 solely in terms of economic productivity - either from food or tourism or the opportunity to conserve it. There is no reference to the inherent beauty of landscape - the High Weald represents one of the best-preserved remaining examples of a medieval landscape in western Europe - no reference to topography, hedgerows, trees, woodland and rivers. Even more alarmingly there is no mention of flora, fauna or even a nod to protecting biodiversity and nothing to describe remoteness, tranquility and a sense of place.
BW1: OBJECT
This is a greenfield site which includes Ancient Woodland and Priority Habitat, with three ponds and a stream. From a previous planning application which was turned down by RDC for representing "substantial harm to the landscape character and scenic beauty of the High Weald AONB (now NL), the presence of great-crested newts, grass snakes and slow worms were identified along with evidence of bats using habitat features on site and other protected wildlife. The site will be car-based and lacks a footpath to services.
BW2: SUPPORT
In principle support as the site is already built on. There is no footpath to the village and it would be car-based.
BW3 and BW4: OBJECT
Both sites are greenfield and form part of the historic landscape field pattern. They currently provide a green field break/ green corridor with hedgerows and link with the Local Wildlife Site / Ancient Woodlands at Park Wood. Ribbon development urbanises the rural lane and adds traffic pressure as the site would be car-based and lacks a walkway to services. Harm to Biodiversity.
BC1: OBJECT
Greenfield, also part of the medieval field pattern with historic hedgerow therefore harms biodiversity as well as the rural landscape. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.
BC2: SUPPORT
In principle support as this is the site of an old nursery, so close to brownfield status. If the trees are retained for both screening and to retain Biodiversity the impact is reduced. The site is on a bus route, although, due to poor frequency of service, it will inevitably be car-based.

Please see attached:
- Development Strategy and Site Allocations EA response (Part 1)
- Interim SA and IDP EA response (Part 2)
- Rother Draft Local Plan IDP Part B - EA amendments (Part2)

Part 1 - Development Strategy and Site Allocations

Consultation on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

We have provided advice and guidance
to strengthen policies and evidence to ensure the new Local plan aligns with
national, regional and local requirements.

Environment Agency Position

Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.

Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.

Further details are provided in:
• Section 1 – General recommendations
• Section 2 – Specific comments on proposed policies and sites

Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.

Our planning advice service

As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.

We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our
cost recoverable planning advice service.

Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally sensitive development.

We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

Part 2 - Interim SA and IDP

Consultation on the Draft Rother Local Plan 2025–2042 – Interim Sustainability
Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and Part B (the
Schedule)
Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Interim
Sustainability Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and
Part B (the Schedule). We have provided advice and guidance to strengthen policies
and evidence to ensure the new Local plan aligns with national, regional and local
requirements.
Environment Agency Position
Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.
Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.
Further details are provided in:
•
Section 1 – Infrastructure Delivery Plan (IDP) comments
•
Section 2 – Interim Sustainability Appraisals (SA) comments
We also attach the following document to our response:
•
Rother Draft Local Plan IDP Part B - EA amendments
Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.
Our planning advice service
As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.
We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our cost recoverable planning advice service.
Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally
sensitive development.
We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.