Site HG1 and HG2 feel reasonable. HG1 will provide greenspace and much needed parking, along with safety features on the A21. HG2 is between residential areas and thus develops unused space. Consideration for traffic to and from the site required as it is already difficult to get out of Foundry Close.

HG3 would cause significant decline in the views of properties along this section. Additionally, the need to increase vehicle access via Foundry Close would be a nuisance. Parking is already a significant issue in this area of the village.

I support any proposal that offers genuine change to its community. Small developments often get away with not delivering the affordable housing or infrastructure needed. This proposal (HG4) by Rother holds the developer’s feet to the fire to deliver the changes needed in the community before they realise any return. I support this proposal and strategy to get new homes that will benefit its community.

I support any proposal that offers genuine change to its community. Small developments often get away with not delivering the affordable housing or infrastructure needed. This proposal (HG4) by Rother holds the developer’s feet to the fire to deliver the changes needed in the community before they realise any return. I support this proposal and strategy to get new homes that will benefit its community.

I think the proposed housing allocation of 150 houses at site HG4 is far too great a number for this village to support. It will change Hurst Green from being a village into a small town. There is not the infrastructure to support this number. There are no local jobs which means inhabitants will have to travel on the already overstretched A21 or use public transport. The bus service is very limited, no doctors or shops apart from expensive farm shops. The total of 239 new houses for this village will put too greater a strain on existing resources.

I’m not a planning expert, I’m just a mum, so I’ll keep this short and simple. I fully support including Site HG4 in the Regulation 18 plan because it’s one of the few proposals I have seen that genuinely tackles the housing shortage for real families in Hurst Green.

There aren’t enough suitable homes for families, young people, or older residents wanting to downsize. What matters to me is whether new housing makes everyday life easier. HG4 is close to buses, the train, and the shops, meaning kids can get to school or college more independently, parents can get to work without long detours, and families can walk to local facilities instead of relying on the car. For someone juggling school runs, work, and everything else, that really matters.

We’ve already lost the community shop due to lack of use, and other services are struggling. HG4 would bring in enough new residents to help keep the village going, but not so many that it overwhelms it.

I work with people across the area, and I see how important it is for small villages to stay active. More families here means more support for local businesses and services. HG4 also feels realistic, something that could actually be delivered without years of delay. We need solutions that work now, and Rother has finally put forward an option that does.

For all these reasons, I strongly support HG4 being included in the plan and in future stages to come.

I’m not a planning expert, I’m just a mum, so I’ll keep this short and simple. I fully support including Site HG4 in the Regulation 18 plan because it’s one of the few proposals I have seen that genuinely tackles the housing shortage for real families in Hurst Green.
There aren’t enough suitable homes for families, young people, or older residents wanting to downsize. What matters to me is whether new housing makes everyday life easier. HG4 is close to buses, the train, and the shops, meaning kids can get to school or college more independently, parents can get to work without long detours, and families can walk to local facilities instead of relying on the car. For someone juggling school runs, work, and everything else, that really matters.
We’ve already lost the community shop due to lack of use, and other services are struggling. HG4 would bring in enough new residents to help keep the village going, but not so many that it overwhelms it.
I work with people across the area, and I see how important it is for small villages to stay active. More families here means more support for local businesses and services. HG4 also feels realistic, something that could actually be delivered without years of delay. We need solutions that work now, and Rother has finally put forward an option that does.
For all these reasons, I strongly support HG4 being included in the plan and in future stages to come.

I’m hoping to return to Britain after my studies and settle in Hurst Green. I know the site marked HG4 on the plan very well. It sits on the edge of the village with convenient access to the A21 and the A229 towards Hawkhurst. The land is part of a very old estate, surrounded by mature oaks and established hedgerows, giving it a natural, characterful setting.

In my view, it would make a lovely new housing development. Families would benefit from a balance of affordable homes and green outdoor space while still being close to village life. The railway station is within walking distance, which adds to the site’s practicality. I would be very happy to live in a home there, and I hope the development would include a significant amount of affordable housing, giving people like me a real chance to get back onto the housing ladder in our own community.

This is why I support the emerging Rother Local Plan for Hurst Green and welcome the much‑needed upgrades and new housing supply it proposes. Ultimately, both Rother and the current national government face the challenge of addressing the housing shortage, and building well‑integrated, high‑investment developments like HG4 planned for Hurst Green is the right way forward. Hurst Green is a prime location for regeneration on a meaningful scale. I’d like this site to move forward as the plan develops.

Newlyn Investments write in support of this draft allocation HG4 - Land at The Lodge, London Road, Hurst Green - 150 dwellings.

The site clearly scores well in terms of the Interim Sustainability Appraisal (2026). It appears that the land can be well accessed from the A21, does not flood and has good connections into the village centre. Moreover, the quantum of development is important to support current market factors. There is an acute issue with affordable housing providers taking on smaller s.106 quotas on site. However, with 40% of the development being affordable ie 60 homes, this is a meaningful contributions towards affordable dwellings and will be of a collective size that will allow registered providers to achieve grant funding and progress. We are also supportive of a mix use on site for community, leisure or retail. This element needs to be carefully addressed in terms of viability, but should be a welcome consultation for the Parish.

