1) TC1 is outside the settlement boundary.
2) I fear a development in that location will have a major environmental impact as more water will run down into Steellands Rise (and Field Rise) than currently does causing flooding.
3) Infrastructure is not adequate enough in the village. School too small, GP Surgery planning to close, too much traffic, etc.

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 hereby object to the proposed development TC1 as the scale of the development is too large for the local infrastructure to support. Such a development would place significant additional pressure on local services and facilities, which are already operating at capacity.

In addition, the development would likely have a detrimental impact on local wildlife and the surrounding natural environment. The increase in housing would also result in more vehicles using local roads, which are already congested, potentially worsening traffic conditions and increasing safety concerns.

In contrast, the proposed development TC2 is considerably smaller in scale and, in my view, represents a more proportionate and acceptable level of development for the area.

No objection to either site provided their impact on the environment is minimalised.

We do not have the infrastructure as a village to have more houses, industrial units or anything other than the area currently has!
There’s already not enough drs surgery’s, outages on water etc there simply isn’t the infrastructure to sustain further housing!
There are also currently PLENTY of properties sitting empty in the area whether social or for sale so why do we need another selection of simply unaffordable and frankly not needed properties in the area!

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

I hereby object to the proposed development TC1 as the scale of the development is too large for the local infrastructure to support. Such a development would place significant additional pressure on local services and facilities, which are already operating at capacity.

In addition, the development would likely have a detrimental impact on local wildlife and the surrounding natural environment. The increase in housing would also result in more vehicles using local roads, which are already congested, potentially worsening traffic conditions and increasing safety concerns.

In contrast, the proposed development TC2 is considerably smaller in scale and, in my view, represents a more proportionate and acceptable level of development for the area.

Development on site TC1 should be rejected due to the following:-
1. Site is outside the existing Ticehurst village development boundary.
2. Site is within High Weald National Landscape (2018-28 Plan policy R1) The sites elevation means development will become a prominent feature within the local landscape.
3. Development contravenes "Maintain Green Gaps Between Settlements" (2018-28 Plan policy R2)
4. Development involves destruction of agricultural land which should remain agricultural.
5. Already insufficient healthcare provision in Ticehurst.
6. Already insufficient parking provision in Ticehurst.
7. Already insufficient local road infrastructure. The Flimwell/A21 junction is heavily congested at peak times. The right-hand turn lane from A21 to B2087 already dangerously backing up into main A21 traffic flow
8. Traffic queuing to turn right into Steelands Rise will back up on dangerous B2087 blind bend.
9. Ticehurst area is officially designated as "seriously water-stressed", driven by high population density.

Representation – Site TC1: Land at Steellands Farm, Field Rise, Ticehurst
1. Introduction
This representation relates to Site TC1.
In contrast to other allocations in the area, this site is supported in principle, given its location adjacent to the existing settlement, proximity to the primary school, and relative accessibility to village services.
However, concerns remain regarding the scale, density and infrastructure impacts, and modifications are required to ensure the development is appropriate and policy-compliant.
________________________________________
2. Principle of Development and Sustainability
The site represents a logical extension to Ticehurst, with:
• Proximity to the primary school
• Walking access to village facilities
• Better integration with the existing settlement compared to more remote allocations
This aligns more closely with the principles of sustainable development, reducing reliance on private vehicles relative to other sites in the plan.
________________________________________
3. Scale and Density
The proposed development of approximately 54 dwellings at 30 dwellings per hectare raises concerns in relation to:
• The rural character of the area
• The sensitivity of the High Weald National Landscape
• The constrained and visually prominent nature of parts of the site
Given these factors:
• The density appears relatively high
• The level of development risks creating a more urban form of development than is appropriate
A reduction in density, with greater provision of green space and lower-rise development, would better reflect the character of the area and site constraints.
________________________________________
4. Landscape and Site Constraints
The site contains a number of important constraints:
• Sloping topography, particularly in the southern field
• Visibility from the surrounding landscape
• Proximity to a Grade II listed building
• Existing hedgerows, trees and a pond
While the policy includes mitigation measures, the extent of development proposed raises concern that:
• The landscape setting may be adversely affected
• The effectiveness of screening and buffering may be limited
A lower-density approach would allow for:
• More meaningful green infrastructure
• Better integration with the landscape
• Improved protection of the setting of heritage assets
________________________________________
5. Housing Mix and Local Need
Given the site’s location:
• Adjacent to the primary school
• Within walking distance of village services
It is particularly well suited to meeting local housing needs, especially:
• Affordable housing
• Social housing
• Housing for young families
This should be prioritised within the development to ensure that:
• The scheme supports the long-term sustainability of the village
• The local school benefits from increased enrolment
________________________________________
6. Transport and Traffic Impact
While the site is relatively well located, traffic impacts remain a concern:
• The village has limited local employment opportunities
• Many residents are likely to commute, increasing traffic through:
o The centre of Ticehurst
o Routes toward Flimwell and the A21
The impact of development traffic, particularly during school drop-off and pick-up periods, must be carefully assessed and mitigated.
In addition:
• Improvements to pedestrian and cycle infrastructure are essential
• Safe and convenient walking and cycling routes must be delivered, including connections toward Tinkers Lane and surrounding areas
________________________________________
7. Infrastructure and Local Services
While the site is relatively well located, there are emerging concerns regarding local service provision, particularly in relation to healthcare.
• Recent changes, including the closure of local GP provision, indicate that existing services are under pressure or reducing in availability
• Additional development without corresponding infrastructure risks placing further strain on already limited provision
Given the scale of development proposed, it is important that:
• The impact on healthcare provision and other local services is properly assessed
• Appropriate contributions are secured to support or enhance local infrastructure
In particular, consideration should be given to:
• Financial contributions toward local healthcare provision
• Ensuring that development contributes to maintaining sustainable community services
Without such measures, there is a risk that development, while well-located, does not result in a fully sustainable community.
________________________________________
8. Infrastructure and Connectivity
The requirement for improved pedestrian and cycle infrastructure is strongly supported.
In particular:
• The current lack of continuous footways along parts of the B2087 presents a barrier to safe movement
• The proposed connections should be delivered early in the development to ensure:
o Safe access to the school
o Reduced reliance on car travel
________________________________________
9. Suggested Approach
A more appropriate approach would be:
• Retaining the site allocation in principle
• Reducing the overall density and number of dwellings
• Prioritising:
o Affordable and social housing
o Family housing suited to local needs
In addition:
• Ensuring high-quality green infrastructure is provided
• Delivering pedestrian and cycle improvements early
• Carefully managing traffic impacts, particularly around the school
• Securing contributions toward local infrastructure, including healthcare provision
________________________________________
10. Conclusion
Site TC1 represents a relatively sustainable location for development and is supported in principle.
However, the proposed scale and density are higher than appropriate for this rural and sensitive location.
A revised approach, with reduced density, enhanced green infrastructure, improved infrastructure provision (including healthcare), and a focus on local housing needs, would better align with policy objectives and ensure the development integrates successfully with the village.



