Battle Town Council has a number of temporary sites already in place and have concerns regarding the further development of these sites, subject to conditions already in place.

Subject: Formal Objection to Site Allocation: Land adjacent to Fir Tree Cottage, Netherfield Hill, Battle (Policy Ba3)

I am writing to formally object to the proposed permanent allocation of the site at Netherfield Hill for gypsy and traveller pitches. This allocation is fundamentally inconsistent with the Rother Core Strategy, the National Planning Policy Framework (NPPF), and the statutory duties regarding National Landscapes.

My objection is based on the following specific legal and planning grounds:

1. Breach of Statutory Duty (Section 85, CRoW Act 2000)
The site lies within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000 (as amended by the Levelling Up and Regeneration Act 2023), the Council has a statutory duty to further the conservation and enhancement of the area.

• Policy Violation: The council’s admission of "harmful landscape impact" and "residential paraphernalia being out of keeping" proves that this allocation fails to enhance the landscape.
• Case Law: Planning inspectors have consistently ruled that "screening" via vegetation (as suggested in your policy text) is a transient mitigation and does not justify permanent harm to the intrinsic character of a protected landscape.

2. Failure to Meet NPPF "Exceptional Circumstances" Test

NPPF Paragraph 182 mandates that "great weight" be given to conserving National Landscapes. Furthermore, Paragraph 183 states that major development should be refused other than in exceptional circumstances. While this is a small-scale site, its permanent impact on the primary character of the High Weald is significant. The Council has failed to demonstrate that there are no alternative, less harmful sites available outside the National Landscape to meet the district's pitch requirements.

3. Conflict with Rother Core Strategy (Policy RSS1 & Policy EN1)

The allocation directly conflicts with:

• Policy RSS1: Which requires all development to "conserve and safely enhance the High Weald AONB."
• Policy EN1: Which protects the "sense of place" and "remote and tranquil character" of the countryside. The introduction of a permanent residential site in this location, with the associated domestic lighting, vehicles, and structures, permanently erodes the "tranquillity" which the Council is legally bound to protect.

4. Direct Threat to Irreplaceable Habitat (Ancient Woodland)

The site is adjacent to Ancient Woodland. The Standing Advice from Natural England requires a minimum 15-metre buffer zone to protect the complex root systems and ecosystem of ancient woods from "edge effects" (pollution, trampling, and invasive species).

• The policy text allows for this buffer but fails to account for the cumulative impact of permanent residential intensification.
• Under NPPF Paragraph 186(c), development resulting in the loss or deterioration of irreplaceable habitats should be refused.

5. Highway Safety and Visibility (Policy TR3)

The requirement for a 155-metre visibility splay to the south-east highlights the extreme danger of this stretch of Netherfield Hill. Rother Policy TR3 requires safe and convenient access for all. The frequent ingress and egress of large caravans on a road with known visibility constraints poses an unacceptable risk to road users. A temporary "tolerance" of this risk during a temporary permission period is legally distinct from a permanent "acceptance" of a hazardous junction.

Conclusion The Council's justification—that there is a "need" for pitches—does not legally override the protection of a National Landscape. An allocation that admits to "harmful landscape impact" is, on its face, a violation of the High Weald Management Plan and national policy. I formally request that this site be removed from the permanent allocation list.

GYP4:
This objection opposes the proposed permanent traveller/gypsy site allocation at Netherfield Hill (Policy Ba3). The site lies within the High Weald National Landscape, where the Council has a statutory duty under Section 85 of the CRoW Act to conserve and enhance the landscape. The Council’s own acknowledgement of “harmful landscape impact” shows this duty is not met, and screening vegetation cannot mitigate permanent harm.The proposal also fails the NPPF requirement to give great weight to National Landscapes and does not demonstrate the exceptional circumstances needed when less harmful alternative sites have not been ruled out. It conflicts with Rother Core Strategy Policies RSS1/EN1 by eroding tranquillity, introducing lighting and residential activity, and diminishing local character. The site borders Ancient Woodland, risking deterioration contrary to NPPF guidance. Finally, serious highway safety concerns remain due to the required visibility splays on a dangerous stretch of road. The allocation should be removed.

I formally object to the proposed permanent allocation of GYP4 in Netherfield Hill. The site lies within the High Weald National Landscape, where the Council has a statutory duty under Section 85 of the CRoW Act 2000 (as amended) to further conservation and enhancement. The Council’s own assessment acknowledges “harmful landscape impact” and development “out of keeping,” confirming this duty is not met.

The proposal also conflicts with the NPPF requirement to give “great weight” to National Landscape protection, and the Council has not demonstrated that less harmful alternatives outside the designation have been fully explored.

It is contrary to the Rother Core Strategy (RSS1 and EN1), which requires the High Weald to be conserved and tranquillity protected. The site’s proximity to Ancient Woodland risks deterioration of irreplaceable habitat, contrary to NPPF 186(c). Finally, the required 155m visibility splay highlights unsafe access, making permanent allocation unacceptable under Policy TR3.