We are planning to move back to Hurst Green, so I have been following the development of the Local Plan and the Neighbourhood Plan with great interest. Hurst Green is a friendly, well‑connected village, within walking distance of the train station for our boys and ideally located on the East Sussex–Kent boundary for my commute. It is a great place to live, but it lacks the cohesion and stability that comes from having enough homes for the people who want to be part or stay part of the community. It is exactly the kind of environment where my children could grow up with space, good transport links to school and work opportunities.

However, the housing market in Hurst Green is extremely limited. Properties are rarely available, and when they do come up, they are sold almost immediately. For a family like mine, trying to return home from the other side of the world, it feels as though the opportunity to settle in Hurst Green here barely exists.

This is why I believe that building more homes in Hurst Green is not only practical but necessary. It would give families like ours a genuine chance to become residents, rather than restricting the village to those who can secure the very few properties that appear. An increase in homes would help sustain local services, potentially support new ones (particularly if developments such as HG4 are approved) and bring renewed energy to the community. It could also enable long‑overdue improvements, such as enhanced road safety at Coopers Corner (known as one of the worst accident black spots on the A21) and at Station Road, benefiting everyone who lives in or travels through the village.

I support additional housing, ensuring that Hurst Green remains a place of opportunity for the families who need a home, including my own boys. I’d like to see this site continue through to the later stages of the plan.

We are writing to you as the sole landowners of Site HG4, which is currently identified in the Rother Draft Local Plan 2025-2042 for the delivery of some 150 residential units.

Following the emergency public meeting on Friday 13th February, regarding the A21 safety package within Hurst Green, we had the opportunity to meet the representatives from National Highways and our local MP, Dr Kieran Mullan. A keen interest was shown in this site’s potential to resolve local infrastructure constraints and Dr Mullan requested to be kept directly informed of our communications.

Sadly, as you may already know, there has been yet another serious accident in the village this past week - a 13 year old boy was badly injured in a hit and run. This reinforces what residents have been saying for a long time: action is urgently needed. The sooner a real, effective solution is put in place to address the safety problems and excessive speeds through the village, the sooner the A21 will be safer for everyone.

As our Ward Councillors, we want to ensure you are fully briefed ahead of the Cabinet Meeting on 2nd March 2026 about a unique opportunity to address two long standing problems in Hurst Green:
1. a permanent, effective solution, supported and campaigned for by local residents, to address the safety issues at Coopers Corner (A21/A229), and
2. meaningful action to tackle the excessive speeds through the rest of the village.

Our Commitment as Landowners:
We are formally committing to offer land from our holding to facilitate the construction of a new strategic roundabout at the Coopers Corner junction. This offer is made to ensure the 150-unit allocation is not only deliverable but serves as a "safety-first" solution for the entire village.

Strategic Advantages of this Proposal:
• Infrastructure-Led Growth: An allocation of some 150 units provides the "critical mass" and land-take required to deliver the roundabout - a primary objective of the recently adopted Hurst Green Neighbourhood Plan.
• Immediate Road Safety: This proposal directly unlocks National Highways' A21 Safety Package by addressing one of the most notorious accident blackspots with a shovel ready solution as well as significantly slowing the speeds in the village at the same time.
• AONB & Public Interest: By providing a major strategic safety benefit, this considered development satisfies the "Exceptional Circumstances" and "Public Interest" tests required for major development in the High Weald AONB.
• Unprecedented Parish Investment: Following the recent success of the Hurst Green Neighbourhood Plan Referendum in November 2025, the Parish will receive a 25% CIL "Neighbourhood Portion." For a 150-unit scheme, this represents a multi-million-pound investment for the Parish Council to spend on local priorities, including the replacement and improvement of the children’s park, the development and the improvement of recreational facilities, including enhancing the Drewetts Sportsground.

Requested Action
With the Regulation 18 consultation closing on 23rd March 2026, it is vital that the Cabinet Portfolio Holder for Planning is aware that the A21 solution is now very much on the table. We ask that you represent this "Infrastructure Solution" to the Cabinet to ensure HG4 is secured in the final Plan as a deliverable, safety-led allocation for the residents of Hurst Green.

We disagree that houses should be built on greenfield sites due to loss of habitat for all the animals, bird and insects. Also the pressure all these developments will have on all our local services. For example the Doctors surgery and the Primary School are not being made bigger to accommodate all these extra houses. Also the impact on local traffic.

This is with regard to Rother local plan 2025 to 2042 and Hurst Green.

Clearly the proposed new number of houses will put additional strain upon the infrastructure and services therefore any such new development of this quantity must be contingent upon the local infrastructure and services being upgraded to handle such a quantity of new housing.
Also with regard to site number HG4 the already dangerous turning at Cooper’s corner will need to be examined and the opportunity taken for construction of a new roundabout at this junction on the A21.

I agree with the site allocations in Hurst Green, these are in the village Neighbourhood Plan and I know that homes are needed to meet government targets and to house everyone.
I particularly like the parking provision for Hurst Green primary school in the plans for HG1 and the parking for the church in HG2. The inclusion of HG4 makes sense to me, particularly if community facilities are also included in this development. However, crossing the A21 north of the village is difficult and a crossing would be a welcome addition to any development.