Representation – Site TC2: Orchard Farm, Ticehurst Village
1. Introduction
This representation relates to Site TC2.
It is acknowledged that the site benefits from an extant planning permission (RR/2022/1265/P) and allocation within the Ticehurst Neighbourhood Plan. As such, the principle of development is not disputed.
However, concerns remain regarding the density, form of development and its alignment with local character and need, and whether the Local Plan should reinforce or encourage this approach.
________________________________________
2. Density and Character
The site proposes development at an indicative density of approximately 42 dwellings per hectare, which is high in the context of:
• The village setting
• The grain and character of surrounding development
• The constrained nature of the site
The site forms a relatively enclosed green space within the village and represents a form of backland development.
There is concern that:
• The density proposed risks creating an overly intensive form of development
• The scheme may appear out of keeping with the prevailing character of Ticehurst
• Incremental developments of this nature contribute to a gradual erosion of village character
A lower-density approach would better reflect the established pattern of development and respect the site’s context.
________________________________________
3. Flood Risk and Site Constraints
A significant proportion of the site is identified as being at risk of surface water flooding, particularly in the northwest.
While the policy seeks to direct development toward less vulnerable areas, this:
• Further constrains the developable area
• Increases pressure to build at higher densities within the remaining land
This raises concern that the proposed number of dwellings may not be compatible with the site’s physical constraints without compromising design quality or amenity.
________________________________________
4. Highway Access and Local Impact
Access is proposed via Lower St Mary’s, which is a constrained village road.
While the scale of development is relatively small, consideration should be given to:
• The cumulative impact of additional traffic within the village
• The suitability of access arrangements in a tight historic environment
These impacts, while limited individually, contribute to wider pressures within the village.
________________________________________
5. Housing Mix and Local Need
There is limited evidence that the form of development delivered under the existing permission reflects local housing need.
In particular:
• The village would benefit from a greater proportion of:
o Affordable housing
o Smaller homes suited to local residents
There is a concern that higher-density backland schemes may prioritise maximising site value, rather than delivering housing that supports the long-term sustainability of the community.
The Local Plan should therefore place stronger emphasis on:
• Appropriate housing mix
• Delivery of genuinely affordable homes
________________________________________
6. Role of the Local Plan
Given that planning permission has already been granted, it is unclear what additional benefit is provided by allocating this site within the Local Plan at its current density.
There is a risk that:
• The allocation implicitly endorses higher-density backland development
• This sets a precedent for similar forms of development elsewhere within the village
The Local Plan should instead ensure that:
• Development is consistent with local character
• Site constraints are fully respected
• Density is appropriate to context
________________________________________
7. Conclusion
While the principle of development is accepted, concerns remain regarding:
• The relatively high density of development
• The impact on village character
• The constrained nature of the site, including flood risk
• The lack of clear alignment with local housing needs
Accordingly, the Local Plan should not reinforce or promote this form of development without clearer safeguards to ensure that future schemes are lower in density, more responsive to local character, and better aligned with community needs.

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
On behalf of our clients, the Stapylton-Smith Family, who own the Land at Steellands Farm, Field Rise, Ticehurst that was previously promoted via the Call for Sites, these representations are in response to the Regulation 18 consultation on proposed site allocations for the Rother Local Plan 2025–2042, specifically in relation to Policy TC1: Land at Steellands Farm, Field Rise, Ticehurst.

The landowner fully supports the principle of allocating this site for residential development and welcomes its identification through the Housing and Economic Land Availability Assessment (HELAA) process as a suitable, available and achievable location for new homes in Ticehurst. The site represents a logical and sustainable extension to the village at a time when the district faces an acute and well-documented housing land shortfall.

However, in order to ensure the policy is sound and deliverable, and consistent with national planning policy, a number of modifications to the policy wording are respectfully sought. These modifications do not seek to undermine the intent of the policy, but rather to ensure it provides an appropriate degree of flexibility to respond to matters that can only be properly determined at the planning application stage, once detailed surveys, assessments and design work have been undertaken.

It is essential that the policy for Site TC1 is considered in the context of the Council’s significant and acknowledged housing land shortfall.

The HELAA and Site Selection Methodology Background Paper (January 2026) confirms that, following an extensive review of all available sites in summer 2025 – including sites previously rejected due to landscape and sustainability concerns – the total identified supply across the district is 8,427 dwellings, equating to approximately 495 dwellings per annum over the 17-year plan period.

This is compared to a Local Housing Need (LHN) of 912 dwellings per annum, calculated using the Government’s revised standard method following the December 2024 NPPF. The district therefore faces a structural shortfall of over 45% against its identified housing need. In this context, each and every allocated site – including Site TC1 – makes a meaningful and necessary contribution to the Council’s ability to demonstrate soundness at examination.

The HELAA Background Paper further records that the review process involved reconsidering sites previously rejected within the High Weald National Landscape (HWNL), specifically to determine whether impacts could be mitigated to an acceptable degree. The fact that Site TC1 survived and was maintained through this rigorous review process is a significant material consideration that further demonstrates its appropriateness for allocation.

Critically, the Windfall Assessment (Appendix 2 of the HELAA Background Paper) records that Ticehurst achieved a net small-site windfall completion figure of -5 dwellings over the 10-year monitoring period from 2009/10 to 2018/19 (Figure 7 of the Windfall Assessment). This is one of only two settlements in the district to record a negative figure.

In other words, Ticehurst has experienced a net loss of dwellings through organic small-site development over the past decade. This data reinforces the importance of Policy TC1 as the principal mechanism for delivering meaningful housing growth in the village, and further strengthens the case for ensuring the policy is not unnecessarily restrictive in terms of the quantum of development it can accommodate.

Support for the Allocation in Principle

The allocation of Land at Steellands Farm is supported without reservation in principle. The site is well related to the existing settlement of Ticehurst, lying adjacent to established residential development along Field Rise, and in close proximity to Ticehurst and Flimwell Primary School. It has a realistic prospect of delivering a vehicular and pedestrian access from Field Rise, as confirmed by initial Highways Authority commentary referenced in the supporting text.

Site TC1’s identification as a Greenfield site within the High Weald National Landscape is acknowledged, and the landowner is committed to ensuring that any development is designed sensitively and in accordance with the policies of the National Landscape designation. The requirements of Policy LAN3 and the High Weald National Landscape Unit’s Technical Advice Note on Dark Skies are fully accepted.

Dwelling Numbers, Density and Design (Policy TC1)

Issue

The policy states that the site is allocated for “some 54 new dwellings” at an indicative density of 30 dwellings per hectare across an indicative built development area of 1.8 hectares.

