Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 28860
Received: 25/02/2026
Respondent: Mr Neil Cameron
1. Unless changes are made to secure the provision of footways, Proposed Allocation SG2 is not consistent with the vision for Northern Rother, which contemplates development ‘where sustainable’.
2. Criteria should be added to proposed allocation SG2 to secure the necessary infrastructure.
3. If the change is not made, the site should not be allocated.
Vision for Northern Rother
1. The ‘Vision’ for Northern Rother includes the following:
There are opportunities for sensitive development in the sub-area during the timeframe of the Local Plan, where sustainable and related to an existing settlement, including those alongside the A21.
(my underlining)
2. Fig 26 includes an allocation of 25 dwellings at Stonegate.
3. Paragraph 6.93 states:
6.93. Sites of smaller scale are identified in the ridgetop village of Burwash and the villages of Staplecross, Stonegate and Burwash Common. Burwash, Staplecross and Stonegate have primary schools, while Stonegate village is some one mile north of Stonegate railway station on the Hastings to London line.
(my underlining)
4. The ‘Vision’ identifies opportunities for development ‘where sustainable’.
5. Paragraph 6.93 identifies characteristics which are relied upon to identity locations where development may be sustainable.
6. A development proposal which is not designed in such a way as to be easily accessible to identified existing facilities will not meet the qualification ‘where sustainable’.
7. In the case of Stonegate:
a. a particular community facility is identified, the primary school;
b. a particular public transport facility is identified, the railway station.
8. If residential and other development in Stonegate is to meet the qualification, “where sustainable” those living in new housing (or working or visiting employment sites) must be able to access the identified facilities by sustainable means, primarily by walking.
9. Stonegate has poor footway provision. At present, it is not possible safely to access:
a. The primary school by foot from the entrance to proposed site SG2, as there is no footway along Bardown Road.
b. The railway station from the village, as there is no footway from the village to the station and no safe walking route.
10. A plan which identifies facilities access to which it is said may make development sustainable without considering how such access will be obtained is not based upon up to date evidence (as referred to at paragraph 32 NPPF), is not justified (as referred to at paragraph 36(b) NPPF) and is not sound.
11. If development allocations at Stonegate are to meet the ‘where sustainable’ criterion, the allocations should be dependent upon a clear policy requirement that the following improvements be in place before any housing unit is occupied:
a. The provision of a footway from the entrance to site SG2 to the junction of Bardown Road/Lymden Lane/Station Road/Cottenden Road.
b. The provision of a safe pedestrian crossing facility at the junction of Bardown Road/Lymden Lane/Station Road/Cottenden Road.
c. The provision of a footway from the railway station to join the existing footway on Station Road (by the church).
Proposed Allocation SG2 – Land east of Bardown Road, Stonegate
12. The site is allocated for residential development comprising some 20 new dwellings.
13. The following is included under the heading ‘Policy Text”
2. Include a new vehicular and pedestrian access from Bardown Road;
3. Include any necessary on-site or off-site highway works necessary to make the development acceptable;
4. …
14. Criterion (3) is vague and imprecise. There is no footway on Bardown Road. In order to ensure that those living in the new development can access village facilities such as the primary school, the village hall and the church, it is essential that a footway is provided along Bardown Road into the centre of the village, and that appropriate pedestrian crossing facilities are provided at the junction of Bardown Road/Lymden Lane/Station Road/Cottenden Road.
15. In order to ensure that those living in the new dwellings can access the only public transport facility in Stonegate (the railway station) by sustainable means, it is essential that a footway is provided from the railway station joining the existing footway by the church in Station Road.
16. The policy criteria should make clear that the SG2 allocation is dependent upon the provision of the Bardown Road footway referred to above.
17. The policy criteria should make clear that Allocation SG1 and Allocation SG2 are dependent upon:
a. The provision of a footway from the entrance to site SG2 to the junction of Bardown Road/Lymden Lane/Station Road/Cottenden Road.
b. The provision of a safe pedestrian crossing facility at the junction of Bardown Road/Lymden Lane/Station Road/Cottenden Road.
c. The provision of a footway from the railway station to join the existing footway on Station Road (by the church).
18. If those criteria are not applied, and/or if the development is not financially viable if those requirements were to be applied, then the allocations should not be made, as the development would not meet the ‘where sustainable’ criterion.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 28886
Received: 27/02/2026
Respondent: Mrs Sarah Kidd
The number of units proposed on these two rural sites is wildly unworkable. They are badly placed for access for build work and residents, one being on a busy narrow road without pedestrian walkways/lighting, the other on a dangerously narrow country lane. Stonegate has no facilities; just a church and school; no pub, no shop, no public transport (except station over a mile further south), necessitating more cars on unsuitable roads. There will be of no benefit to the community, save a few school age children, but they will be a big drain on very scarce local services, especially healthcare. buyers may well invest in buy to let or weekend/holiday homes or some will be young professionals commuting to London, so not much community spirit. Waste drainage will also be a problem with the small village works already struggling. Further desecration of the countryside is unwarranted.
The number of units proposed on these two rural sites is wildly unworkable. They are badly placed for access for build work and residents, one being on a busy narrow road without pedestrian walkways/lighting, the other on a dangerously narrow country lane. Stonegate has no facilities; just a church and school; no pub, no shop, no public transport (except station over a mile further south), necessitating more cars on unsuitable roads. There will be of no benefit to the community, save a few school age children, but they will be a big drain on very scarce local services, especially healthcare. buyers may well invest in buy to let or weekend/holiday homes or some will be young professionals commuting to London, so not much community spirit. Waste drainage will also be a problem with the small village works already struggling. Further desecration of the countryside is unwarranted.
Support
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29004
Received: 02/03/2026
Respondent: Southern Water
SG1, SG2
Please see: Full representation on Draft Rother District Local Plan 2025-2042 Consultation
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.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29050
Received: 06/03/2026
Respondent: Mrs Karina French
Site 09 is at a very narrow part of the Lane, busy when diversions are in place (quite often) and sight lines along the Lane would be dreadful (we live on Lymden Lane at a wider part but still experience issues joining the road). If safe access WAS achieved, five terraced cottages would be far too many, would assume at least one car per cottage, probably two. Parking would need to be factored in (two spaces per cottage?). Site not big enough for five cottages and parking. A car is a necessity living in Stonegate - no shops, medical centre, etc.
Bardown Road again is quite narrow and getting out from Site 10 on to the Road would be dangerous - sight lines, speed of traffic.
Number of proposed houses too many - not the infrastructure to support and only a small stretch of pavement by the school.
Site 09 is at a very narrow part of the Lane, busy when diversions are in place (quite often) and sight lines along the Lane would be dreadful (we live on Lymden Lane at a wider part but still experience issues joining the road). If safe access WAS achieved, five terraced cottages would be far too many, would assume at least one car per cottage, probably two. Parking would need to be factored in (two spaces per cottage?). Site not big enough for five cottages and parking. A car is a necessity living in Stonegate - no shops, medical centre, etc.
Bardown Road again is quite narrow and getting out from Site 10 on to the Road would be dangerous - sight lines, speed of traffic.