HG4: OBJECT. The Development causes Urban Sprawl, a fragmented village and contributing to environmental damage, substantial traffic congestion and air pollution. It destroys natural habitants, environmental degradation, ecosystems and reduces biodiversity. It causes irreversible loss of countryside ,valuable agricultural land and greenbelt. It causes increased car dependency and higher flood risks. It lacks existing infrastructure to support such a large scale development. It will significantly impact upon over subscribed schools, dentists and GP's. Commuting to a Work Place afar will be required. The additional housing would also unlikely benefit existing residents of Hurst Green and the neighbouring villages.

Note my objection to the proposed residential allocations HG1, HG2, HG3, and HG4 within the Hurst Green area. These developments represent an unsustainable expansion that threatens the character of the village and the safety of its residents. My objections are based on the following grounds:

1. Preservation of Greenfield Sites
The sites identified (HG1–HG4) are greenfield locations that provide essential natural boundaries and contribute to the rural character of the High Weald Area of Outstanding Natural Beauty (AONB). Development here would result in an irreversible loss of biodiversity and natural habitat. National planning policy dictates that brownfield sites should be prioritized; the scale of these greenfield allocations is disproportionate and unnecessary.

2. Severe Impact on the A21 and Highway Safety
The A21 is already a heavily congested arterial road that struggles to manage current traffic volumes.

Access Risks: The proposed entrance points directly onto the A21 are a major safety concern. Increasing the number of junctions and turning vehicles on this high-speed road will inevitably lead to an increase in accidents.

Capacity: The local road network lacks the capacity to absorb the hundreds of additional daily vehicle movements these developments would generate.

3. Critical Lack of Infrastructure and Amenities
Hurst Green lacks the basic "social infrastructure" required to support a population increase of this magnitude.

Healthcare: There is no doctors' surgery or dental practice within the village. New residents would be forced to travel to already overstretched facilities in neighboring towns, increasing carbon emissions and wait times.

Retail: The absence of a village shop means every new household will be entirely car-dependent for basic necessities.

Community Spaces: The existing village hall and church are of a size and scale suited to a small hamlet, not a suburbanized hub. They cannot accommodate the social needs of these proposed developments.

4. Education and Child Safety
The local primary school is currently at capacity.

Traffic Danger: The area surrounding the school is already plagued by significant parking issues and traffic congestion. Adding more residents will exacerbate the "school run" chaos, creating a direct physical danger to children, parents, and motorists navigating the A21 corridor.

Lack of Expansion: Without a viable plan (or space) to expand the school and provide dedicated off-street parking, these developments are socially irresponsible.

To conclude, the proposed developments HG1, HG2, HG3, and HG4 fail the "sustainability test" required by the National Planning Policy Framework (NPPF). They offer no benefit to the existing community while placing an unsustainable burden on the A21 and non-existent local services. I urge the council to remove these allocations from the local plan.

Support for Allocation of HG4 – Land at The Lodge, London Road, Hurst Green

As landowner of HG4 (Land at The Lodge), I support Rother District Council’s proposed allocation of the site for a residential led mixed use development. The site is available, suitable, achievable, and represents one of the most sustainable and deliverable opportunities in Rother.

Policy Alignment

The allocation accords with the NPPF, including:
• Boosting housing supply (paras 60–65)
• Promoting sustainable transport (104–106)
• Protecting and enhancing the natural environment (174–180)

- I fully support HG4’s inclusion in the emerging Local Plan.

Suitability and Sustainable Location

HG4 directly adjoins the settlement edge and development boundary on two sides (Foundry Close to the south; HG2 to the west). It is:
• Within a 15 minute walk of the local train station
• A few minutes walk to the village centre, primary school, and bus stops

The location enables:
• Reduced reliance on private cars
• Improved pedestrian/cycle links between the village, A229, and northern parish
• Opportunities to support local services and community infrastructure

- HG4 is the most sustainable development location in Hurst Green for the following reasons.

Safety Led, Infrastructure First Approach

This is not a housing led proposal. HG4 unlocks the land required to deliver a long overdue safety upgrade to the A21/A229 Coopers Corner junction, providing a genuine infrastructure first solution for residents of Hurst Green and the broader community.

Contribution to Housing Need

The indicative 150 homes are appropriate and supported by early master planning. The site can deliver:
• Policy compliant affordable housing (HOU2)
• A balanced mix of dwelling types (HOU1)
• Family homes and downsizing options

- This scale is necessary to meet Northern Rother’s housing requirement and support Hurst Green’s long term vitality.

Deliverability

The site is in single ownership, free from constraints, and available immediately. Early assessments confirm:
• Feasible access to the A21
• No insurmountable ecological issues
• Development outside flood risk areas
• Capacity for utilities and drainage

- HG4 meets the NPPF definition of a deliverable site and can come forward very early in the plan period.

Comments on Draft Policy Requirements

Green Infrastructure

I support the GI requirements, consistent with Policy LWL5 and the site’s parkland character, including:
• Watercourse and lake
• Ancient woodland buffer
• Structural landscaping
• Informal open space and ecological corridors

- A 15m ancient woodland buffer is appropriate. Enhancements could include wetland woodland planting, species rich grassland, and long term management via a LEMP, ensuring compliance with NPPF 180(c).