Whilst the use of “some” is noted and welcomed as providing a degree of flexibility, it is considered that the policy and its supporting text do not go far enough in making clear the genuinely indicative nature of all the numerical parameters.

In this regard, attention is drawn to the density guidance set out in the HELAA and Site Selection Methodology Background Paper (January 2026). Figure 4 of that document sets out the “Option B – higher density” approach adopted for calculating site capacity in the HELAA, which establishes an appropriate density range for villages with development boundaries of 25–45 dwellings per hectare, with an average of 35 dph.

The indicative density of 30 dph proposed for Site TC1 falls below this average and at the lower end of the applicable range. The policy should not therefore be interpreted as constraining development to 30 dph where detailed design work, landscape assessment and the requirements of the HWNL support a higher density within this established range.

Given the district’s acute housing shortfall and the Council’s need to maximise the efficient use of land – as required by NPPF paragraph 130 – it is particularly important that the policy does not inadvertently cap development at the lower end of the density range.

Recommended Modification

It is requested that the supporting text is amended to make explicit that the dwelling number, density and built area statistics are genuinely indicative and do not constitute fixed parameters or a ceiling on development. The precise quantum of development will be determined at the planning application stage, informed by detailed landscape sensitivity assessment, site-specific design, and the findings of all required technical surveys. A modest variation in dwelling numbers above or below the indicative figure should not be treated as a departure from the allocation.
Suggested addition to supporting text:

“The indicative dwelling figure of ‘some 54’, the indicative density of 30 dwellings per hectare, and the associated built area statistics are not intended to operate as fixed parameters or as a ceiling on development. The applicable density range for village sites, as set out in the Council’s HELAA evidence base, is 25–45 dwellings per hectare. The precise number of dwellings, layout, heights and built footprint will be determined at the planning application stage, having regard to the findings of the required landscape sensitivity assessment and other technical evidence, and subject to the requirements of this policy.”

Building Heights

A specific concern arises from the following passage in the supporting text to Policy TC1, which relates to the southern field:

“…this part of the site could be more suited to low-rise dwellings.”

It is submitted that this reference to “low-rise dwellings” is premature and inappropriate at the allocation stage, and should be removed or substantially qualified. The reasons for this are set out below.

First, building height is a detailed design matter that should not be fixed – even in indicative terms – before the landscape sensitivity assessment required by the policy has been carried out. That assessment is specifically commissioned to determine an appropriate layout, form and detailed design for the site. Pre-empting its conclusions by characterising the southern field as suited only to “low-rise” development in the supporting text risks fettering the assessment before it has taken place, and could prejudge the outcome of the planning application process. For Site TC1 it is truly difficult to be able to assess the impact that the proposals could have on the National Landscape from Lower Platts without this assessment, given the rising topography of Cherry Tree Field.

Secondly, the concept of “low-rise” is undefined both within Policy TC1 and within the wider Local Plan. Without a clear and agreed definition – whether expressed in terms of storeys, ridge height, eaves height or relationship to adjacent buildings – the reference is incapable of forming a reliable or consistent basis for development management decisions. Its inclusion in the supporting text therefore creates ambiguity rather than clarity, and risks generating unnecessary conflict at the application stage.

Thirdly, whether a two-storey dwelling constitutes “low-rise” in this context is a matter that can only be assessed having regard to the topography, the character of the surrounding area, the findings of the landscape sensitivity assessment, and the conclusions of the heritage impact assessment in respect of the adjacent listed public house. All of these matters remain to be properly evaluated. It is therefore not possible at this stage to conclude that anything other than a particular building height would be appropriate, and it would be wrong in principle for the allocation to purport to do so.

Fourthly, the NPPF (paragraph 130) requires planning policies to ensure developments make optimal use of the potential of each site. Fixing – or implying – a height constraint in the supporting text before the landscape evidence base has been completed is inconsistent with this requirement, particularly in the context of the district’s significant housing land shortfall.

Recommended Modification

It is requested that the reference to “low-rise dwellings” in the supporting text to Policy TC1 be removed and replaced with wording that appropriately defers this question to the required assessment process. The following amendment is proposed:

Current wording: “…this part of the site could be more suited to low-rise dwellings.”

Suggested wording: “…the appropriate scale, height and massing of development in this part of the site will be determined through the landscape sensitivity assessment required by the policy, having regard to the topography, the character and appearance of the surrounding area, and the setting of the adjacent Grade II listed public house.”

This approach ensures that building height is considered carefully and on the basis of proper evidence, without either ruling out or pre-approving any particular scale of development in advance of that evidence being produced. It is consistent with the NPPF’s approach to design, which requires decisions to be based on thorough assessment of context rather than blanket height restrictions applied at the plan-making stage.

Design and Landscape Requirements

The landscape and design-related policy requirements in Policy TC1 are accepted in full. The landowner recognises the sensitivity of the High Weald National Landscape designation and the HELAA Background Paper’s detailed framework for assessing HWNL impacts – covering natural systems, settlement character, routeways, woodland, fieldscape, dark skies, aesthetic qualities and land-based economy.

The landowner is committed to ensuring that development conserves and enhances landscape character in accordance with this framework. The following requirements are fully supported:

• The requirement for a landscape sensitivity assessment to inform layout, form and detailed design;
• Retention and enhancement of historic hedgerows and treebelts on all site boundaries, consistent with the HELAA’s fieldscape and settlement character components;
• Retention and protection of the existing pond, with an appropriate ecological buffer informed by survey;
• Compliance with Policy LAN3 and the High Weald National Landscape Unit’s Technical Advice Note on Dark Skies, consistent with the HELAA dark skies character component;
• Delivery of appropriate landscape buffers to the setting of the Grade II listed public house.

It is, however, respectfully requested that the policy wording makes clear that specific parameters – such as the precise extent of tree planting, the design of boundary treatments, and the configuration of buffers – will be determined through the landscape sensitivity assessment and other technical work required by the policy, rather than being fixed at the allocation stage.

This would ensure the policy provides the appropriate framework for high-quality design without unnecessarily prejudging outcomes that can only properly be established through detailed technical work.

Green Infrastructure Quantum and Layout

Issue

The policy allocates “some 2ha of Green Infrastructure” and sets out specific requirements for tree planting and open space in both the southern and northern fields. Whilst the commitment to providing meaningful green infrastructure is fully supported, the prescriptive delineation of Green Infrastructure arrangements across both fields at this stage may constrain the ability to optimise the overall scheme through detailed design, and could inadvertently reduce the buildable area below what the landscape evidence ultimately justifies.