Number of proposed houses too many - not the infrastructure to support and only a small stretch of pavement by the school.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29082
Received: 07/03/2026
Respondent: Mrs Jenny Bodenham
SG1
Site not suitable for proposed 5 houses with parking and access on to Lymden Lane. Generally at least 2 cars per household in rural area such as this. Lymden Lane is a small rural lane at its narrowest at the proposed building site. Access on to lane dangerous. Lymden Lane often used as diversion route - poor sight lines and no pavement to village. Cars travel at speed along Lymden Lane including this section despite speed limit. There are large potholes that are never repaired. Regular deliveries to and from Smith's reclamation yard - heavy vehicles/lorries which can cause more disrepair to road. Extra traffic generated with the 5 proposed houses poses danger to pedestrians and further degradation of road surface. No facilities - nearest GP in Wadhurst has over 10,000 patients registered!
SG1
Site not suitable for proposed 5 houses with parking and access on to Lymden Lane. Generally at least 2 cars per household in rural area such as this. Lymden Lane is a small rural lane at its narrowest at the proposed building site. Access on to lane dangerous. Lymden Lane often used as diversion route - poor sight lines and no pavement to village. Cars travel at speed along Lymden Lane including this section despite speed limit. There are large potholes that are never repaired. Regular deliveries to and from Smith's reclamation yard - heavy vehicles/lorries which can cause more disrepair to road. Extra traffic generated with the 5 proposed houses poses danger to pedestrians and further degradation of road surface. No facilities - nearest GP in Wadhurst has over 10,000 patients registered!
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29084
Received: 07/03/2026
Respondent: Mrs Jenny Bodenham
SG2
Proposed site in an AONB and in proximity to an ancient woodland (Green to the Core Policy).
Access to the site is proposed from Bardown Road which is already continually in a state of disrepair. Additional traffic would mean even further degradation of the road. At least 3 cars burst their tyres only 2 weeks ago on this road. Cars often speed on this road and there are no pavements, so no safe walking route to village.
No local transport so use of car would be essential to live in this location - not aligned with Green to Core Policy.
No local facilities such as shop or doctor within walking distance.
Water pressure a constant issue in Lymden Lane, so proposed development should not worsen this issue.
Flood risk? Significant drop down from the field to Lymden Lane.
Topography - roof tops would be visitble from Lymden Lane.
SG2
Proposed site in an AONB and in proximity to an ancient woodland (Green to the Core Policy).
Access to the site is proposed from Bardown Road which is already continually in a state of disrepair. Additional traffic would mean even further degradation of the road. At least 3 cars burst their tyres only 2 weeks ago on this road. Cars often speed on this road and there are no pavements, so no safe walking route to village.
No local transport so use of car would be essential to live in this location - not aligned with Green to Core Policy.
No local facilities such as shop or doctor within walking distance.
Water pressure a constant issue in Lymden Lane, so proposed development should not worsen this issue.
Flood risk? Significant drop down from the field to Lymden Lane.
Topography - roof tops would be visitble from Lymden Lane.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29225
Received: 11/03/2026
Respondent: Ms Katheine Luckhurst
SG1- The submitted outline plan is inaccurate, as it combines land owned by two separate individuals.
The site fronts the narrowest section of Lymden Lane, which is single track at this point. Any additional traffic generated by five new dwellings would significantly increase the risk to both vehicles and pedestrians, creating a clear highway safety concern. In addition, the site appears incapable of providing adequate parking for the proposed number of properties. It should be noted that planning permission for a single dwelling at this location was previously refused.
There are further serious concerns regarding water and drainage infrastructure. South East Water states that properties should have a minimum pressure of 1 bar; nearby Limden Close already records only 1.2 bar. Following repeated water main failures, the system is fragile. The Stonegate treatment works already struggles with sewage and runoff after rainfall, affecting the nearby stream and the River Rother.
SG1- The submitted outline plan is inaccurate, as it combines land owned by two separate individuals.
The site fronts the narrowest section of Lymden Lane, which is single track at this point. Any additional traffic generated by five new dwellings would significantly increase the risk to both vehicles and pedestrians, creating a clear highway safety concern. In addition, the site appears incapable of providing adequate parking for the proposed number of properties. It should be noted that planning permission for a single dwelling at this location was previously refused.
There are further serious concerns regarding water and drainage infrastructure. South East Water states that properties should have a minimum pressure of 1 bar; nearby Limden Close already records only 1.2 bar. Following repeated water main failures, the system is fragile. The Stonegate treatment works already struggles with sewage and runoff after rainfall, affecting the nearby stream and the River Rother.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29226
Received: 11/03/2026
Respondent: Ms Katheine Luckhurst
SG2- The field is outside of the village boundary. Previous planning applications have been refused.
There are serious concerns regarding local water infrastructure. According to South East Water, the recommended minimum water pressure for residential properties is 1 bar. The lowest recorded pressure in Stonegate is 1.1 bar, located in The Acorns, Bardown Road.
These already low pressure levels are partly the result of multiple water main bursts that occurred several years ago, after which the local infrastructure has struggled to maintain adequate pressure. Any additional demand from further development is likely to exacerbate this issue.
There are also concerns regarding wastewater capacity. The water treatment works in Stonegate already appears unable to adequately manage existing sewerage and surface water runoff. Following periods of rainfall, there is a noticeable smell of sewage, suggesting that runoff is entering the nearby stream and ultimately flowing into the River Rother.
SG2- The field is outside of the village boundary. Previous planning applications have been refused.
There are serious concerns regarding local water infrastructure. According to South East Water, the recommended minimum water pressure for residential properties is 1 bar. The lowest recorded pressure in Stonegate is 1.1 bar, located in The Acorns, Bardown Road.
These already low pressure levels are partly the result of multiple water main bursts that occurred several years ago, after which the local infrastructure has struggled to maintain adequate pressure. Any additional demand from further development is likely to exacerbate this issue.
There are also concerns regarding wastewater capacity. The water treatment works in Stonegate already appears unable to adequately manage existing sewerage and surface water runoff. Following periods of rainfall, there is a noticeable smell of sewage, suggesting that runoff is entering the nearby stream and ultimately flowing into the River Rother.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29275
Received: 12/03/2026
Respondent: Mary Varrall
SG1 would be acceptable if treated sensitively. SG2 too large and unsustainable in this village.
SG1 would be acceptable if treated sensitively. SG2 too large and unsustainable in this village.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29438
Received: 16/03/2026
Respondent: Nicholas Davies
Objections under the public consultation to the Proposed Site Allocation SG2 in Stonegate adjacent to the Bardown Road:
- Proposed Density & Site Sustainability
- Site Accessibility
- Groundwater
- Landscape Significance and Bio-diversity
- Services & Adjoining Uses
- Archaeology
My property in The Acorns and rear garden area immediately abuts the open southern field boundary of the proposed site allocation SG2. I and others abutting the site would be adversely and materially impacted by any such site allocation for development. I believe the proposed allocation fails to meet a number of Rother’s own planning policy and criteria for inclusion and has failed to give sufficient weight to a number of site constraints on development or to the sustainability aspects of the proposed site allocation. I have not met a single person in Stonegate yet at any of the public consultations that supports the inclusion of this site.
