* RY4 Freda Gardham is a rare example of its build type in Rye and provides great potential in refurbishment not demolition.
* RY1 Tilling Green should be developed by the town council's community trust and is a good example of where proper social housing should go with no commercial properties on here.
* RY7 Sites along Rock Channel are a ridiculous proposition with flooding and should remain an industrial area - where are people supposed to work in Rye if every site is built on?
* RY9 Lower school site plan has too many dwellings on it, we don't need more older people's housing, but do need something for younger people. Protection of wildlife habitats are important here.
RY6 Rye Hire is an important business in the town, let them be!
RY2 should be left for related river industry sites, is a flood risk and highly unsuitable for housing.
We don't need these new homes in town that will end up being second homes and AirB&Bs; restrict second homes and a lot of properties will come back on the market to provide homes for young people. And leave space for employment - so many homes and so few jobs are not sustainable.

There are too many Developments for this small town. No infrastructure for all these people. Where are the all the children going to go to school. Only one school in Rye. One Doctors, where will these people all go to Dr. There only 2 Dentists in Rye. Both full and takes months and months and months to get appointment. Only one Supernarket. Ridiculous all these Developments for such a small town. Will totally spoil this TOWN.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP.

The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

Detailed comments on the 9 Brownfield sites within the development boundary are below.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

1. Rother will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019. I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

2. Rye has noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

3.In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

4.Rye notes the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

5.While Rye supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

6. While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years. There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

Section 1, Paragraph 1.1, Plan:
It is noted that this strategy forms only part of the Rother Local Plan

Section 1, Paragraph 1.11, Plan Period:
As Rye is reviewing its own NP (2023 to 2026) and is awaiting guidance on target numbers and plan period, presumably it can adopt and conform to the figures in the Rother Plan for its own Reg 16 version: 325 over period 2025 to 2042?

Section 1, Paragraphs 1.17 to 1.19, NP Allocations:
Rye has made its own site assessment which provided the basis for the made 2019 RNP. This has been reviewed and fed into the Rother site assessment. Indeed the Rother DC plan now replicates the Rye allocation, which is contrary to Locality guidance?

Section 1, Strategic Objectives Q1,
Rye supports the objectives and underscores the text on:
1. “Green and Blue infrastructure”: define?
2. Maximise “conservation”
3. “setting”
4. ADD “Affordable”?
5. Nil
6. ADD “support Town Centres”
7. “timely delivery of infrastructure including medical and sewerage”;
8. Support for rural travel”;
9. Support “accessibility”;
10. Support “Neighbourhood Planning”;
11. “priority use of brownfield” ; “appropriate density for local context”

Section 2, Paragraph 3.6, Housing Need:
Support need for “affordable housing and affordable social housing” Little has been achieved in the last 15 years. Homes are needed for people servicing the care, hospitality, retail, and education industries.

As the demand for 2nd homes influences housing need, was the demand across Rother factored into HEDNA? If so what figures were used for Rye?

Section 2, Paragraph 3.16, Allocations:
Allocations in the Rye NOP have been reviewed and numbers adjusted to take account of density and achievability.

Section 2, Paragraph 3.24, Supply Targets,Q2:
It is difficult to comment on The Rother total target but the disaggregated figure for Rye is achievable, despite the severe constraints in Rye such as flood risk and protected landscape. Because of the constraints, development potential is finite.

Section 2, Paragraphs 3.31 – 3.34, Q3:
As a rural service centre, Rye centre provides needs for both Rye and the surrounding villages. Numbers used to indicate dependency should reflect that.

Section 2, Paragraph 3.45, Housing Needs:
Did the housing need consider the impact of 2nd homes? In Rye the number could be as high as 400?

Section 2, Paragraph 4.1, Q5:
Rye supports the need for infrastructure to match development. Over the plan period the Rye population could rise by up to 2000 citizens (Rye and immediate village cluster) and more employees in the Harbour Road. This will place huge increased demand on water, medical, early years learning and sewerage. The record shows that providers have not matched the increased demand of recent developments.

Rye maintains its own IDP, which should be reflected in the Rother IDP.

Section 3, Paragraphs 5.12 – 5.13, Strategic Gaps:
Rye strongly desires to retain its Strategic Gap - flooded to 12 inches in the near past - which was designed to prevent the coalescence of Rye and Rye Harbour using essentially protected land originally salt marsh of high flood risk and high ground water. This has been acknowledged in all plans for the last 20 years.

The “green” gap adds value to the much loved character of Rye as it preserves the view of the town built on an outcrop rising from the Marsh.