Recommended Modification

It is recommended that the policy retains the requirement for an appropriate and policy-compliant quantum of Green Infrastructure, but that the detailed layout, extent and precise configuration of green infrastructure provision – including specific tree planting locations, buffer zones and open space arrangements – be determined at the planning application stage, informed by:

• The landscape sensitivity assessment required by the policy;
• An ecological survey and habitat assessment, including assessment of the pond and its buffer;
• A heritage impact assessment in relation to the setting of the Grade II listed public house to the east;
• Detailed design and masterplanning work.

This approach would better reflect the NPPF’s requirement that allocated site policies provide sufficient flexibility to adapt to changing circumstances and technical findings, while still clearly establishing the Council’s expectations for high-quality green infrastructure delivery.

Access Arrangements

Issue

Policy TC1 requires vehicular and pedestrian access onto Field Rise “to the satisfaction of the Highways Authority,” and also includes requirements for a Transport Assessment and an off-site pedestrian and cycle path towards Tinkers Lane. These requirements are broadly accepted.

However, the policy wording for the pedestrian and cycle link to Tinkers Lane does not carry forward the important land availability caveat that is explicitly acknowledged in the supporting text, which states that the path would be “subject to land being available.”

Recommended Modification

It is requested that criterion (ix) of the policy is amended to reflect the land availability caveat:

Current wording: “Include a new pedestrian and cycle path leading from Field Rise northwards through the site, and providing for a link beyond the northeastern boundary towards Tinkers Lane.”

Suggested wording: “Include a new pedestrian and cycle path leading from Field Rise northwards through the site, and providing for a connection beyond the northeastern boundary towards Tinkers Lane, subject to the availability of land and the agreement of the relevant landowners.”
This modification would ensure the policy requirement is reasonable, proportionate and deliverable, consistent with the NPPF’s tests of soundness.

Affordable Housing

Policy TC1 requires the provision of a policy-compliant amount of on-site affordable housing in line with Policy HOU2 of the Rother Local Plan. This requirement is noted. The landowner is committed in principle to the delivery of affordable housing on the site.

It is, however, requested that the policy makes clear that the precise tenure split, mix and delivery mechanism for affordable housing will be agreed at the planning application stage through an open-book viability assessment where required, in line with national planning policy and the NPPF’s guidance on viability. Given the significant on-site obligations proposed – including substantial green infrastructure, access improvements, landscape mitigation and the demolition of existing farm buildings – it is important that the policy does not foreclose the ability to test viability at the application stage if necessary.

Soundness

The Rother Local Plan is required to be submitted for examination by December 2026. In the context of a Local Housing Need of 912 dwellings per annum and an identified supply of only 495 dwellings per annum – a shortfall of over 45% – the soundness of the plan will depend in significant part on demonstrating that allocated sites are genuinely deliverable and that their policies are not unnecessarily restrictive.

Subject to the modifications requested in these representations, it is considered that Policy TC1 would be:

• Positively prepared – the allocation makes a meaningful contribution to Rother’s housing supply at a time of acute district-wide shortfall. The HELAA Background Paper confirms that Ticehurst has seen a net loss of dwellings through small-site development over the past decade, making Site TC1 the primary vehicle for growth in the village;
• Justified – the site has been identified through a robust and comprehensive HELAA process and has been specifically reconsidered and maintained through the summer 2025 HELAA review, which focused on maximising deliverable supply within the HWNL;
• Effective – with the requested modifications, the policy would provide a deliverable and flexible framework for development, capable of responding to the findings of technical assessments without requiring a formal departure from the allocation;
• Consistent with national policy – the allocation and its policy requirements, as modified, would be consistent with the NPPF (December 2024), including policies on housing delivery, National Landscape protection, biodiversity net gain, efficient use of land and design quality. The NPPF (paragraph 130) specifically requires that planning policies avoid homes being built at low densities where there is a housing land shortfall, and the policy should not therefore cap density at the lower end of the applicable range.

Summary of Requested Modifications

The following modifications to Policy TC1 and its supporting text are requested:

• Amend supporting text to confirm that the figure of ‘some 54 dwellings’, the density of 30 dph, and the indicative built area of 1.8 hectares are genuinely indicative and do not constitute fixed parameters or a ceiling. The applicable density range for village sites is 25–45 dph (average 35 dph) as established in the HELAA evidence base, and precise quantum will be determined at application stage.
• Amend the policy to confirm that the detailed layout and configuration of Green Infrastructure – including tree planting locations, buffer extents and open space arrangements – will be determined at application stage, informed by the landscape sensitivity assessment, ecological surveys, heritage impact assessment and masterplanning work.
• Remove the reference to ‘low-rise dwellings’ in the supporting text for the southern field and replace with wording that defers the question of appropriate scale, height and massing to the landscape sensitivity assessment required by the policy, to be determined having regard to topography, local character and the setting of the adjacent listed public house.
• Amend criterion (ix) to include the caveat that the off-site pedestrian and cycle connection towards Tinkers Lane is subject to land availability and landowner agreement, consistent with the supporting text.
• Add clarifying text to confirm that specific landscape and design parameters will be determined through the required technical assessments at application stage rather than being fixed by the allocation.
• Confirm in the policy that the affordable housing tenure, mix and mechanism will be agreed at application stage and that viability testing will be available where the cumulative obligations of the policy require it.

Should you have any questions regarding our representations, please do not hesitate to get in contact with ourselves or the landowner.

I am selecting this option only because the online consultation form does not allow respondents to comment on the merits of the individual sites separately. TC1 and TC2 group together sites with very different planning considerations, and the form forces a single response for multiple allocations. As set out in my full written email submission of 22 March 2026, I support Sites 6 and 7 (Cherry Tree Fields and Steelands Farm) subject to specific provisos, but I do not support Site 8 (Orchard Farm) as currently proposed due to unresolved ancient‑woodland and sewage‑capacity constraints. My detailed reasoning is provided in my full submission.

Further to previous representations I agree the suggestion to build 115 houses to the north of Flimwell village is development fit for a town and an example of over development. I doubt the current size of Flimwell is very much larger than 150 houses in total.
No account appears to have been taken of the following three points:-
1) the sewage treatment works at Dale Hill golf course is currently having difficulty coping with the effluent now being produced. Flimwell Park and some of the houses to the north of the Hawkhurst road presently send their sewage to 3 very large tanks situated to the north of the track leading to Keepers Cottage. These are constantly being emptied by 30-40 ton road tankers and the sewage taken to Tonbridge. The plan I was told 3 years ago was to put in a new sewer in the Hawkhurst road within 3 years but so far very little has changed and I doubt Southern Water will find the funds necessary for the improvement as they are already millions in debt. Apparently the sewage goes to the pumping station situated opposite Sunnybank Garage where it is macerated and then pumped up a 2 inch pipe which is now unable to cope with the flow of sewage before being sent on its way to the sewage treatment plant at Dale Hill.
2) No consideration appears to have been given to the future development of the A21. I am aware that the land necessary for the Flimwell "bypass" has been bought and then sold back twice in the last 50 years. It does not make sense to build houses on land that was once allocated for this highway development as sometime in the future the land will be needed for highway development as Access to Hastings may become a priority to a future government.
3) The development to the south of the A21 is ribbon development of the worst sort such there will be little farmland left between Flimwell and Hurst Green with access problems on to a very busy highway.