Background Topography and Surrounding Site Context
The Acorns was designed and built in a traditional Kent/Sussex vernacular on a former brownfield site (a former plant hire yard) in 1988. It incorporated TPO’d trees, mature Oaks and was shaped around the retention of an existing historic natural pond at its centre. The Pond is a survivor of 4 ponds that once existed on The Acorns shown on the historic OS map survey of 1874. The density and layout of The Acorns was dictated by these constraints when it was designed, forming a soft and seamless transition into the open countryside to the north on much higher ground with open and permeable boundaries to the proposed site allocation SG2. This transition is successful because of the significant change in level in the site topography between the rear gardens of the easternmost properties in the Acorns and the land SG2 above. The land rises steadily eastwards on this boundary, so the difference between the field boundary level above and my immediate outside garden level below is 3.5 metres. At some time in history this dramatic change in level would have been created by activity for clay winning, mining or quarrying which is the pattern in the Weald as it is not a natural feature and would explain the existence of the many ponds that once existed here. When viewed from the field SG2 my property is sunk down by a storey and and a half into the landscape and so has little visual impact when viewed from the north. Viewed from the house however, the field is level with my first floor windows. The sudden change in level here is maintained by terraced retaining walls and the steep tree’d embankment in the garden on my property. Any proposed development on the field adjacent could therefore look down into my private amenity space, dominate the skyline and reduce the vertical sky component (VSC) for daylighting that I have benefitted from for 28 years. Necessary higher fencing associated with securing the privacy of the open boundary from any future development would of course only exacerbate this. The preliminary landscape assessment and site description in the proposed allocation fails to acknowledge or pick up on any of the differing site topography on its southern boundary and perversely suggests development would be better suited here on the highest ground furthest from the proposed access on Bardown Road?
Proposed Density & Site Sustainability
The proposed density of 35 dwellings per hectare to generate 20 dwellings is not representative of the built density that prevails anywhere else in Stonegate. By Rother’s own criteria higher densities in villages are justified in village centres in close proximity to public transport, shops and local services. This is not applicable here. Stonegate is not a service village. Curiously this density is applied to only half the site without any robust analysis to determine where that half might be other than a suggestion that it should be contained in the southern and eastern parts? Justification for higher densities by Rother’s own criteria is within 1600 metres of stations or 800 metres of frequent bus services. We have no bus service in Stonegate and the station is 1.2 miles by road or 1930 metres to the closest possible site entry point on Bardown Road. Proposed development on the allocated site might therefore be over 2000 metres distant. It therefore fails this suitability test. Travel to the station is car dependant as the road access is rural and has no road markings, footway or lighting. Higher densities are most commonly found in the centres of historic settlements not on the edges.
I have read the Draft Site Density study parts 1 & 2 produced by Rother in 2024 & 2026 in support of higher densities for site allocations. Tellingly, none of the contemporary best practice development examples used to justify density assumptions are taken from a Kent or Sussex Rural Wealden context and appear largely urban in character. In addition, the Historic examples from villages in Sussex, whilst they might illustrate appropriate building typologies, fail to include any car parking analysis associated with them. I regard this omission as deeply flawed if used for comparison purposes with their contemporary examples. This is not a robust planning argument for higher densities on the edge of historic settlements. The proposed site is entirely car dependant and not sustainable.
Site Accessibility
The proposed site entrance on Bardown Road would be located outside the current village 30mph limit. Sight lines for this access might be as much as 2.4 metres (X) x 90 metres (Y) northwards depending on traffic surveys requiring large sections of the hedgerow abutting the highway to be removed. Whilst extending the 30mph limit northwards to include the proposed site might reduce the Y forward visibility distance to 43 metres in each direction, this would still result in a significant loss of hedgerow on the western boundary. The importance of retaining and reinforcing landscaping on this sensitive edge has however already been highlighted by Rother.
It would not even be possible to connect the proposed site to the local primary school by footway as there is no pavement to the Bardown Road nor the means of providing it at the junction pinch point at the centre of the village. There is insufficient Highways land width available at this location to provide this footpath connectivity without a traffic light controlled single carriageway.
Groundwater
One of the principal objections I have to this proposed site allocation is the profound impact it would have on the natural water supply to the pond in the Acorns which is its central feature and jointly owned by me with my neighbours. The pond, as previously noted, is historic. It derives its water supply from underground springs from the catchment area of the proposed site allocation, a protected Sandstone outcrop (a ‘Special to Sussex’ habitat) and partly within a source protection zone. Ground water from the proposed site allocation percolates through fissures in the clay and subsurface sandstone beds and runs down to the pond through the subsoil of our rear garden in land drains. This was evident when the pond was de-silted some years ago. The pond, even in severe periods of drought has never dried up, because it has this constant underground supply from the land above. When I first moved to the house the rear garden was not terraced and springs would often form on the bank in prolonged wet weather. These are now directed into the pond via land drainage that was installed when the garden was landscaped and terraced twenty years ago.
I believe that any proposed development would change and interrupt the water supply that derives from this site by altering the water table. The necessary groundworks for foundations, access roads and drainage associated with development would undoubtedly alter the subsurface hydrology of the field site and jeopardise the outflows from it. The water falling previously on open land would be captured on new buildings and hard surfaces to be diverted away into surface water drainage systems. SUDs would not mitigate this as they are designed to capture and slow down rapid run-off into surface water systems. The pond as well as being a beautiful visual asset is a significant wildlife asset.
Landscape Significance and Bio-diversity
The proposed site is greenfield so I oppose its inclusion on principle. Prominent in the Wealden landscape it is located on the highest ground adjacent to the village built envelope. In the previous landscape assessment it was described by Rother as “visually exposed (with long views to the west only partially obscured by hedge) and of rural character”. The proposed access would result in the loss of hedgerow and the suggestion is that any development should be on the south and eastern sections of the site which are on the highest ground so by definition appearing above the hedgerow in long views from the west? Its development would be harmful to the surrounding landscape, hydrology and would result in the loss of habitat with negative impacts on the existing biodiversity. Once lost this will never be regained.
The pond in The Acorns supports a prolific array of bird life, amphibians, aquatic life and insect life. In my time I have seen grass snakes, kingfishers and other rare species using it. In the summer we have many types of dragonflies which appear in the garden to feed from the pond. I have planted, maintained and improved it with my neighbours over more than twenty years. Its connectivity to the wider landscape through the permeable open boundaries to the north are the key for its survival and its importance for the bio-diversity we enjoy.
The dark sky environment with the mature trees on the proposed allocation site supports bat colonies who in turn feed at dusk from the prolific insect life on the pond. Owls and other small raptors predate rodents and small mammals on the field and roost in the trees at night with woodpeckers and many other species of birds benefitting from the existing mature trees and hedgerows. It is this landscape interconnectivity which is part of an holistic relationship with the proposed allocation site which provides these wildlife corridors through the permeable boundaries and is at risk of loss here. No amount of proposed nett gain on paper could ever compensate for the physical loss.
Whilst the High Weald AONB Management Plan has very well intentioned policies for dark sky mitigation, the reality is that a development located here and silhouetted at night on very much higher ground will be negative and harmful. Multiple lit windows after dark from a higher density development and light spill from outdoor security lighting cannot be avoided and in reality would not be enforced against by Rother once development is built.
Services & Adjoining Uses
The proposed site has three overhead high voltage cables owned by UKPN which cross the site from the northwest to the south east and roughly dissect the proposed site midway. The cables then only divert underground immediately on my easternmost rear boundary with the pole stays on my land. These would need to be placed underground across the site for any development to take place in their vicinity.
Despite living close to one of the largest reservoirs in the south east, ironically we still suffer from very low water pressure. I also understand the provision of surface water treatment for sewerage at the Stonegate site is at capacity already. The current infrastructure would not support additional dwellings without network reinforcement.
The small quarry site adjoining the north west boundary of the proposed site is used by a company for processing, crushing and loading aggregates. The noise from this process is sometimes obtrusive, sheltered as I am by the topography and at some distance in the landscape. It would however create an unsatisfactory adjacent planning use for any proposed residential development at higher level on the proposed site.