Access and Movement

I support requirements for:
• Vehicular access to the A21 (in conjunction with National Highways)
• Pedestrian/cycle links to the A229
• Connections to PRoW Hurst Green 33

The policy should confirm that:
• Access design will follow a Transport Assessment
• Off site works must be proportionate and CIL Reg 122 compliant

Mixed Use Provision

I support the principle of mixed uses, with clarification that:
• Scale/type of uses will follow local needs and viability
• Community space may be flexible and multi purpose
• Employment/retail uses should be small scale and ancillary

Phasing

The requirement for delivery of the LEAP and community building(s) before 50% occupation is reasonable, with flexibility on:
• Definition of “community building(s)”
• Phased delivery where justified by evidence or viability

Environmental and Technical Matters

Ecology and BNG

Initial appraisal shows:
• Valuable habitat around the lake and watercourse
• Ancient woodland buffer protecting sensitive areas
• Strong potential for Biodiversity Net Gain

- BNG measures may include wetland enhancements, species rich grassland, hedgerow reinforcement, and bat/bird habitat, aligning with Policy ENV3 and NPPF 179(b).

Flood Risk and Drainage

The watercourse and lake provide a natural basis for a SuDS network. Early work indicates:
• On site surface water management
• SuDS integrated with GI
• No increased downstream flood risk

Landscape and High Weald National Landscape
The site benefits from:
• Containment by the A21 (west) and A229 (north)
• Mature boundary vegetation
• Supportive topography

- A landscape led masterplan will retain parkland trees, reinforce historic boundaries, and create a softened village edge, consistent with the High Weald Management Plan and Policy LAN1.

Conclusion

I strongly support the allocation of HG4 – Land at The Lodge as a sustainable, safety led mixed use development capable of delivering:
• A safety led infrastructure solution for the A21/A229
• 150 new homes, including affordable housing
• Significant Green Infrastructure and biodiversity gains
• Improved pedestrian and cycle connectivity
• New community facilities
• A high quality extension to Hurst Green that respects the High Weald landscape

- With the details suggested, the policy will be sound, deliverable, and capable of providing substantial public benefits for the residents of Hurst Green and Rother.


Additional Supporting Information to Accompany Our Regulation 18 Submission:

(Continuation of our existing representation, submitted by the landowners of HG4, Land at The Lodge)
This section provides updated supplementary evidence and clarification to support the policy, landscape, biodiversity, transport, heritage and deliverability considerations relevant to HG4, Land at The Lodge. It offers the Regulation 18 public consultation a clearer, more comprehensive understanding of the suitability, strategic role, and alignment with the most recent spatial, landscape and infrastructure evidence emerging through the Draft Local Plan process.
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A1. Heritage Context – Confirmation of Non Designation

• The Lodge is not a designated heritage asset.
• It is not locally listed, nor identified as a non designated heritage asset (NDHA).
• It lies outside any Conservation Area.
Consequently:
• NPPF paragraphs 203 and 209 are not triggered.

This provides a robust heritage baseline for all future assessment. We remain committed to undertaking proportionate heritage and townscape appraisal at application stage. We are not aware of any previous heritage designation processes relating to the site.
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A2. Transport, A21 Corridor and Safety Led Strategic Infrastructure Opportunity

A2.1 Settlement wide constraints (not site specific)

Hurst Green faces parish wide transport challenges:
• High car dependency
• Limited bus services
• Limited narrow and constrained footways
• A21 congestion speed and safety issues

These apply to all development in Hurst Green and demonstrate the need for strategic transport interventions rather than a cap on growth in any one location.

A2.2 Why HG4, Land at The Lodge is uniquely strategic for A21 improvements

HG4, Land at The Lodge’s location makes it uniquely able to contribute to:
• Coopers Corner (A21/A229) junction improvements
• Wider A21 safety upgrades
• Improved crossing and active travel infrastructure

Coopers Corner is one of the most documented safety priorities locally. HG4, Land at The Lodge is the only site in the parish positioned to meaningfully assist with resolving these longstanding issues.

Crucially, recent updates to the Draft Local Plan’s Development Strategy emphasise infrastructure led growth and recognise the High Weald’s sensitivity as a landscape constraint. A site that can actively support a safety critical A21 improvement has a materially stronger justification within this policy framework.

A2.3 National Highways engagement

National Highways has contacted us on many occasions, including two written requests in March 2024 for pre-construction survey access. Ongoing direct dialogue confirms HG4, Land at The Lodge’s strategic value for past & forthcoming A21 corridor improvements.
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A3. Landscape & High Weald National Landscape (HWNL) – Settlement Wide Sensitivity and Evidence Supported Opportunity

A3.1 The two AECOM reports and why the 2023 SEA is authoritative

Two AECOM studies exist within the Neighbourhood Plan evidence base:
• AECOM 2019 (Site Options & Assessment): An early, high level review commissioned by the Parish Council. It clearly states its findings may be superseded by more current evidence.
• AECOM 2023 (Strategic Environmental Assessment): The formal statutory SEA supporting the Regulation 14 Neighbourhood Plan. It assesses settlement wide sensitivity, reasonable alternatives and environmental effects. It is the more recent and policy relevant evidence and therefore the correct resource to rely upon.