Please confirm receipt of my observations, attached, regarding all 10 proposed sites within the above villages.

May I express my disappointment that the online consultation format did not allow respondents to comment on the merits of the individual sites. Several allocations with very different planning considerations were grouped together under single response boxes, forcing a single ‘support’ or ‘object’ choice for multiple unrelated proposals. This structure makes it impossible to give accurate, site‑specific feedback within the online form itself, which is why my full observations were submitted separately by email on 22 March 2026.

May I take this opportunity to compliment the quality of interaction between your officers and the public at the recent public consultation at Ticehurst Village Hall. Particularly, [redacted] who engaged well on the observations put to him, which led to a constructive discourse on the various sites.

Yours faithfully

Rother Development Plan
I recognise the considerable pressure placed on local authorities by central government to deliver new housing, and I understand the natural reluctance of local communities to see change in the character of the places they value. While it is entirely reasonable for residents to wish to protect the landscape and identity of their environment, there is also a clear need for additional homes within the parish. That need must, however, be met in a way that provides a balanced mix of housing types and tenures, ensuring that all sections of the community — including young families, local workers, and older residents wishing to downsize — can be properly accommodated. My comments on the proposed sites are therefore made in the spirit of supporting appropriate, well located development that meets genuine local need without undermining the qualities that make the parish distinctive.
Flimwell – Sites 1, 2 and 3 (Cherry Tree Cluster)
Site 1 — Cherry Tree Nursery, Hawkhurst Road, Flimwell
Support, subject to provisos
This site lies immediately adjacent to Sites 2 and 3, and all three share the same fundamental characteristics: they sit outside the Flimwell development boundary and within the High Weald AONB, yet they form a coherent cluster on the edge of the existing settlement. Notwithstanding the rejection of my own Church Farm site on similar grounds, I support the allocation of this land because it represents a more logical and less harmful location for growth than many alternatives.
The site can accommodate modest housing if handled sensitively. However, the cluster of Sites 1–3 is affected by the same access and traffic constraints associated with the A268/A21 junction. Although the junction is controlled by intelligent traffic lights, peak time queues regularly build up on the minor road approaches, extending:
• eastwards to the Flimwell parish boundary, and
• westwards along Union Street.
This demonstrates that the junction is already operating close to capacity at busy times.
In theory, a roundabout could alleviate these delays, but delivering such a scheme would require the compulsory purchase of the Furniture Barn site and the redundant public house. The public house is a listed building and sits directly where the central island of a roundabout would need to be located, making this option practically unachievable.
Given these constraints, development at Site 1 is acceptable only if:
• a clear and deliverable highway mitigation strategy is secured,
• pedestrian connectivity to village facilities is improved, and
• building heights and boundary treatments are designed to minimise landscape impact within the AONB.
With these provisos, Site 1 represents an appropriate and deliverable location for new housing.
Site 2 — Junction of London Road and A268 (North)
Support, subject to provisos and confirmation from National Highways
This site sits immediately alongside Sites 1 and 3 and shares the same characteristics: it lies outside the Flimwell development boundary and within the High Weald AONB, yet forms part of a coherent cluster of land well related to the existing settlement. I support the allocation in principle, provided that the known constraints are properly addressed.
A key issue for this site is its relationship with the A21/A268 junction, which is controlled by intelligent traffic lights. While these operate efficiently under normal conditions, peak time queues regularly build up on the minor road approaches, extending:
• eastwards to the Flimwell parish boundary, and
• westwards along Union Street.
This demonstrates that the junction is already operating close to capacity.
Historically, Sites 2 and 3 were identified as land required for future A21 improvements. If these sites are now allocated for housing, that land will no longer be available for strategic road upgrades. It is therefore essential that National Highways is formally consulted to confirm whether:
• the safeguarding requirement still exists, and
• development would compromise any future improvement scheme.
In theory, a roundabout could alleviate peak time delays, but delivering such a scheme would require the compulsory purchase of the Furniture Barn site and the redundant public house. The public house is a listed building and sits directly where the central island of a roundabout would need to be located, making this option practically unachievable.
Given these constraints, development at Site 2 is acceptable only if:
• National Highways confirms that the land is no longer required for A21 improvements,
• a deliverable highway mitigation strategy is secured, and
• pedestrian connectivity to village facilities is improved.
With these provisos, Site 2 can contribute positively to local housing needs.
Site 3 — Land to the south of A268, Hawkhurst Road
Support, subject to provisos and confirmation from National Highways
Site 3 forms part of the same cluster as Sites 1 and 2, lying outside the Flimwell development boundary and within the High Weald AONB. Notwithstanding these constraints, I support the allocation in principle because the land is well related to the existing settlement and represents a more coherent and less harmful location for growth than many alternatives.
However, the site shares the same strategic constraints as Site 2. Historically, Sites 2 and 3 were earmarked for future A21 improvement works, and allocating them for housing may sterilise land required for long term strategic transport upgrades. It is therefore essential that National Highways is formally consulted to confirm whether:
• the safeguarding requirement still applies, and
• development would compromise any future A21 scheme.
In addition to the A21 safeguarding issue, pedestrian access from Site 3 to the western part of the village is severely constrained there being no footpath. Reaching the village hall and other facilities requires crossing the A21. While there is a controlled pedestrian crossing on the north side of the traffic light junction, there is:
• no pedestrian crossing on the south side of the A21, and
• no crossing of the A268 to the north to enable pedestrians to reach the existing A21 crossing safely.
This means that residents of Site 3 would have no safe or direct pedestrian route to the western section of the village and could be forced to negotiate fast moving traffic at an already complex junction.
Given these constraints, development at Site 3 is acceptable only if:
• National Highways confirms that the land is no longer required for A21 improvements,
• a deliverable pedestrian access solution is secured, and
• landscape, drainage and access impacts are properly mitigated.
With these provisos, Site 3 can be considered a suitable location for modest, sensitively designed development.
Flimwell – Other Sites
Site 4 — Land to the rear of Fruitfields, High Street, Flimwell
Strong objection
I strongly object to the allocation of this site. While there is existing planning permission for a small development within the area marked in blue, the extended areas marked in yellow and red raise significant and insurmountable concerns.
First, the yellow and red areas encroach directly onto ancient woodland and a thriving wildlife habitat. This woodland forms part of a wider ecological corridor and supports a rich variety of species. Any further encroachment would cause irreversible harm to biodiversity and undermine the integrity of the habitat.