Archaeology
I note that Rother confirm, were this site ever to come forward it is recommended that an Archaeology report is prepared in relation to its proximity to the identified Bardown Roman ironworks site 300 metres to the North. (Mistakenly referred to as an Arachnological report in Rother’s assessment - a typographic error I believe). As I have periodically turned up examples of iron bloomery deposits from my own garden embankment, I would support any such initiative.
Conclusions
When Site SG2 was excluded from development in the 2016 - 2028 Ticehurst Neighbourhood Plan it was for very good reasons, Nothing has changed since apart from increased pressure from central government to bring forward more sites. Officers drafting the emerging Draft Local Plan may feel under significant pressure to put forward the maximum number of sites knowing some on examination will fall away as unsuitable. I believe that a measured assessment of the suitability of this site taking into consideration all policy criteria would prove that to be the case here. I have set out above what I believe are very sound planning and policy reasons why this site should be excluded from the proposed site allocations and would urge Officers to relook at the criteria and justification behind this site. I hope they will reach the same conclusion as I and many others have after careful consideration of all the evidence.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29547
Received: 16/03/2026
Respondent: Rob Lansdowne
I object to site SG2 in Stonegate. My home sits directly opposite the site the development would significantly harm the rural character of the village and the surrounding HWNL. The site is elevated, visually exposed and would require the removal of hedgerows, permanently altering the countryside. The suggested housing density is inappropriate for a small rural settlement like Stonegate, which lacks services and relies heavily on private cars. There is no regular bus service, the station is over a mile away along unsafe rural roads, and there are no pavements for pedestrians. Access onto Bardown Road raises serious highway safety concerns. Local infrastructure—including water pressure and wastewater capacity—is already constrained. The site also forms part of an important ecological network, with wildlife habitats and dark skies that would be harmed by development. The site is crossed by high voltage power lines and lies within an area of archaeological sensitivity.
I am writing to formally object to the proposed site allocation SG2 adjacent to Bardown Road in Stonegate within the Emerging Rother Local Plan 2025–2042.
My property is located opposite the proposed site and therefore any development would have a direct and material impact on our home, local environment and the character of the village.
In my opinion, the proposed allocation fails to adequately consider several important planning principles including sustainability, landscape impact, infrastructure capacity, biodiversity, and highway safety. For the reasons outlined below, I strongly believe that the site should not be included as a housing allocation in the emerging Local Plan.
1. Character of the Village and Landscape Impact
Stonegate is a small rural village within the High Weald landscape, characterised by low-density housing, mature trees, hedgerows and open countryside.
The proposed site is greenfield land located on elevated ground at the edge of the settlement, making it highly visible within the surrounding landscape. Development on this site would significantly alter the rural setting of the village and create an urbanising effect in an otherwise open and sensitive landscape.
Previous assessments have recognised the land as being visually exposed and of rural character, with views extending across the wider countryside. Development in this location would therefore be highly intrusive and detrimental to the landscape character that defines the area.
The loss of hedgerows and natural boundaries required for access and visibility splays would further erode the rural character of this location.
Once this landscape is lost, it cannot realistically be restored.
2. Unsuitable Housing Density for a Rural Settlement
The proposed density of 35 dwellings per hectare to achieve approximately 20 houses is not reflective of the existing built form of Stonegate.
Housing within the village is generally low density and dispersed, which is typical of settlements within the High Weald.
Higher density housing is typically considered appropriate only in locations that are close to services, public transport and village centres. The proposed site does not meet these criteria.
Stonegate is not a service village and residents rely heavily on private vehicles for daily activities.
The proposed development would therefore represent overdevelopment of a rural edge-of-village site, inconsistent with the existing settlement pattern.
3. Lack of Sustainable Transport Options
One of the key tests for site suitability is accessibility to public transport and services.
The proposed site fails to meet these sustainability criteria:
• Stonegate has no regular bus service.
• The railway station is approximately 1.2 miles away by road, and significantly further from the likely site entrance.
• The route to the station is along narrow rural roads with no pavements, road markings or street lighting.
This means residents would be entirely dependent on private cars, which contradicts the principles of sustainable development promoted within planning policy.
4. Highway Safety Concerns
The proposed access onto Bardown Road raises serious concerns.
The site access would be located outside the current 30mph speed limit, where vehicles regularly travel at higher speeds.
Achieving adequate visibility splays for a junction would likely require significant removal of existing hedgerows, which are important landscape and ecological features.
Furthermore, there is no safe pedestrian route connecting the site to the centre of the village or the primary school, as there are no pavements along Bardown Road and insufficient highway width to provide one without major road alterations.
This raises concerns regarding pedestrian safety, particularly for children travelling to school.
5. Infrastructure Capacity
Stonegate already experiences limitations in local infrastructure.
There are known concerns regarding:
• Water pressure in the area
• Wastewater treatment capacity
• General infrastructure provision for a rural settlement
It is unclear how existing infrastructure would accommodate additional housing without significant upgrades, which have not been clearly identified.
Allocating housing without first ensuring adequate infrastructure capacity would place additional strain on existing services.
6. Biodiversity and Ecology
The proposed site currently forms part of an important local ecological network, consisting of:
• Open fields
• Mature hedgerows
• Trees
• Dark sky habitat
These features support a wide range of wildlife including birds, bats, insects and small mammals.
Development would inevitably lead to the loss or fragmentation of these habitats, even if mitigation measures were proposed.
Whilst biodiversity net gain policies exist, they cannot fully replace the established ecological relationships and wildlife corridors currently present within the landscape.
Additionally, the introduction of residential lighting would have a negative impact on the dark sky environment, which is an important feature of the High Weald landscape.
7. Overhead Power Infrastructure
The site is also crossed by high voltage overhead electricity cables, which would likely require relocation or undergrounding to enable development.
This represents an additional constraint and would involve further disturbance to the landscape.
8. Archaeological Sensitivity
The area surrounding the site is known to contain historic archaeological features, including the nearby Bardown Roman ironworks site.
Any development would therefore require archaeological investigation, which further highlights the sensitivity of this location.
Conclusion
For the reasons outlined above, the proposed allocation SG2 at Bardown Road is not a suitable location for residential development.
The site:
• Is visually prominent within the landscape
• Is poorly connected to services and public transport
• Raises highway safety concerns
• Risks harm to biodiversity and dark skies
• Would place additional pressure on local infrastructure
Stonegate is a small rural settlement and development of this scale and density would fundamentally change the character of the village.
I therefore strongly urge Rother District Council to remove Site SG2 from the proposed site allocations within the Emerging Local Plan.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29549
Received: 16/03/2026
Respondent: Ruth Jordan
Number of people: 2
I object to site SG2. It would significantly affect my property bordering the south of the site. The land is around 3.5 metres higher than my home, meaning the development would have an intrusive visual impact. The proposed housing density of 35 dwellings per hectare is not in keeping with Stonegate and contradicts Rother’s own criteria, which require higher densities only where there is good access to public transport and services. Stonegate has no bus service, and the station is nearly 2km away along an unlit rural road with no pavements. The proposed access on Bardown Road is outside the 30mph limit and would require extensive hedgerow removal, with no safe pedestrian route to the school. Development would also threaten groundwater feeding a historic wildlife pond in The Acorns and harm biodiversity, dark skies and landscape character. Infrastructure limits, including sewer capacity, further justify excluding SG2 from the Local Plan.
We live in The Acorns and our property borders the southern field boundary of the proposed site allocation SG2. It would be detrimental to us if the development goes ahead and we and our neighbours believe that the proposed site fails to meet a number of Rother’s own planning policy and criteria for inclusion and has failed to give sufficient weight to a number of site constraints on development or to the sustainability aspects.