A3.2 Landscape findings relevant to HG4, Land at The Lodge

The SEA and other studies confirm that:
• All of Hurst Green lies within the High Weald National Landscape (formerly AONB).
• Landscape sensitivity is medium to high across the parish, not uniquely high at the eastern settlement edge.
• The Rother Market Towns & Villages Landscape Assessment identifies the east of the A21—where HG4, Land at The Lodge is located—as the area offering the strongest potential for accommodating growth, due to:
o Enclosed field patterns
o Containment by existing boundaries
o Proximity to the settlement & development edge

This is reinforced by the updated Landscape Character Policy LAN1 in the Draft Local Plan, which requires development to maintain settlement-edge character, support dark skies protection and strengthen landscape features such as hedgerows and field patterns. HG4, Land at The Lodge can satisfy all of these requirements as part of a landscape led masterplan.

A3.3 RDC’s proactive and responsible design safeguards
RDC has embedded clear landscape, biodiversity and design parameters within the HG4, Land at The Lodge allocation. These ensure:
• AONB/HWNL appropriate mitigation
• Protection of dark skies
• Hedgerow and field pattern strengthening
• Sensitive scale and massing
• A strong, multifunctional Green Infrastructure framework

This provides confidence that HG4, Land at The Lodge will come forward in a manner that respects the landscape character of the High Weald, responds to local setting, and secures meaningful environmental and community benefits. This is in addition to ensuring that infrastructure criteria are delivered for community benefit.

A3.4 Alignment with the Development Strategy (2026)

The Draft Local Plan’s Development Strategy recognises the High Weald National Landscape as a principal constraint and therefore prioritises landscape led and infrastructure-supported growth. HG4, Land at The Lodge aligns with this approach by locating development in the most contained and visually enclosed direction for Hurst Green, embedding robust design and GI parameters from the outset, and—critically—by offering a strategic land contribution to support the A21/A229 safety package. Together, these factors demonstrate that HG4, Land at The Lodge is an in principle fit with the council’s strategy to accommodate need in the most sensitive, mitigable way, while directly enabling safety led infrastructure improvements that benefit the whole settlement as well as broader commuters from the district.

A3.5 Design led density and edge treatment

While HG4, Land at The Lodge can accommodate the Draft Plan’s indicative quantum, we recognise the need for design led density that responds to character, topography, views, dark skies, and settlement edge conditions. The masterplanning brief will therefore:
• Provide lower intensity, landscape buffered edges to the countryside;
• Focus slightly higher intensity where visual containment is strongest;
• Embed a green blue network (hedgerows, copses, swales, lake & ponds) that reinforces High Weald character;
• Adopt dark sky compliant lighting principles.
This approach ensures compliance with landscape policy and HWNL expectations, while retaining a deliverable and viable scheme.
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A4. Biodiversity – Baseline Habitats, No Receptor Sites, and BNG Potential
• HG4, Land at The Lodge contains typical parish habitats such as hedgerows and some Priority Habitat.
• These are not statutory designations and do not prevent development when appropriately managed.
• There are no biodiversity receptor sites, ecological compensation areas or designated ecological assets associated with HG4, Land at The Lodge.
• DEFRA’s Biodiversity Net Gain Register confirms no receptor sites in Hurst Green, Etchingham or TN19.

HG4, Land at The Lodge is large enough to deliver on site BNG through:
• Habitat creation
• Strong landscape buffers
• Ecological connectivity improvements
• Multifunctional open space

To ensure the Regulation 19 plan stage is fully supported, we will commission a Preliminary Ecological Appraisal (PEA). This will provide a clear ecological baseline and identify targeted BNG opportunities in a proportionate manner.
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A5. Alignment with the Made Neighbourhood Plan

HG4, Land at The Lodge aligns fully with the Made Neighbourhood Plan because:
• It lies outside all NP designated protected areas (Local Green Spaces, Protected Views, Important Gaps, etc.).
• NP policies on design, views, landscaping, parking, dark skies and GI are criteria based, not restrictive. They can be fully satisfied through masterplanning.
• The NP Examiner confirmed that Neighbourhood Plans cannot restrict strategic district wide allocations.
• The SEA identifies the eastern side of the A21 as having capacity for development.

HG4, Land at The Lodge can therefore be delivered entirely in conformity with the NP’s aims and principles. As previously stated, the site will be both landscape & strategic infrastructure led
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A6. National Planning Policy (NPPF) – Strategic Consistency

HG4, Land at The Lodge complies with national planning policy because:
• Strategic policies must meet district wide housing and infrastructure needs, including in sensitive areas.
• A recently made NP does not restrict strategic allocations.
• Settlement boundaries in NPs apply to planning applications, not to emerging Local Plan allocations.

The Draft Local Plan must remain flexible and capable of meeting overall housing needs, including within the High Weald, where opportunities are more constrained. The Government imposed housing requirement for Rother is 912 homes per year, whereas the emerging Draft Local Plan currently plans for c.495 homes per year (around 54% of the Government requirement). This leaves a substantial deficit between need (912 p.a.) and planned delivery (≈495 p.a.), underscoring the necessity of allocating and delivering every sustainable site that can viably come forward.