1. GYP4: Land adjacent to Fir Tree Cottage, Netherfield

several retrospective Planning Applications for this site has only been given residential permission based upon specific residents declared status needs and not for any general traveller status for a limited temporary use until 2027-05-30, when quite rightly the site should be restored to “field” condition, given its proximity to Ashes Wood,
(a designated Ancient Replanted and Semi-Natural Woodland).

.It should be noted that the most recent permission granted (RR/2025/1015/P), stated: “The residential use of the site is not considered suitable on a permanent basis in this location due to the harm it causes to the landscape and scenic beauty of the High Weald National Landscape.

At this stage, we do not have evidence or information specific for Gypsies, Travellers and Travelling Showpeople, which are not already detailed in Policies GYP1 to GYP6, beyond those already identified in the draft Local Plan. It is, however, essential that any new allocations or changes to existing sites continue to consider supporting infrastructure, particularly Primary Care provision, to ensure that healthcare services can accommodate additional patients.

Please see individual responses and attachment for comments on the proposed sites in Battle Civil Parish.

Please see individual responses and attachment for comments on the proposed sites in Battle Civil Parish.

Please see individual responses and attachment for comments on the proposed sites in Battle Civil Parish.

GYP4: Retrospective, temporary permission was granted for this site solely on the basis that the short-term needs of the residents should be met. The site is not in a sustainable location and contravenes numerous policies relating to development within the HWNL. RDC commented in relation to the RR/2025/1015/P ‘The residential use of this site is not considered suitable on a permanent basis in this location due to harm it causes to the landscape and the scenic beauty of the HWNL’.

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.

My objection is that sites seem to have more freedom in terms of planning than what would normally be allowed. All communities should abide by the same rules and regulations.

Mountfield Parish Council object to the extension of the traveller site at Valentine Ridge (Policy GYP6). We consider it over-development and there will be a severe lack of services.

Policy Reference: GYP3
The original reasons for not granting permanent planning for this site still stand. This retrospective application was agreed on a temporary basis ONLY because Rother had no alternative site to offer when the family arrived in the field, and granted for only while the children were at school. The objections for this site remain: the harmful impact on the environment and High Weald National Landscape continues, as does the nuisance to the local residents. The planning permission should remain temporary until either another site becomes available or the children leave school. Then the land should be returned to its initial state with all the existing buildings and caravans etc. removed. See objections to the planning applications: RR/2020/1613/P and RR/2025/1848/RVC.

GYP1 –High Views, Loose Farm -1 pitch . OBJECT
This is in addition to pitches already on the site, with a history of retrospective planning applications. The area is becoming overdeveloped, particularly if the proposed site for 5 dwellings at Loose Farm goes ahead.

GYP2-Land south of Hastings Road- 5 pitches. OBJECT
It is considered this area is subject to excessive over development

GYP4 – Land to the rear of Fir Tree Cottage OBJECT
This site has had many retrospective Planning Applications and currently benefits from temporary planning permission for Temporary use until 30/05/27. It should then be returned to "field" condition, given its proximity to Ashes Wood (a designated Ancient Replanted and Semi-Natural Woodland). Making it permanent would ignore earlier planning findings and set a harmful precedent
The latest permission granted (RR/2025/1015/P) stated “The residential use of the site is not considered suitable on a permanent basis on this location due to the harm it causes to the landscape and scenic beauty of the High Weald National Landscape.”
The national speed limit suggests that the area should not be developed. For all of these reasons, all previous planning applications were approved on the condition that occupancy on this site is temporary, and is strictly for the existing occupants.

My objection still stands that No permanent planing should be given on this site.
The temporary planing permission was agreed By Rotherhithe district council until a suitable alternative site could be found or until the children leave school which should remain nothing has changed and at the time of this period the land should be returned to how it was and all existing caravans and buildings should be removed this land was never ment to be lived on.
Please see my objections in the original planning and all other Planning objections raised
RR/2020/1613/P and RR/1848/RVC

Policy No. GYP3
I object to this temporary site becoming permanent. Temporary permission was given only while the kids are at school to minimise the effect on the AONB. The site should remain temporary until another site becomes available instead of permission being given to develop it further. It is already a very obtrusive ugly development, ruining the AONB and so close to neighbouring houses, particularly the listed cottage on the south border.
As I have said before I often get the smell of cleaning water when I walk my dogs passed the site and I know there are problems with the fish in the nearby fishing pond. Another building with a kitchen and bathroom will create even more ground pollution. Two bird boxes and a bat box next to the mobile home wont do much to repair the damage to the local wildlife.

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

Battle for Trees opposese this site as it will entail a lot of tree destruction and is not suitable for a residental site without amenties.

GYP3
The residents on this site, since its inception, have not obeyed the current restrictions placed on their temporary planning permission, and it should not now be made a permanent site.
The site is within the AONB and outside the development boundary of the Parish. There is already considerable disturbance and effect on the neighbouring Grade 2 listed property, the rural setting, the flora and fauna. There are concerns about lack of foul water drainage and light pollution. The site does not fit the criteria for assessing the suitability of a travellers site.