We question why the suggested development is at the southern boundary of the proposed development which is furthest from the proposed access on Bardown Road. The southern boundary is approximately 3.5 metres higher than our property which would mean that should the development go ahead, it would have a huge visual impact from our property.
Proposed Density: The proposed density of 35 dwellings per hectare to generate 20 dwellings is not representative of the build density that exists anywhere else in Stonegate. By Rother’s own criteria higher densities in villages are justified in village centres in close proximity to public transport, shops and local services. This density is applied to only half the site without any strong analysis to determine where that half might be other than a suggestion it should be contained in the southern and eastern parts. Justification for higher densities by Rother’s own criteria is within 1600 metres of stations or 800 metres of frequent bus services.
Site Accessibility: There is no bus service in Stonegate. The station is 1.2 miles by road or 1930 metres to the closest possible site entry point on Bardown Road. Proposed development on the site might therefore be over 2000 metres distant which therefore fails this suitability test. To safely travel to the station, a car must be used. Travel by foot is extremely hazardous as there are no footways or lighting along a winding country lane with the national speed limit.
The proposed site entrance on Bardown Road is outside the current 30mph village speed limit. Sight lines for this access may be as much as 2.4 metres (X) x 90 metres (Y) northwards requiring large sections of the hedgerow abutting the highway to be removed. Whilst extending the 30mph limit northwards to include the proposed site might reduce the Y forward visibility distance to 43 metres in each direction, there would still be a significant loss of hedgerow on the western boundary. The importance of retaining and reinforcing landscaping on this sensitive edge has already been highlighted by Rother.
The proposed site provides no footway to the local primary school as there is no pavement to Bardown Road and there is not enough land width available at the proposed site to provide a footpath without a traffic light controlled single carriageway.
Groundwater: Within the Acorns there is a historic pond. The proposed site would have a huge impact on the natural water supply to the pond. The pond’s water supply comes from underground springs from the proposed allocation site. The proposed development we believe will alter the water table, changing and interrupting the water supply. The pond is a significant wildlife asset.
Landscape Significance: The proposed site is greenfield. It is located on the highest ground adjacent to the village built envelope. This development will be harmful to the surrounding landscape and hydrology and would result in the loss of habitat with negative impacts on the existing bio-diversity.
The pond in The Acorns supports a prolific array of birdlife, amphibians, aquatic and insect life. Dragonflies feed from the pond.
The dark sky environment with the mature trees on the proposed allocation site supports bat colonies which feed on the insect life on the pond. We hear owls every night who roost in the trees along with woodpeckers and many other species of birds.
The proposed development on the higher ground will be harmful to the dark sky environment in turn damaging our wildlife.
Services: The provision of surface water treatment for sewerage at the Stonegate site is we believe at capacity and would not therefore support additional houses without network reinforcement.
Archaeology: We understand that an Archaeology report will need to be prepared in relation to the site’s proximity to the Bardown Roman ironworks 300 metres to the North.
We believe there ae significant planning and policy reasons why this site should be excluded from the proposed site allocations.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29562
Received: 18/03/2026
Respondent: Mr Stephen Burley
SG1. Oppose. Overdevelopment of small site. Narrow lane. No pavement to school and centre of village.
SG2. Oppose. Out of scale for size of the village.
Topography. Scale of development and associated lighting would have a damaging effect on the National Landscape.
Would overshadow some of the properties in the Acorns.
Infrastructure. Lack of pavement to the centre of the village and the school would be hazardous for children. Vehicular
access already constrained by severe congestion at school times. Installation of a pavement not practical.
Sewerage treatment works already overloaded.
As a resident of Stonegate and a member of Ticehurst Parish Council I would like to object to policies SG1 and SG2.
SG1. This represents an overdevelopment of a small site located on a very narrow part of Lymden Lane which is heavily used in school times. There is no pavement to the centre of the village. A smaller development might be suitable.
SG2. The proposed development is not suitable for the following reasons -
1. 20 houses is out of scale for the size of the village which has few amenities. Previous developments such as Lymden Close and
The Acorns are significantly smaller representing incremental development which is much more suitable for a village of the size of
Stonegate.
2. The topography of the land which rises from Bardown Road means that the development with it’s associated lighting would be
visible from across the valley to the West and thus have a detrimental effect on this important part of the National Landscape.
The topography would also mean that any development would overshadow some of the properties in The Acorns which lie well
below the level of the field.
3. Infrastructure. 20 houses would almost certainly mean that there would be more children attending Stonegate Primary School.
There is no pavement between the field and the centre of the village. Moreover there is limited scope to install one without
using land currently occupied by private gardens. Vehicular access to the school is already constrained by acute congestion at
school times.
Sewerage is almost certainly another constraint as the local treatment works clearly has capacity problems as demonstrated by
a recently installed temporary overflow tank.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29616
Received: 18/03/2026
Respondent: High Weald AONB Unit
Please see attached documents including HWNL response letter and Appendix 1.
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.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29650
Received: 18/03/2026
Respondent: East Sussex County Council
Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation
Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29716
Received: 19/03/2026
Respondent: Anne Scoones
SG1 - Lymden Lane is very narrow in parts, traffic travels too fast, the road surface is in poor condition.
The site plan indicates the planning area includes the next door property- entrance and gateway to the fields behind.
In the short term if planning were to proceed I can not see how there would be space for construction vehicles
SG2 - 20 houses would have too great an environmental impact.
Stonegate has no amenities/village shop etc. The roads leading in and out of the village are narrow and/or subsiding.
The water pressure drops at peak times. The sewage treatment works can not cope with the current population and spills effluent down the stream. I will not let my dogs enter it.
There is no pavement associated with either development. There are bats, owls and other protected species in the village.
SG1 - Lymden Lane is very narrow in parts, traffic travels too fast, the road surface is in poor condition.
The site plan indicates the planning area includes the next door property- entrance and gateway to the fields behind.
In the short term if planning were to proceed I can not see how there would be space for construction vehicles
SG2 - 20 houses would have too great an environmental impact.
Stonegate has no amenities/village shop etc. The roads leading in and out of the village are narrow and/or subsiding.
The water pressure drops at peak times. The sewage treatment works can not cope with the current population and spills effluent down the stream. I will not let my dogs enter it.
There is no pavement associated with either development. There are bats, owls and other protected species in the village.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29798
Received: 19/03/2026
Respondent: CPRE Sussex
Agent: CPRE Sussex
SG1 and SG2 are unsuitable due to remoteness, lack of services, parking issues and difficult access. These sites cannot support sustainable development.
See attached.
Support
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29821
Received: 20/03/2026
Respondent: Mr Dave Smith
SG1
This representation is made by Mr David Smith
Myself and my brother own the land which is proposed as a Site Allocation under reference SG1. We confirm it is available for development. Further, it is suitable and deliverable, and should be carried forward in the new Local Plan.
We reinforce that this land is situated in a sustainable location being within walking distance of key village amenities such as the school and mainline railway station. It is therefore not completely dependent on car use.
The land is suitable for small dwellings which are needed in the locality. Appropriate levels of parking and turning can be provided within the site. We note the proposed requirement to retain and enhance as much of the frontage hedging as possible.
We would intend to submit a planning application at the appropriate time and deliver housing without delay, i.e. within a 5 year period.
SG1
This representation is made by Mr David Smith
Myself and my brother own the land which is proposed as a Site Allocation under reference SG1. We confirm it is available for development. Further, it is suitable and deliverable, and should be carried forward in the new Local Plan.