In this context, HG4, Land at The Lodge is critical. It represents a deliverable, sustainable allocation that can make a direct, quantifiable contribution to closing the shortfall created by national requirements and local capacity constraints—particularly acute in the High Weald National Landscape. Retaining and prioritising HG4, Land at The Lodge will increase the district’s overall supply, improve the robustness of the five year housing land supply position, and help move Rother closer to the Government’s 912 homes per year requirement while underpinning the plan’s own 495 homes per year trajectory. Given the Council’s acknowledged environmental constraints and its current strategy to plan below the national figure, removing or diluting HG4, Land at The Lodge would materially worsen the gap and weaken the soundness and deliverability of the Local Plan.

To be effective and sound, the Local Plan should retain HG4, Land at The Lodge in full and support its timely delivery, with appropriate design, landscape and infrastructure safeguards to reflect its High Weald context. This approach aligns with the Council’s evidence that significant constraints exist but that a thorough search for sites is required—and with the current consultation draft, which acknowledges both the heightened national housing requirement and the need to maximise suitable, deliverable allocations to secure a realistic housing trajectory.

HG4, Land at The Lodge forms part of a robust case toward meeting the ‘exceptional circumstances’ test for major development in the High Weald National Landscape, because it addresses a clearly evidenced public safety problem, (National Highways has identified this need, This need has been further underlined through direct approaches made to us by National Highways. In addition, a number of county council representatives and MPs, and parish council councillors and the democratically approved neighbourhood plan all evidence the need for a safety-led solution needing to be delived at Coopers Corner).

The second point is that there has no reasonably available alternative outside the HWNL. The A21 safety team confirmed at the recent emergency meeting hosted by the Parish Council that the reason that the safety enhancement could not go ahead was that the land was not available and the funding was not available. The junction is next to our property, and we are offering the land for the solution.

The Government has set out almost £25 billion of spending for National Highways for the 2026–2031 period, and this funding framework is formally described as the third Road Investment Strategy – RIS3. The A21 Safety Package has also been extended, with active National Highways works now documented through mid 2026, well beyond the originally published completion date. These funds, will be further supported via the development financing of HG4, Land at The Lodge.

The final point is that it should be designed to avoid, minimise and mitigate landscape harm in line with national policy. Currently Rother has put together a robust proposal for how HG4, Land at The Lodge will need to meet the HWNL Planning criteria and we have confirmed that as landowners we are fully supportive of Rothers proposed requirements.
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A7. Availability, Deliverability & Community Benefit
HG4, Land at The Lodge represents a highly deliverable and sustainably planned allocation. It is:
• Available now, in single ownership, allowing straightforward progression.
• Deliverable, with realistic, infrastructure aligned phasing that ties into the timing of A21/A229 safety improvements.
• Capable of supporting National Highways’ safety led infrastructure, addressing a broadly recognised public safety need.
• Suitable for some 150 homes, including a policy compliant proportion of affordable housing.
HG4, Land at The Lodge can deliver the following community benefits:
• High quality Green Infrastructure (GI), integrated from the outset.
• Biodiversity Net Gain (BNG) delivered on site.
• SuDS led, climate resilient drainage infrastructure.
• Pedestrian and cycle connectivity enhancements, extending and increasing village wide walkability and safety.
• A landscape sensitive extension to the village, respecting High Weald character and settlement form.

The scheme’s design led density strategy and phased delivery approach ensure that development sits comfortably within the existing village character, supports the independently commissioned viability work for the site, and aligns with required infrastructure timing.
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A7.1 Transparent and Proactive Community Engagement

We have undertaken consistent and open engagement with residents through both Parish hosted and Rother District Council hosted exhibitions, drop-ins and consultation events. This approach has allowed the community to clearly understand the genuine benefits HG4, Land at The Lodge brings, including:
• Meaningful safety improvements linked to A21/A229 interventions.
• Bespoke landscape enhancements and strengthened GI corridors.
• Infrastructure aligned growth, preventing uncoordinated or reactive expansion.
• Housing for existing and future residents, supporting village vibrancy, sustainability and long term security.

We recognise that transparency is essential, and have embraced this throughout our engagement to date.
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A7.2 Developer Engagement and Viability Testing

We have undertaken detailed and constructive discussions with multiple reputable, high quality, scalable developers with strong track records in delivering complex, landscape sensitive sites. These discussions have advanced beyond early interest and now include:
• Active masterplanning input, shaping the evolving concept plan.
• Initial viability testing, confirming the site’s realistic and sustainable deliverability.
• Collaborative exploration of design, access and phasing options, ensuring alignment with both local character and infrastructure requirements.

All credible development partners engaged to date recognise HG4, Land at The Lodge’s strategic potential, its realistic deliverability, and its ability to meet both local and district wide objectives.

This early collaboration provides strong confidence that HG4, Land at The Lodge can be delivered in a phased, feasible and policy compliant manner once allocated.