Second, the Fruitfields properties were constructed with specific drainage channels beneath them to allow surface water to pass under the houses. This system was designed to take runoff from Union Street and the properties opposite, effectively creating a wetland area that functions as an informal attenuation system. The land therefore performs an important hydrological role, and development would disrupt established drainage patterns, increasing flood risk both on site and downstream.
Third, it is understood locally that the area marked in yellow was historically used as an informal dumping ground. This raises legitimate concerns about ground contamination, stability, and the feasibility of safe construction. Any remediation would be complex, costly, and uncertain, and may not be achievable without significant environmental harm.
Taken together — the presence of ancient woodland, the ecological value of the habitat, the engineered drainage function of the land, and the suspected contamination — these factors make the site impossible to develop safely or sustainably. It should not be taken forward for allocation.
Site 5 — Cedar Farm, Hastings Road, Flimwell
Approve as an employment development, subject to provisos
I support the allocation of Cedar Farm for employment use. Flimwell has a clear need for local employment opportunities, and this site is well placed to accommodate small scale commercial activity without undermining the character of the wider area. However, any development must be carefully controlled to ensure that it remains compatible with its rural and residential surroundings.
In particular:
• building profiles must remain low, both to protect the landscape setting of the High Weald AONB and to avoid creating an overbearing presence when viewed from Hastings Road and neighbouring properties;
• heavy industrial uses must be excluded, as such activities would generate noise, traffic, and environmental impacts inappropriate for this location;
• environmental safeguards should be required to ensure that lighting, noise, and operational hours do not adversely affect the surrounding area.
With these provisos in place, Cedar Farm represents a suitable and beneficial location for employment development that can support the local economy while protecting the environmental quality of Flimwell.
Sites 6 and 7 — Land at Cherry Tree Fields & Land at Steelands Farm, Flimwell
Approve, subject to the provision of a safe pedestrian footpath
Sites 6 and 7 form a natural cluster on the eastern side of Flimwell, close to the primary school and served by a network of minor roads. In principle, both sites represent appropriate locations for modest residential development, provided that a critical pedestrian safety issue is addressed.
At present, pedestrians approaching the village from the east — including schoolchildren — must use the one way section of the B2087, which has no footway. This creates a hazardous route at all times of day, but particularly during school drop off and pick up periods when traffic levels are highest.
To make development at Sites 6 and 7 safe and sustainable, it is essential that a new footpath is provided behind the Cherry Tree public house, linking through to Tinkers Lane. This would:
• remove the need for pedestrians to use the un footpathed one way section of the B2087,
• provide a safe and direct walking route to the primary school,
• improve connectivity to village facilities, and
• ensure that new development does not exacerbate existing safety risks.
With this footpath secured as a condition of allocation, Sites 6 and 7 can be supported as suitable locations for new housing that integrate well with the village and improve pedestrian safety for existing and future residents.
Site 8 — Orchard Farm, Ticehurst
Suitable only for limited development, subject to resolution of key constraints
This site may be suitable for a limited and carefully designed development, but only if two significant constraints are fully addressed.
First, the site lies immediately adjacent to ancient woodland, which forms an important ecological asset and supports a well established wildlife habitat. Any development must avoid encroachment on this woodland and must include robust measures to protect the root protection areas, habitat corridors, and the wider ecological function of the site. Without such safeguards, the proposal would cause unacceptable environmental harm.
Second, the sewage infrastructure serving this part of Ticehurst is currently inadequate. The neighbouring recent development at Lower St Mary’s has been affected by persistent sewage capacity problems, with repeated failures reported by residents. Until these issues are fully resolved and the system demonstrably upgraded to accommodate additional load, it would be inappropriate to introduce further dwellings that would exacerbate an already compromised network.
If — and only if — these two constraints are satisfactorily addressed, a small scale, sensitively designed scheme could be considered appropriate. However, the scale and layout of any development must be tightly controlled to ensure that:
• the ancient woodland is fully protected,
• ecological connectivity is maintained, and
• the upgraded sewage system can reliably support the additional homes.
Subject to these conditions, the site may have potential for limited development, but it should not be allocated for housing unless the environmental and infrastructure constraints are demonstrably resolved.
Site 9 — Land at Lymden Lane, Stonegate
Object
I object to the allocation of this site. Lymden Lane is a narrow rural road with no footways, limited passing places, and poor visibility. Pedestrians — including children walking to the primary school — are forced to walk in the carriageway. There is no safe or practical opportunity to provide a footpath due to the tight boundaries, hedgerows, and the rural character of the lane.
As a result, there is no safe pedestrian route from the site to the school or the village centre. Any development here would increase pedestrian and vehicle movements on a road that is already hazardous, particularly at school times.
The site also forms part of the natural drainage catchment feeding the pond at the Acorns development. Altering this land risks disrupting established drainage patterns and could increase surface water problems both on site and downstream.
In addition, Stonegate suffers from long standing sewage capacity issues, with repeated failures affecting properties across the village. Until the system is comprehensively upgraded, it cannot support additional dwellings.
Given the combination of unsafe access, lack of pedestrian infrastructure, drainage sensitivity, and inadequate sewage capacity, Site 9 is not suitable for allocation.
Site 10 — Land east of Bardown Road, Stonegate
Object
I object to the allocation of this site. Like Site 9, it is served by narrow, un footpathed rural lanes — Bardown Road and Lymden Lane — both of which carry fast moving traffic and offer no safe walking route to the primary school or village centre. There is no realistic prospect of providing a footway without fundamentally altering the rural character of the area or requiring land that is not available.
The site itself is small and constrained, with limited space for parking and turning. Vehicles would likely need to reverse onto Lymden Lane, creating an unacceptable highway safety hazard on an already narrow and busy rural road.
Stonegate’s sewage infrastructure remains inadequate, with known capacity problems affecting existing residents. Adding further dwellings would place additional pressure on a system that is already failing.
Taken together — the unsafe pedestrian environment, the highway safety risks, the site specific access constraints, and the ongoing sewage capacity failures — Site 10 is not a suitable or sustainable location for development.
In conclusion, my comments are offered in the spirit of supporting a fair, evidence based Local Plan that meets genuine local need while safeguarding the qualities that make our parish distinctive. I recognise the pressures on the authority to deliver new homes, and I do not oppose development where it is appropriate, sustainable, and properly supported by infrastructure. My concern is simply that each site is assessed on its merits, with full regard to landscape, ecology, access, drainage, and the lived realities of the communities affected. If these principles are applied consistently, the resulting Plan will serve both current residents and future generations well.
Yours faithfully,

Please confirm receipt of my observations, attached, regarding all 10 proposed sites within the above villages.