We reinforce that this land is situated in a sustainable location being within walking distance of key village amenities such as the school and mainline railway station. It is therefore not completely dependent on car use.
The land is suitable for small dwellings which are needed in the locality. Appropriate levels of parking and turning can be provided within the site. We note the proposed requirement to retain and enhance as much of the frontage hedging as possible.
We would intend to submit a planning application at the appropriate time and deliver housing without delay, i.e. within a 5 year period.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29831
Received: 20/03/2026
Respondent: Mrs Jean Sanford
Site SG1.
Lymden Lane is very narrow, with room for one car and cars often have to back up to allow other cars to pass. There is no footpath and cars drive very fast which makes this lane very dangerous . There is no public transport so all the new houses would need cars.
Site SG1.
Lymden Lane is very narrow, with room for one car and cars often have to back up to allow other cars to pass. There is no footpath and cars drive very fast which makes this lane very dangerous . There is no public transport so all the new houses would need cars.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29843
Received: 20/03/2026
Respondent: Mrs Diana Simmons
• This proposed development SG2, an elevated green field site lying within National Landscapes, will be visually prominent & have an adverse impact on the landscape in Stonegate which lies in National Landscapes. It will overbear into properties beneath it & overshadow them.
• It will have a damaging effect on the local groundwater supply, affect the SPZ located in field SG2, impact the Sandstone outcrop important for Sussex habitat also in field SG2, interfere with the water supply to the pond in The Acorns from field SG2, affect the ecology & destroy the current biodiversity of field SG2 and the pond in The Acorns where protected & indicator species; e.g. bats, dragon flies and slow worms are present.
• Any development in Stonegate lacks sustainability e.g no public transport/amenities.
• Any development of field SG2 will impact the night sky negatively, even with light pollution strategies in place.
• This proposed development SG2, an elevated green field site lying within National Landscapes, will be visually prominent & have an adverse impact on the landscape in Stonegate which lies in National Landscapes. It will overbear into properties beneath it & overshadow them.
• It will have a damaging effect on the local groundwater supply, affect the SPZ located in field SG2, impact the Sandstone outcrop important for Sussex habitat also in field SG2, interfere with the water supply to the pond in The Acorns from field SG2, affect the ecology & destroy the current biodiversity of field SG2 and the pond in The Acorns where protected & indicator species; e.g. bats, dragon flies and slow worms are present.
• Any development in Stonegate lacks sustainability e.g no public transport/amenities.
• Any development of field SG2 will impact the night sky negatively, even with light pollution strategies in place.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29880
Received: 21/03/2026
Respondent: Mrs Diana Simmons
SG1, a greenfield site in Stonegate is situated in National Landscapes on a rural lane which is already overused as a cut through from B2099 to Stonegate. Access from site onto highway would be dangerous. A pavement is not present; dangerous for children attending school - I do not believe that there is physical space for a pavement in Lymden Lane. Development is not sustainable - only amenities in Stonegate are school, Church, playing fields. No shop. All residents are dependent on cars as no bus service and railway station over 1 mile away without pavement or lighting on roads at National Speed Limit. Centre of village congested due to dependence on cars. Current wastewater situation in Stonegate is overtaxed and clean water supply is at low pressure. Does Stonegate school have space and/or teachers? Local doctors surgery occupies cramped premises and is unable to cope with current population.
SG1, a greenfield site in Stonegate is situated in National Landscapes on a rural lane which is already overused as a cut through from B2099 to Stonegate. Access from site onto highway would be dangerous. A pavement is not present; dangerous for children attending school - I do not believe that there is physical space for a pavement in Lymden Lane. Development is not sustainable - only amenities in Stonegate are school, Church, playing fields. No shop. All residents are dependent on cars as no bus service and railway station over 1 mile away without pavement or lighting on roads at National Speed Limit. Centre of village congested due to dependence on cars. Current wastewater situation in Stonegate is overtaxed and clean water supply is at low pressure. Does Stonegate school have space and/or teachers? Local doctors surgery occupies cramped premises and is unable to cope with current population.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 29929
Received: 21/03/2026
Respondent: Mrs Lynn Owen
SG1. The site does not form a small section of a larger field on eastern side as you have stated…. They have two separate owners.
The thick red line outlining the site SG1 inaccurately includes the access to a small holding, and should not form part of the site.
The whole lane is narrow, extremely busy, and very badly maintained, and is single track at the site.
Sewage works in village can’t cope with current use.
Water pressure is already low with current use.
No footpaths.
No local facilities/amenities.
Drs surgery in Wadhurst already at capacity.
SG1. The site does not form a small section of a larger field on eastern side as you have stated…. They have two separate owners.
The thick red line outlining the site SG1 inaccurately includes the access to a small holding, and should not form part of the site.
The whole lane is narrow, extremely busy, and very badly maintained, and is single track at the site.
Sewage works in village can’t cope with current use.
Water pressure is already low with current use.
No footpaths.
No local facilities/amenities.
Drs surgery in Wadhurst already at capacity.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30091
Received: 22/03/2026
Respondent: Mrs Elspeth Hill
There are many reasons I feel that Stonegate is unsuitable for the proposed developments despite having a school. There is a lack of basic infrastructure - no public transport or shop. There is no gas supply and the new sewerage system is already under pressure. Any new residents will have to have their own transport, possibly two vehicles per household, and parking space, particularly during school hours, is already desperately inadequate. There are few pavements in the village and walking to school is already dangerous for small children. It seems that the owners of both the proposed sites have not been properly consulted and the Lymden Lane proposal seems to offer an access that is not available. The roads approaching the village are narrow with high hedges and there are many near-accidents at the four-way crossroads in the centre of the village.
There are many reasons I feel that Stonegate is unsuitable for the proposed developments despite having a school. There is a lack of basic infrastructure - no public transport or shop. There is no gas supply and the new sewerage system is already under pressure. Any new residents will have to have their own transport, possibly two vehicles per household, and parking space, particularly during school hours, is already desperately inadequate. There are few pavements in the village and walking to school is already dangerous for small children. It seems that the owners of both the proposed sites have not been properly consulted and the Lymden Lane proposal seems to offer an access that is not available. The roads approaching the village are narrow with high hedges and there are many near-accidents at the four-way crossroads in the centre of the village.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30661
Received: 23/03/2026
Respondent: Martin and Nichanan Hall
Number of people: 2
Objections to the Proposed Site SG2 in Stonegate. Reasons include:
- Visual intrusion and damage to the landscape, including removal of hedgerow;
- Negative impact of the development on complex water tables and geology across the site SG2 and changes in the run-off of stormwater from the development.
- Other sustainability issues such as lack of or poor access to public realm, public transport, facilities and services
Objections to the Proposed Site SG2 in Stonegate, in the Draft Local Plan 2025-2042, under Regulation 18 Consultation: Development Strategy and Site Allocations.
We, [names redacted] owners of [address redacted], Stonegate since 1994, whose property lies immediately adjacent to the southern boundary of field SG2, object to the proposed development for the following reasons. Please note that we have summarized our objections since many of them have already been raised in detail by others.
Historically the site has been considered for housing development by Rother District Council in 2011. The site was rejected at that time. Nothing has changed in terms of the criteria against which development was considered, but we acknowledge that the government is encouraging local authorities to identify more sites for housing development. We argue that to approve the site for development now it would be necessary to erode the standards and criteria that have already been applied to consideration of the site. This erosion of standards would be irreversible and damaging to the established ecosystems both on the site and within the neighboring Acorns.