Fir Tree cottage GYP4 marks the second time that travellers have illegally occupied a site in the AONB/ High Weald, then sought to have that regularised. Planning law must apply to all owners and this plan effectively says that there's one rule for ordinary developers and one for travellers. This should NOT be approved. Battle Parish would house 4 traveller sites (one existing) plus GYP4, GYP1 and GYP2, with GYP3 and GYP5 and 6 being within a short distance of Battle (and nearest town). This means 6 of 28 new sites will affect Battle Parish. This feels completely disproportionate. I ask what economic or social benefit it is to Battle or to Rother to provide so much land (which is far more generous density wise than other population groups). Why cannot sites outside High Weald be found, when the Report indicates how constrained Battle's development sites are already.

Has any consideration been made to the increased resources required in the village of Robertsbridge for the sites close to this village? Robertsbridge already has a more than excessive demand based on your housing allocations.

Policy Reference GYP3 There is a planning app in to make this site permanent RR/2020/1613/P & RR/2025/1848/RVC. This has been opposed by Brede Parish Council and many local residents. This document is saying it will become four plots.The original reasons for not granting permanent planning for this site still stand.This retrospective application was agreed on a temporary basis only because Rother had no alternative site to offer when the family arrived at field and granted for only while the children were at school.The objections for this site remain: the harmful impact on the environment and High Weald National Landscape continues as does the nuisance to the local residents.The planning permission should remain temporary until either another site becomes available or the children leave school. Then the land should be returned to its initial state with all the existing buildings and caravans etc.removed and not then become four plots as stated.

GYP4: Retrospective, temporary permission was granted for this site solely on the basis that the short-term needs of the residents should be met. The site is not in a sustainable location and contravenes numerous policies relating to development within the High Weald National Landscape (HWNL). Rother District Council commented in relation to the RR/2025/1015/P application "The residential use of this site is not considered suitable on a permanent basis in this location due to harm it causes to the landscape and the scenic beauty of the HWNL."

The current site has been granted temporary planning permission following an illegal occupation of the field. There are not suitable services to the site it borders a site of special scientific interest. A permanent building has been erected without planning permission and thereis no indication that the occupants will abide by restrictions put in place. The entrance is unsuitable on a dangerous stretch of road and it regularly floods. The site is an eyesore and there is no attempt to sheild it from the road.

Temporary permission was given to this site for traveller use for one family. There were a number of objections to the use of this site for such a purpose and the land should not be included in the local plan for permanent status.

GYP4
Several approved Gypsies and Travellers sites exist in and around Battle, ref Gyp2 and Gyp6. Both sites are submitted for additional pitches. Another new site proposed within Battle is GYP1.

GYP4 site is not fully approved. Temporary condition under RR/2022/2791/P was that permitted use shall be discontinued, and caravans removed from site on or before 22 June 2026. The site was not considered suitable for permanent occupation due to harm it causes to landscape and scenic beauty of High Weald AONB but permitted on temporary basis due to current lack of local provision of Gypsy and Traveller sites. A temporary permission will time limit harm to landscape and natural beauty of the High Weald AONB in accordance with Policies EN1(i) & LHN6 of the Rother LPCS. Sites do now exist in the area.
Permanent status would set a precedent for further development of land on Netherfield Hill.

GYP1&2 The sites should not be expanded by 6 pitches as it would be one of the largest sites in Rother, despite being enclosed on two sides by residential properties (11 homes directly). Increasing the size would impact residential amenity, as the travellers use the site for commercial purposes, despite planning conditions in 2012 stating "Condition 4. No commercial activities shall take place on the land, including the storage of materials”. The travellers have landscaping and tree surgery businesses, and use the site for commercial operations, including storage of vehicles, equipment (wood chippers, etc), and the regular burning of wood. Burning impacts residents by lowering air quality and preventing use of gardens (sometimes for the whole day). Existing use of flood lights on pitches (all night) also reduces residents' amenity due to light pollution. And dwellings have been added and expanded without planning permission (regarding pitch 6 - 2023 application).

Over the past 2 decades The population has increased but the number of affordable housing schemes have not followed which has today created a shortage of house. So I peronally think this kind of project will help a lot of people in finding an offordable property but also helping to improve the area. Also by building today it will cost less than doing this in 5 or 10 years with the cost of living increasing drastically year on year.

I am writing to formally submit my objection to the proposed allocations of sites GYP1 & GYP2, but also BT1 & BT8. As a resident of Hastings Road, I have daily experience of the site conditions.

Hastings Road is a very busy main thoroughfare. Loose Farm Lane, which would be the only vehicle access for both sites, is a blind turning. Travellers use long vehicles that would pose a large risk of accidents when coming out of the lane. The lane is also not suitable for lots of additional traffic.