May I express my disappointment that the online consultation format did not allow respondents to comment on the merits of the individual sites. Several allocations with very different planning considerations were grouped together under single response boxes, forcing a single ‘support’ or ‘object’ choice for multiple unrelated proposals. This structure makes it impossible to give accurate, site‑specific feedback within the online form itself, which is why my full observations were submitted separately by email on 22 March 2026.

May I take this opportunity to compliment the quality of interaction between your officers and the public at the recent public consultation at Ticehurst Village Hall. Particularly, [redacted] who engaged well on the observations put to him, which led to a constructive discourse on the various sites.

Yours faithfully

Rother Development Plan
I recognise the considerable pressure placed on local authorities by central government to deliver new housing, and I understand the natural reluctance of local communities to see change in the character of the places they value. While it is entirely reasonable for residents to wish to protect the landscape and identity of their environment, there is also a clear need for additional homes within the parish. That need must, however, be met in a way that provides a balanced mix of housing types and tenures, ensuring that all sections of the community — including young families, local workers, and older residents wishing to downsize — can be properly accommodated. My comments on the proposed sites are therefore made in the spirit of supporting appropriate, well located development that meets genuine local need without undermining the qualities that make the parish distinctive.
Flimwell – Sites 1, 2 and 3 (Cherry Tree Cluster)
Site 1 — Cherry Tree Nursery, Hawkhurst Road, Flimwell
Support, subject to provisos
This site lies immediately adjacent to Sites 2 and 3, and all three share the same fundamental characteristics: they sit outside the Flimwell development boundary and within the High Weald AONB, yet they form a coherent cluster on the edge of the existing settlement. Notwithstanding the rejection of my own Church Farm site on similar grounds, I support the allocation of this land because it represents a more logical and less harmful location for growth than many alternatives.
The site can accommodate modest housing if handled sensitively. However, the cluster of Sites 1–3 is affected by the same access and traffic constraints associated with the A268/A21 junction. Although the junction is controlled by intelligent traffic lights, peak time queues regularly build up on the minor road approaches, extending:
• eastwards to the Flimwell parish boundary, and
• westwards along Union Street.
This demonstrates that the junction is already operating close to capacity at busy times.
In theory, a roundabout could alleviate these delays, but delivering such a scheme would require the compulsory purchase of the Furniture Barn site and the redundant public house. The public house is a listed building and sits directly where the central island of a roundabout would need to be located, making this option practically unachievable.
Given these constraints, development at Site 1 is acceptable only if:
• a clear and deliverable highway mitigation strategy is secured,
• pedestrian connectivity to village facilities is improved, and
• building heights and boundary treatments are designed to minimise landscape impact within the AONB.
With these provisos, Site 1 represents an appropriate and deliverable location for new housing.
Site 2 — Junction of London Road and A268 (North)
Support, subject to provisos and confirmation from National Highways
This site sits immediately alongside Sites 1 and 3 and shares the same characteristics: it lies outside the Flimwell development boundary and within the High Weald AONB, yet forms part of a coherent cluster of land well related to the existing settlement. I support the allocation in principle, provided that the known constraints are properly addressed.
A key issue for this site is its relationship with the A21/A268 junction, which is controlled by intelligent traffic lights. While these operate efficiently under normal conditions, peak time queues regularly build up on the minor road approaches, extending:
• eastwards to the Flimwell parish boundary, and
• westwards along Union Street.
This demonstrates that the junction is already operating close to capacity.
Historically, Sites 2 and 3 were identified as land required for future A21 improvements. If these sites are now allocated for housing, that land will no longer be available for strategic road upgrades. It is therefore essential that National Highways is formally consulted to confirm whether:
• the safeguarding requirement still exists, and
• development would compromise any future improvement scheme.
In theory, a roundabout could alleviate peak time delays, but delivering such a scheme would require the compulsory purchase of the Furniture Barn site and the redundant public house. The public house is a listed building and sits directly where the central island of a roundabout would need to be located, making this option practically unachievable.
Given these constraints, development at Site 2 is acceptable only if:
• National Highways confirms that the land is no longer required for A21 improvements,
• a deliverable highway mitigation strategy is secured, and
• pedestrian connectivity to village facilities is improved.
With these provisos, Site 2 can contribute positively to local housing needs.
Site 3 — Land to the south of A268, Hawkhurst Road
Support, subject to provisos and confirmation from National Highways
Site 3 forms part of the same cluster as Sites 1 and 2, lying outside the Flimwell development boundary and within the High Weald AONB. Notwithstanding these constraints, I support the allocation in principle because the land is well related to the existing settlement and represents a more coherent and less harmful location for growth than many alternatives.
However, the site shares the same strategic constraints as Site 2. Historically, Sites 2 and 3 were earmarked for future A21 improvement works, and allocating them for housing may sterilise land required for long term strategic transport upgrades. It is therefore essential that National Highways is formally consulted to confirm whether:
• the safeguarding requirement still applies, and
• development would compromise any future A21 scheme.
In addition to the A21 safeguarding issue, pedestrian access from Site 3 to the western part of the village is severely constrained there being no footpath. Reaching the village hall and other facilities requires crossing the A21. While there is a controlled pedestrian crossing on the north side of the traffic light junction, there is:
• no pedestrian crossing on the south side of the A21, and
• no crossing of the A268 to the north to enable pedestrians to reach the existing A21 crossing safely.
This means that residents of Site 3 would have no safe or direct pedestrian route to the western section of the village and could be forced to negotiate fast moving traffic at an already complex junction.
Given these constraints, development at Site 3 is acceptable only if:
• National Highways confirms that the land is no longer required for A21 improvements,
• a deliverable pedestrian access solution is secured, and
• landscape, drainage and access impacts are properly mitigated.
With these provisos, Site 3 can be considered a suitable location for modest, sensitively designed development.
Flimwell – Other Sites
Site 4 — Land to the rear of Fruitfields, High Street, Flimwell
Strong objection
I strongly object to the allocation of this site. While there is existing planning permission for a small development within the area marked in blue, the extended areas marked in yellow and red raise significant and insurmountable concerns.
First, the yellow and red areas encroach directly onto ancient woodland and a thriving wildlife habitat. This woodland forms part of a wider ecological corridor and supports a rich variety of species. Any further encroachment would cause irreversible harm to biodiversity and undermine the integrity of the habitat.
Second, the Fruitfields properties were constructed with specific drainage channels beneath them to allow surface water to pass under the houses. This system was designed to take runoff from Union Street and the properties opposite, effectively creating a wetland area that functions as an informal attenuation system. The land therefore performs an important hydrological role, and development would disrupt established drainage patterns, increasing flood risk both on site and downstream.