Visual intrusion and damage to the landscape – the site topography rises significantly from the east of Bardown Road making a housing development highly intrusive when entering Stonegate from Wadhurst. This impact would be compounded by the necessary removal of the long-established hedgerow on SG2 along Bardown Road (for sight lines necessary for vehicle access to the site SG2).
Negative impact of the development on complex water tables and geology across the site SG2 and changes in the run-off of stormwater from the development.
Sustainability challenges posed by the proposed development.
• Potable water supplies at The Acorns are already subject to low pressure and wider network failures. Adding the housing development will exacerbate this situation.
• Overload of wastewater from the existing Stonegate community has necessitated construction of a holding tank at the wastewater treatment plant, indicating likely overload of the existing wastewater system and potential lack of capacity for an additional development.
• The above potable and wastewater issues combine with stormwater run off and water table issues to make the entire water cycle a complex problem at the proposed development.
• There is no footpath along Bardown Road, making the route to the school unsafe for children, and adults, from the new development.
• Stonegate has no shopping amenities with residents having to drive to Wadhurst or beyond for daily and weekly provisions. The development would add to the road traffic generated by this issue.
• The main railway station is over a mile away from the development, along a steep, unlit road with no footpaths. Again, the use of a car to get to the station is essential, with the development traffic adding to this.
• Other amenity issues such as overload of doctors’ surgeries in Wadhurst, school capacity, lack of any bus service to Stonegate etc. have been raised by others, which all raise questions against the sustainability of adding a new development to an already amenity challenged community.
The above points are raised to complement the issues that we see with the proposed development. Other local residents have expressed similar and other concerns in greater detail.
We understand the pressure to identify potential housing development sites, but we also trust that the standards and criteria seen fit to reject site SG2 in 2011 should be applied now, and not watered down to allow approval of a site carrying multiple sustainability, visual, safety and engineering challenges.
Thank you for your time in reading and considering the above.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30777
Received: 20/03/2026
Respondent: Chris and Diana Simmons
Number of people: 2
Objections to the Proposed Site SG2:
1. This proposed development on field SG2, a green field site lying within National Landscapes, will have an adverse impact on the landscape in Stonegate.
2. It will have a damaging effect on the local groundwater supply, undermine the ecology of field SG2 and the pond in The Acorns and destroy the current biodiversity in field SG2 and the pond in The Acorns.
3. Any development in Stonegate as a whole lacks sustainability.
4. Any development of field SG2 will impact the night sky negatively, even with light pollution strategies in place.
Objections to the Proposed Site SG2 in Stonegate, in the Draft Local Plan 2025 - 2042, under Regulation 18 Consultation: Development Strategy and Site Allocations.
We, Chris and Diana Simmons owners and residents on The Acorns, Stonegate, whose property lies immediately adjacent to the southern boundary of field SG2, object to its development for the following reasons;
1. This proposed development on field SG2, a green field site lying within National Landscapes, will have an adverse impact on the landscape in Stonegate.
2. It will have a damaging effect on the local groundwater supply, undermine the ecology of field SG2 and the pond in The Acorns and destroy the current biodiversity in field SG2 and the pond in The Acorns.
3. Any development in Stonegate as a whole lacks sustainability.
4. Any development of field SG2 will impact the night sky negatively, even with light pollution strategies in place.
To explain further;
This proposed development on field SG2, a green field site lying within National Landscapes, will have an adverse impact on the landscape in Stonegate.
Whilst it is not immediately apparent on first observation of the field SG2, the topography of the land rises progressively to the east of Bardown Road and the field SG2 dominates its immediate surroundings. Any development of this field will be visually prominent on entering Stonegate from Wadhurst as the existing hedging will inevitably need to be removed in order to provide vehicular access and clear sight lines on to Bardown Road, resulting in a development not in keeping with National Landscapes.
The Acorns is comprised of 6 properties nestled in a dip in the ground below field SG2 and adjacent to its southern boundary. For us personally, field SG2, occupies a raised and prominent position above our back garden. This back boundary adjacent to field SG2 is in fact the most favourable position in our whole garden, where the light is most propitious and where we have located our kitchen garden with raised beds and a greenhouse, thereby utilising the rise in land at the rear of our property advantageously. Any development in the field SG2 will inevitably overbear into our back garden and affect the amount and quality of daylight incident upon our kitchen garden. This intrusion into our privacy will then necessitate the placement of privacy screening along our back boundary abutting field SG2, which will further restrict the daylight incident upon these beds and will undermine the viability of the kitchen garden and the usefulness of our greenhouse. However, even with privacy screening along our rear boundary, any development in the field SG2 will inevitably be extremely visible from our properties and any properties on field SG2 will have vistas straight into our back gardens and back rooms.
It will have a damaging effect on the local groundwater supply, undermine the ecology of field SG2 and the pond in The Acorns and destroy the current biodiversity in field SG2 and the pond in The Acorns.
It is our understanding that when this site (currently SG2) was considered in 2011 (then described as ST1), it was rejected by Rother District Council as being unsuitable. We attach the file “Strategic Housing Land Availability Assessment” (SHLAA) (see page 121) and refer you to map number 45 for Ticehurst, Flimwell and Stonegate TQ6929, which was used in a previous local plan in 2011 by Rother, identifying the field SG2 as ST1 at that time. There were several reasons for the rejection of this site, one of which was the Ground Water Protection Zone (GWPZ, now defined as Source Protection Zone, SPZ3) in the north west corner of the field which is still considered to be especially important due to the inflow of surface water from the field SG2 into the water table and thence ultimately into our water supply in Sussex. A sandstone outcrop which is special to Sussex habitat is also located in field SG2. Our belief is that by developing the field SG2 with new roads/drives and drainage into the main waste water, the run off into the SPZ will be detrimentally affected and will impact the water table. Moreover, any change in how the rainwater falling on the field SG2 is received and dealt with, will almost certainly affect the water supply to our pond in The Acorns, see more below. If we continue to experience drought and increasing climate change in the future as seems most likely, the way rainwater which falls on to field SG2 is treated, will become more and more significant not just for Stonegate, but for other local communities reliant on Ground Water for their water supply.
Furthermore we object on the basis that any development in field SG2 will negatively affect the water supply to our pond in The Acorns (which we co-own with the neighbours). This pond acts as a focal point of natural interest in The Acorns, but it is not the aesthetics of the pond which is at stake. What is of far greater importance is the ecology of the pond and how it provides habitat and food for a wide range of wildlife to include only a few examples; Damsel flies, Dragon flies numerous other insects, bats, amphibians and invertebrates. We believe that the run off from field SG2 supplies this pond either directly over the land surface or via water flow, percolating through the soil into the water table and that any interference or interruption to this supply will detrimentally affect its water level, possibly even causing it to dry up. We believe that a disturbance of the equilibrium in the pond’s water levels and quality would destroy the ecology and natural habitat in and around the pond, leading to an irreversible destruction in biodiversity there.
It is also important to point out that the field SG2 and its surroundings provides habitat for a diverse range of wildlife. Kestrels, Owls, Buzzards, Red Kite and Gold Crest have been observed over and in field SG2. Within our garden, butterflies such as Skipper, Comma, Painted Lady have been seen, not to mention slow worms which are always found close to our boundary with the field SG2. It is important to note that the presence of slow worms can be an indicator of a balanced ecosystem.