Section 3, Paragraph 5.14, Development Boundary:
Rye has reviewed and made minor changes to its development boundary as part of the work of the RNP. The boundary is designed to prevent “urban creep” into marshland and areas of high flood risk and protected biodiversity. Certainly some land owners and developers would wish to seek further adjustment to enable development in the constrained areas , but Rye opposes this.

Section 3, Figure 9, Q7:
Rye is a categorised as “rural”, “heritage” and “maritime” location”. Rye strives to keep new building heights to 2.5 storeys to help preserve the unique character. It has reviewed appropriate density for new housing. It finds that areas of new development fall into the “Live Well Locally” category; therefore should be in the average 40 u/ha. The category “urban” does not realistically apply to Rye. For design purposes, the Neighbourhood Plan create three Zones: Yellow, Blue and Green. Only the Yellow can be sensibly called urban. The other two are rural suburban.

Section 3, Figure 10, Rye Strategy, Q9:
Rye is content that the Rye portion of the housing and employment growth figures are achievable within the plan period, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

Section 3, Figure 11, Dev Strategy:
Rye agrees that Figure 11 represents the development strategy and constraints in and around Rye.

Section 3, Paragraphs 6.11 - 6.18, Dev Strategy:
Rye endorses the text on rural communities and the need for sustainable transport.

Rye agrees that the five split area is a more helpful description than the current term of “Rural Rother”.

Section 3, Figure 23, Dev Summary:
Rye agrees that the figure represents the development strategy and constraints in and around Rye, provided that the employment growth figure takes account of further development in the Rye Harbour Road.

To be more sustainable, there is a need for more employment within walking/wheeling distance of the main outer suburbs of Rye.


Section 4, Paragraphs 7.1 to 7.9, Allocations:
Rye has made its own site assessment and site allocation, which provided the basis for the made 2019 RNP and subsequently the reviewed plan. The review has fed into the Rother site assessment (HELAA).

However as this Rother DC plan now replicates the Rye allocation, is this contrary to Locality guidance for the division of allocation between District and NPs? During consultations, what voice does Rye have about representations which are counter to the Neighbourhood Plan?


Section 4, Rye Allocations, Q49:
Rye notes that this section replicates the allocations including small sites, of the Rye NP. Rye will welcome advice on how representations made on this draft plan will be handled to take account of the Rye Neighbourhood Planning process.

RY1 - H3 - Tilling Green
Brownfield: suburban: 25 dwellings:
Intentionally the majority of dwellings should be affordable/social and the community centre retained.

RY2 - H5 - Winchelsea Rd East
Brownfield: suburban: 10 dwellings and 500 sq m of employment space:
Access to flood defences need to be protected.

RY3 - H6 - Winchelsea Rd West
Brownfield: suburban: 59 dwellings and 1900 sq m of employment space:
SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; Rother DC has agreed NO affordable?

RY4 - H7 - Former Freda Gardham
Brownfield: suburban: 50 dwellings and 500 sq m of employment space:
Developer is seeking variance to the development boundary to include 6 more dwellings. SuDS is a key requirement, in addition to a bund is required to defend against surface water on the marsh; affordable homes?

RY5 - H4 - Rock Channel Site A
Brownfield: suburban: 80 dwellings across two sites with different ownership:
SuDS is a key requirement; access to the A259 via St Margaret’s Terrace has to be resolved.

No Ref - Cyprus Place Depot
Brownfield : urban: 7 dwellings:
Leased to a business, which Rye TC has agreed is of community value.

RY7 - H4 - Rock Channel Site D
Brownfield: suburban: 600 sq m of employment space:
Only partially flood protected at high tides; ground floors need to be sacrifical. Environment Agency part owns this site.

RY8 - No Ref - 17-19 Tower St
Brownfield: urban: 6 dwellings

RY9 - H8 - Lower School Site
Brownfield: suburban: 88 dwellings:
Considered over development at 130 dwellings per hectare. No affordable,

It is also noted that despite local priorities to include affordable housing – for younger people in the hospitality, care and education industries - that during the planning process for RY3 and RY9 no affordable housing is required to be provided, on grounds of “viability”.

Section 5, Appx 1, Streets for All, Q66:
Rye supports the Streets for All policy

Section 5, Appx 2, Glossary:
Define:
“Urban, Suburban and Rural”?
“Green and Blue Infrastructure”?

Section 5, Appx 3, Development Options:
SD01- Agree Rye Cluster
SD04- Disagree: this is “urban creep” which development boundaries are set to deter
SD06: Agree; all development sites in Rye are Brownfield
SD08: Agree that this arbitrary division is rejected.
SD09: Agree any development must take account of constraints
SD011: Agree subject to constraints
SDO12: Agree
SDO14: Strategic gaps are designed to deter development to avoid coalescence, to protect biodiversity and avoid flood risk land. They should be retained.