Third, it is understood locally that the area marked in yellow was historically used as an informal dumping ground. This raises legitimate concerns about ground contamination, stability, and the feasibility of safe construction. Any remediation would be complex, costly, and uncertain, and may not be achievable without significant environmental harm.
Taken together — the presence of ancient woodland, the ecological value of the habitat, the engineered drainage function of the land, and the suspected contamination — these factors make the site impossible to develop safely or sustainably. It should not be taken forward for allocation.
Site 5 — Cedar Farm, Hastings Road, Flimwell
Approve as an employment development, subject to provisos
I support the allocation of Cedar Farm for employment use. Flimwell has a clear need for local employment opportunities, and this site is well placed to accommodate small scale commercial activity without undermining the character of the wider area. However, any development must be carefully controlled to ensure that it remains compatible with its rural and residential surroundings.
In particular:
• building profiles must remain low, both to protect the landscape setting of the High Weald AONB and to avoid creating an overbearing presence when viewed from Hastings Road and neighbouring properties;
• heavy industrial uses must be excluded, as such activities would generate noise, traffic, and environmental impacts inappropriate for this location;
• environmental safeguards should be required to ensure that lighting, noise, and operational hours do not adversely affect the surrounding area.
With these provisos in place, Cedar Farm represents a suitable and beneficial location for employment development that can support the local economy while protecting the environmental quality of Flimwell.
Sites 6 and 7 — Land at Cherry Tree Fields & Land at Steelands Farm, Flimwell
Approve, subject to the provision of a safe pedestrian footpath
Sites 6 and 7 form a natural cluster on the eastern side of Flimwell, close to the primary school and served by a network of minor roads. In principle, both sites represent appropriate locations for modest residential development, provided that a critical pedestrian safety issue is addressed.
At present, pedestrians approaching the village from the east — including schoolchildren — must use the one way section of the B2087, which has no footway. This creates a hazardous route at all times of day, but particularly during school drop off and pick up periods when traffic levels are highest.
To make development at Sites 6 and 7 safe and sustainable, it is essential that a new footpath is provided behind the Cherry Tree public house, linking through to Tinkers Lane. This would:
• remove the need for pedestrians to use the un footpathed one way section of the B2087,
• provide a safe and direct walking route to the primary school,
• improve connectivity to village facilities, and
• ensure that new development does not exacerbate existing safety risks.
With this footpath secured as a condition of allocation, Sites 6 and 7 can be supported as suitable locations for new housing that integrate well with the village and improve pedestrian safety for existing and future residents.
Site 8 — Orchard Farm, Ticehurst
Suitable only for limited development, subject to resolution of key constraints
This site may be suitable for a limited and carefully designed development, but only if two significant constraints are fully addressed.
First, the site lies immediately adjacent to ancient woodland, which forms an important ecological asset and supports a well established wildlife habitat. Any development must avoid encroachment on this woodland and must include robust measures to protect the root protection areas, habitat corridors, and the wider ecological function of the site. Without such safeguards, the proposal would cause unacceptable environmental harm.
Second, the sewage infrastructure serving this part of Ticehurst is currently inadequate. The neighbouring recent development at Lower St Mary’s has been affected by persistent sewage capacity problems, with repeated failures reported by residents. Until these issues are fully resolved and the system demonstrably upgraded to accommodate additional load, it would be inappropriate to introduce further dwellings that would exacerbate an already compromised network.
If — and only if — these two constraints are satisfactorily addressed, a small scale, sensitively designed scheme could be considered appropriate. However, the scale and layout of any development must be tightly controlled to ensure that:
• the ancient woodland is fully protected,
• ecological connectivity is maintained, and
• the upgraded sewage system can reliably support the additional homes.
Subject to these conditions, the site may have potential for limited development, but it should not be allocated for housing unless the environmental and infrastructure constraints are demonstrably resolved.
Site 9 — Land at Lymden Lane, Stonegate
Object
I object to the allocation of this site. Lymden Lane is a narrow rural road with no footways, limited passing places, and poor visibility. Pedestrians — including children walking to the primary school — are forced to walk in the carriageway. There is no safe or practical opportunity to provide a footpath due to the tight boundaries, hedgerows, and the rural character of the lane.
As a result, there is no safe pedestrian route from the site to the school or the village centre. Any development here would increase pedestrian and vehicle movements on a road that is already hazardous, particularly at school times.
The site also forms part of the natural drainage catchment feeding the pond at the Acorns development. Altering this land risks disrupting established drainage patterns and could increase surface water problems both on site and downstream.
In addition, Stonegate suffers from long standing sewage capacity issues, with repeated failures affecting properties across the village. Until the system is comprehensively upgraded, it cannot support additional dwellings.
Given the combination of unsafe access, lack of pedestrian infrastructure, drainage sensitivity, and inadequate sewage capacity, Site 9 is not suitable for allocation.
Site 10 — Land east of Bardown Road, Stonegate
Object
I object to the allocation of this site. Like Site 9, it is served by narrow, un footpathed rural lanes — Bardown Road and Lymden Lane — both of which carry fast moving traffic and offer no safe walking route to the primary school or village centre. There is no realistic prospect of providing a footway without fundamentally altering the rural character of the area or requiring land that is not available.
The site itself is small and constrained, with limited space for parking and turning. Vehicles would likely need to reverse onto Lymden Lane, creating an unacceptable highway safety hazard on an already narrow and busy rural road.
Stonegate’s sewage infrastructure remains inadequate, with known capacity problems affecting existing residents. Adding further dwellings would place additional pressure on a system that is already failing.
Taken together — the unsafe pedestrian environment, the highway safety risks, the site specific access constraints, and the ongoing sewage capacity failures — Site 10 is not a suitable or sustainable location for development.
In conclusion, my comments are offered in the spirit of supporting a fair, evidence based Local Plan that meets genuine local need while safeguarding the qualities that make our parish distinctive. I recognise the pressures on the authority to deliver new homes, and I do not oppose development where it is appropriate, sustainable, and properly supported by infrastructure. My concern is simply that each site is assessed on its merits, with full regard to landscape, ecology, access, drainage, and the lived realities of the communities affected. If these principles are applied consistently, the resulting Plan will serve both current residents and future generations well.
Yours faithfully,

Please see attached site assessment document by Ticehurst Parish Council regarding proposed allocated sites within the parish, including site plans.

Assessment of:
01 – Cherry Tree Nursery , The smokery and land to the north. Flimwell - Policy FW2
02 - Junction of London Road and A268 north - Policy FW2
03 - Land to the south of A268, Flimwell - Policy FW2
04 - Land to the north of Fruitfields, Flimwell - Policy FW1
05 - Cedar Farm, Hastings Road, Flimwell - Policy FW3
06 - Land to rear of Cherry Tree Public House - Policy TC1
07 – Land at Steelands Farm - Policy TC1
08 – Orchard Farm, Ticehurst - Policy TC2
09 – Land at Lymden Lane, Stonegate - Policy SG1
10 – Land east of Bardown Road, Stonegate - Policy SG2