Of the species mentioned above at least four are Indicator Species; Dragon flies, Damsel flies, bats and slow worms, and of these, two are known to have Protected Status; bats and slow worms. Life cycles of the Dragon fly and Damsel fly include 1-2 years as aquatic nymphs living in the silt or within the submerged plants and algae in the pond, eventually emerging as adults. These adults can live for 1 – 8 weeks either becoming food for species such as bats or ultimately laying eggs in the pond to complete their life cycle. At dusk, bats habitually leave their roosts to circle around the pond and our houses to feed on the variety of insects including Dragon flies and Damsel flies. All of this points to a vast array of biodiversity in the pond which is interdependent on field SG2. We believe that any development of the field SG2 will result in the irrevocable destruction of the environment, the biodiversity and well established ecosystems which connect the pond in The Acorns to the field SG2 and vice versa.
On the basis of the foregoing we believe that if any development on field SG2 were to be seriously considered, an extensive ecological and biodiversity survey of field SG2 including the pond at The Acorns, must be commissioned in order to assess the full environmental impact of developing the field SG2.
Any development in Stonegate as a whole lacks sustainability.
Additional objections regarding future developments in Stonegate, East Sussex, which especially question the sustainability of any development in this village, are as follows;
Clean water supply to the Acorns is known to be at a low pressure. (We have had instances of no water multiple times in recent years due to water bursts elsewhere further down the water supply.)
A pavement from any development in the field SG2 to the village school will have to be built along Bardown Road in order to make it safe for children to walk to school as one is not in existence at present, but we question it’s feasibility due to the lack of available land.
Highways will need to review the speed limit adjacent to the field SG2, which is currently set at National limit.
The high voltage power lines which traverse the field SG2 diagonally will need to be diverted around field SG2 or be buried beneath it.
Stonegate lacks general amenities; it merely has a primary school, Church, village hall, playing fields and a letter box. Residents invariably have to travel to main shopping hubs in order to access usual day to day commodities etc. or have them delivered to them. This will increase traffic on local access roads to Stonegate whose surfaces and integrity are already seriously compromised.
The main line railway station is one mile away on an unlit road without a pavement. Similarly all bus services are over one mile away, again on an unlit road in the opposite direction, also without a pavement. Both roads carry vehicles with the potential to achieve national speed limit (60 mph). Consequently the local population are reliant on their own cars for transport and feel obliged to ferry their children around for their own safety. In a nutshell a car is an absolute necessity.
As a consequence of the above, there is congestion at the crossroads in Stonegate village frequently and there is a general "pinch point" outside the village school at most times of the day which is particularly difficult when the schools are going in or coming out. Any housing developments in the Stonegate will exacerbate this.
Does the school actually have capacity for more pupils? Does it have the physical space and sufficient teachers to deal with an increase in pupils?
The local Doctor's surgery is over stretched and cannot cope with the current population. Furthermore the surgery premises in Ticehurst have had to be closed due to the building being condemned, so all patients are compelled to attend clinics at Wadhurst Surgery.
Why build properties when several recently built nearby (at Burwash Common) remain unsold in addition to the adjacent 2 building plots?
We understand that a holding tank has had to be placed at Stonegate waste water site in order to cope with waste water from the current population. This indicates that the current waste water infrastructure is already at capacity in Stonegate and will need to be restructured.
Any development of field SG2 will impact the night sky negatively, even with light pollution strategies in place
We also object to any development of field SG2 as it will impact our ability as human beings to observe the night sky. It will also interfere with habits of nocturnal wildlife, such as owls, bats and moths. We understand that Ticehurst aspires to achieving Dark Skies status. Sadly, in spite of any developer’s best efforts, building on plot SG2, even with a Dark Sky strategy, will certainly destroy any future opportunities to observe the night sky. To illustrate how it is possible to view the night sky in Stonegate, we were able to observe Comet Neowise in 2020 simply by looking from our boundary across field SG2 into the night sky, simply by using binoculars and a camera. See appended photograph.
As a final point, it is important to note that field SG2 has been previously rejected several times in earlier Local Plans and that nothing has changed since then to commend it for development.
In conclusion, we appreciate the heavy burden of responsibility which falls upon the individuals who are considering all these proposals and thank them for taking the time to read our objections which are made, not just for ourselves but for future generations to come.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30789
Received: 21/03/2026
Respondent: Peter Manning
I am a stonegate resident living close to the proposed development off bardown road stonegate. Whilst I do not think the proposed will directly affect me I am more concerned about the infrastructure in stonegate to support such developments.
There are currently no bus services (the nearest nearly 2 miles away). There is a train station but realistically can only drive to it (no footpaths and very few verges) so might as well be several miles away.
There are no shops, doctors or any other services in the village and whilst there is a village hall and a playing field they do not appear to be well used.
The sewage treatment works constantly has problems coping with the existing numbers and the water supply suffers from relatively low water pressure.
I am not sure the existing infrastructure would be able to cope with additional numbers without significant investment.
I am a stonegate resident living close to the proposed development off bardown road stonegate. Whilst I do not think the proposed will directly affect me I am more concerned about the infrastructure in stonegate to support such developments.
There are currently no bus services (the nearest nearly 2 miles away). There is a train station but realistically can only drive to it (no footpaths and very few verges) so might as well be several miles away rather than the 1 mile).
There are no shops, doctors or any other services in the village and whilst there is a village hall and a playing field they do not appear to be well used.
The sewage treatment works constantly has problems coping with the existing numbers and the water supply suffers from relatively low water pressure.
I am not sure the existing infrastructure would be able to cope with additional numbers without significant investment in this infrastructure to support them.
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30927
Received: 22/03/2026
Respondent: Nikolas Radcliffe
Site 9 (Land at Lymden Lane)
Object. Lymden Lane is a narrow rural road with no footways, limited passing space and unsafe walking routes to the school and village centre. A footpath is not feasible. The site forms part of a drainage catchment and development risks disturbing natural runoff patterns. Stonegate also has serious sewage capacity problems. The site is unsuitable for allocation.
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,
Object
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 30928
Received: 22/03/2026
Respondent: Nikolas Radcliffe
Site 10 (Land east of Bardown Road)
Object. Both access routes—Bardown Road and Lymden Lane—are narrow, un‑footpathed and unsafe for pedestrians. The site is constrained, with poor space for parking and turning. Sewage capacity in Stonegate remains inadequate. These combined access, safety, drainage and infrastructure problems render the site unsuitable.
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,
Support
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 31214
Received: 13/04/2026
Respondent: Ticehurst Parish Council
Please see attached site assessments regarding proposed allocated sites within Stonegate.
Assessments include:
09 – Land at Lymden Lane, Stonegate - Policy SG1
10 – Land east of Bardown Road, Stonegate - Policy SG2
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
Support
Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Representation ID: 31276
Received: 23/03/2026
Respondent: Rurban Estates Limited
Rurban Estates Limited supports the allocation of Site SG2.
The site:
Is sustainably located in relation to the existing settlement;
Is available and deliverable in the short term;
Will contribute positively to rural vitality, including supporting local services such as schools; and
Is supported in principle by key consultees, including the High Weald National Landscape Unit.
The ESCC response further reinforces that:
Growth in rural villages such as Stonegate is both necessary and beneficial, particularly in maintaining
community infrastructure.
The allocation should therefore be:
Retained within the Local Plan, and
Refined where necessary, rather than restricted.
The recommended modifications set out above will ensure that the policy is:
Flexible and deliverable;
Consistent with a landscape-led approach; and
Capable of supporting a high-quality form of development.
See attachment