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A8. Formal Conclusion and Requests

Conclusion:
HG4, Land at The Lodge is demonstrably available, suitable, and deliverable. It occupies an evidence supported location at the eastern edge of Hurst Green and can accommodate a landscape led development with:
• Proportionate HWNL mitigation
• On site BNG
• Strong GI
• Meaningful A21/A229 safety led infrastructure & transport benefits

It is consistent with:
• National planning policy
• The Made Neighbourhood Plan
• Updated Local Plan evidence including LAN1 and the 2026 Development Strategy
• RDC’s design, landscape and GI expectations for high quality major development

A8.1 Proportionate next stage evidence

We welcome the council’s ongoing, proportionate updates to its evidence base and will actively support any further landscape, transport, infrastructure, design, drainage, or ecology work that the council and statutory consultees consider necessary as the plan moves to Regulation 19. As landowners, we will co operate fully in a timely manner so the authority can finalise concise, decision-ready evidence that secures a sound, deliverable HG4, Land at The Lodge allocation.

We will continue to engage with National Highways & elected officials on the safety led, infrastructure solution at A21/A229 junction, Coopers Corner. We will also continue to undertake consistent and open engagement with residents.
________________________________________
Requests to Rother District Council

1. Retain HG4, Land at The Lodge as a strategic allocation of some 150 dwellings in the Draft Local Plan, recognising its capacity to deliver HWNL appropriate, landscape led growth.
2. Note the confirmed heritage position for The Lodge (no designation; NPPF 203/209 not engaged) and reflect this baseline in the plan evidence.
3. Record the biodiversity baseline accurately, noting the absence of receptor sites in Hurst Green/Etchingham/TN19 and securing BNG via national metrics at application stage.
4. Continue and formalise engagement with National Highways and East Sussex County Council to shape a safety led infrastructure package for Coopers Corner/A21 that can be secured through allocation wording and/or delivery triggers.
5. Confirm the allocation’s design, landscape and GI parameters (as already drafted) so that any future proposal is required to meet these criteria as a condition of delivery.
6. Acknowledge ongoing developer interest and initial viability work as positive indicators of deliverability, and invite further technical dialogue with us as landowners to align phasing, infrastructure and housing delivery.
7. Convene a focused allocation workshop with RDC, National Highways and ESCC to agree in principle safety interventions, proportionate evidence, and a deliverable, infrastructure aligned phasing approach for Regulation 19.
________________________________________
Statement of commitment

We remain committed to working constructively with RDC, National Highways, ESCC and local residents to deliver a high quality, policy-compliant scheme at HG4, Land at The Lodge—one that respects the High Weald landscape, enhances village safety and connectivity, delivers affordable homes, and provides long term environmental and community benefits requested by our local community via the NP.

Please see attached:
- The above Additional Information (Additional Reg 18 information 16 03 26)
- Appendix 1 Policy Alignment Matrix Appendix 1 Policy Alignment Matrix (16/03/2026 APPENDIX 1 — POLICY ALIGNMENT MATRIX)

Approval of HG4

I am writing to express my full support for the proposed 150-home development at HG4
Hurst Green is in need of housing, and this project addresses that demand by offering a mix of homes suitable for young professionals and families. Furthermore, I am encouraged by the proposed investment in local infrastructure and the economic benefits, including job creation, that this development will bring. The focus on sustainability and modern design will enhance the community for future generations and make the A21 within Hurst Green safer for traffic with the new proposed road lay.

I urge the council to approve this application.

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.

I live in Burgh Hill, Etchingham, midway between Hurst Green and Etchingham. I have attended both the parish councils’ presentations on the proposed sites for our villages and spoken with councillors at both district and county council level.

ETCHINGHAM

As a general point Etchingham has no village shop, the butcher is closed, no public house . We do have the station with the Bistro and the Post Office which sells sweets and stationary. The bottom end of the village is in the flood plain and the fields and surrounding lanes often flood. Raw sewage on the field next to the houses at the bottom is the result as the pumping station has long been at capacity. Any further development in the village cannot be allowed until this is resolved.

The site in Church Lane sits on arable pasture some six feet above the road level and immediately at the dangerous bends over the narrow railway bridge. Access is highly compromised. The lane floods badly below the proposed site with normal runoff from the fields so further development here would drastically add to this problem. Further development here where the row of houses opposite have no driveways and residents park at right angles to the houses on their paved over frontages often causing overlap onto the highway would add to the danger of access to this site. I object to this site.

The site on the main A265 outside the village envelope and in an 60 mph speed limit is in the National landscape, AONB, and green belt . Totally unsuitable. I object.
The third site down the lane past the village club is in the flood plain with highly compromised access onto a dangerous narrow lane. I object.

HURST GREEN

This village already has approved permission for 75 units. Only one site has been started and finished, 26 units, the other two yet to begin even after 3 years!

Site HG3.
Provided this site uses the vehicular access through Foundary Close and not the fourth access onto the Station Road A21 junction which is undergoing highly contested restructuring I have no objection.

Site HG4
To suggest an extra 150 units here without due regard to the congestion and access onto the A21, capacity at the village school, drainage, power and water availability is totally irresponsible and demonstrates a disregard for local opinion, or a professional reasoned approach form government at all levels. I object.

Support of Land at The Lodge, London Road, Hurst Green - HG4.

Land at The Lodge, London Road, Hurst Green.

As a local Groundwork, Construction & Civil Engineering Company operating in the Rother District, we wish to express our full support for the proposed allocation of HG4 - for 150 homes with the draft Local Plan.

From a technical, construction-delivery and infrastructure-feasibility standpoint, HG4 is the most suitable and sustainable development locations identified in Hurst Green. The Council's Interim Sustainability Appraisal confirms that this site "scores well" and is assessed as being safely accessible from the A21, free from flooding constraints and well connected to the village centre. These factors are essential for ensuring that the site is both viable and deliverable from a civil engineering perspective.

Furthermore the appraisal notes that HG4 provides the right scale of development to support critical local needs including a 40% affordable housing provision - equating to around 60 affordable homes. which is highlighted as a "meaningful contribution"

Continuation of Earle Construction's support

A development of this scale creates the critical mass required to design, fund, and deliver a safer and more efficient road layout - an outcome that would benefit the entire community. The ability to deliver such improvements is consistent with the Council's own view that HG4 can be well accessed from the A21.

The economic value of HG4 should also not be understated. A development of 150 homes will sustain a significate volume of local construction employment over multiple years, supporting local groundworks businesses, trades, supply chains, plant hire firms, and engineering consultancies. This directly aligns with the Local Plans aim to guide sustainable growth in summary HG4 represents.
A highly deliverable sustainably locates site as confirmed in the Council's own evidence
A development capable of providing meaningful affordable housing
The only allocation in Hurst Green large enough to viably fund A21 Safety improvements
A site

Objection HG3: New traffic lights in the village -access via the lane running next to the Courthouse for pedestrians will be dangerous as there will be stop-start vehicles and this lane has not been taken into account with the traffic lights. Pedestrians using the new crossing will have go across the lane (particularly children going for the School bus stop) and with added houses this I feel will be unsafe.
The area is where villagers go for a walk to the cricket pitch and it will spoil the countryside setting and with extra traffic will make it unsafe for pedestrians.
If it does go ahead 3 storey buildings will be an eyesore - it's behind several listed buildings.

HG4: Needs to ensure future possibility of BY-PASS for Hurst Green in design. Requires roundabout at dangerous junction - serious accidents at Coopers Corner if this housing development is to go ahead.

HG4 should not be considered at this time for a village of this size with limited services. Should there ever be reconsideration given to a by pass it might become sustainable but would bring other necessary considerations including HWNL affects, better infrastructure, employment possibilities for Hurst Green.

We strongly support the allocation of HG4 to provide much needed housing within this location. The site is suitable on a number of fronts to provide a meaningful contribution to meet housing levels in the Borough, but at a scale and form of development which would be wholly appropriate for the size of the village. The allocation also provides the opportunity to deliver a number of much needed facilities for the community, which we believe should be left broad and subject to engagement with the Community and the Council as part of any future planning application process. The size of the site also means the opportunity for significant CIL and S106 contributions which should be ring fenced for local infrastructure to support the delivery of the site but also to address any critical infrastructure concerns within the village itself.

The A21 is already overloaded with traffic. Hurst Green is the only village on the A21 without a bypass, which also has a primary school on this road. Significantly increasing the number of houses due North of the village (HG2 & HG4), opposite the school (HG1), and right in the middle of the village, will make the situation even worse. The introduction of traffic lights at the junction with station road will also result in traffic build ups. The village itself is dying. There is only one shop left, and the pub will only be open for a few hours on Friday and Saturday, as there is no where to park other than on the very busy A21, which causes traffic chaos. The bypass needs to go ahead before any consideration is made towards additional housing.

I am [personal details redacted], and I have lived at The Lodge in Hurst Green [personal details redacted]. I am writing to express my strong support for allocating Site HG4, as it is the only deliverable mechanism capable of fulfilling the policies and intentions of the made Hurst Green Neighbourhood Plan (HGNP) while also helping address the district’s significant housing‑delivery shortfall.
The HGNP gives formal weight to resolving long‑standing highway‑safety issues at Coopers Corner, with Policy HG21 identifying this junction as a critical priority. Living directly beside the A21/A229 junction, I have witnessed the danger first‑hand. On several occasions, the Air Ambulance has landed on our land to respond to serious accidents. This is not theoretical risk — it is a recurring emergency reality for our community. Despite years of discussion, public funding has never delivered a permanent fix. HG4 is the only allocation capable of securing the land and development contributions required to implement the junction improvements the HGNP mandates.
At a recent Regulation 18 Scrutiny Meeting, RDC officers — including [officer name redacted] — presented clear evidence of a severe district‑wide housing deficit. Even assuming densities of 35 dwellings per hectare, Rother is projected to achieve only around 54% of its required housing supply. Officers indicated that density assumptions may need to increase further due to this shortfall. With 83% of the district lying within the High Weald AONB, suitable non‑AONB sites are extremely limited. It was made clear that the district must identify deliverable, suitable sites within the AONB where the public benefit justifies allocation. HG4 provides such public benefit in an exceptional and documented way.
It is also evident that the Parish’s reliance on piecemeal, small-scale sites has not produced the infrastructure the village needs. Several sites have stalled or lacked viability, and none have delivered strategic improvements. HG4 finally provides a coordinated allocation capable of delivering highway safety upgrades, supported by neighbourhood‑level CIL funding for the community facilities outlined in HGNP Vision 2030.
Supporting HG4 means delivering the Neighbourhood Plan as written, addressing the district’s housing shortfall, and fixing a junction that has endangered lives for decades. I strongly urge the Council to allocate Site HG4.

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