Section 5, Appx 4, Development Strategy Options Q67 - 69:
Rye has no further comments.
Q69.

At our Planning and Townscape Committee on 9 February we considered the draft (Regulation 18) Version of the Rother Local Plan Development Strategy and Site Allocations.

As you will know that concurrent with your work on the Rother Local Plan, Rye has been reviewing its Neighbourhood Plan which has been in force since 2019.

I should say that the Rye work has been on hold since November 2025, as during the last consultation, we were advised the reviewed Rye Neighbourhood Plan would only run to 2028, unless numbers were increased. We are content with the target of around 325 dwellings in the plan period set by the Rother Plan. This would provide manageable development on our allocated sites and can be justified by the detail in the Rye site assessment document. However, a lifespan of only two years for the Neighbourhood Plan is clearly unacceptable given that to date the review alone has involved some 3 years of voluntary work (since 2023). Now that we have seen the Rother draft, we would hope that we can secure early guidance from Rother Planners on Rye numbers and timeline.

We have noted that you have replicated the Rye allocation in the draft Rother strategy. Our understanding is that “duplication” of policies between Neighbourhood and District plans is contrary to planning guidance. We are particularly concerned as to how you propose to handle representations on the replicated allocations which might conflict with local agreements within our Neighbourhood Plan.

In Rye, there are two key factors which affect housing need: 2nd homes (probably around 400 in the Parish) and the lack of affordable and affordable\social homes. Rye’s priority need is the latter to enable employees on low pay – care, hospitality and services such as education - to live in Rye, close to their places of employment. This is not only a key priority for individuals but affects sustainability. We would have liked to have seen more policy in the plan to handle both these issues.

We note the text on strategic gaps and development boundaries. Both have been given a lot of consideration in Rye, as they help preserve the unique character of the Town and take account of flood risk and protected biodiversity. The Rye view is to hold firm on both policies.

While we supports the description of “Rye and its cluster of villages” rather than the general term of “Rural Rother”, there is some conflict with your terms “rural, urban and suburban”. We would argue that Rye is “rural, historic and maritime”. The use of “urban” and “suburban” seems to be used to justify higher density of development. We do not agree this in the Rye context, where everywhere is within 10 minutes of rural land. It would be helpful if the terms could be defined and importantly, density be revisited. Our view is that around 40 units per hectare is appropriate in the Rye outer zones (as defined in the Neighbourhood Plan) to preserve a unique sense of place and environment.

While there is mention in the draft, we need more work with partners to ensure that infrastructure matches development. In particular, with planned development resulting in an estimated 2000 or so citizens in the Rye cluster, we will need more medical support, more capacity for nursery and first start education and key services such as sewerage, water and power, including EVCPs. The record shows little enhancement of key infrastructure in recent years.

There is much to like in the draft strategy, but perhaps the Rye concerns could be addressed in the next version.

RY8 should be retained as an essential business.

All riverside sites should require a riverside walk.

RY6: I consider Rye Hire a vital business serving the local community, and it would be a disaster if it were forced to move out of Rye. There is no other business offering the services that Rye Hire offers and we need to protect and cherish small, local businesses which keep Rye as a thriving community not just a turist destination.
Please ensure that Rye Hire can continue as a vital local asset for residents in and around Rye.

I am against the development of RY6.
This is a very small plot which has a very successful business which has been there since 1994.
As businesses have folded in the town, Rye Hire provides an excellent service to tradesmen, businesses and local residents.
Providing equipment hire, building materials from the smallest job to the largest, cycle hire and a lot more.
When all the other outlined areas have been developed on, especially the areas like the lower school site which has stood empty for years, then perhaps look at Rye hire land again. Until then please let a successful business carry on in peace.

RY6: The reallocation to housing of the current business premises leased to Rye Hire in Cyrus Place will deprive Rye and District of a unique source of tools and machinery, repair, and professional advice. Equally, as five local families depend on Rye Hire for their livelihood, the huge financial impact upon the business of uncertainty and potential relocation, poses a threat to their employment and household incomes. In an area with many rural households, Rye Hire’s supply of logs, propane, tools etc etc is a strategic asset well located at the heart of community, and assists it to be resilient and self-reliant. It goes without saying that it is also a key asset for the building trade. Please think again.

RY6
Rye Hire moved to this site some years ago and is a vital part of the local business infrastructure. This is a business based on experience and knowledge which is not available in large supermarket style outlets. It's machine hire and repair facilites are unique in this area and, although a fine resource for tourists with bike hire, it is one of the few amenities for the local people which is of considerable use. Not a tea shop or antique outlet. To move Rye Hire out of town would be no less than a travesty. To have Andy and his team's advice and seemingly endless knowledge on the doorstep is invalluable to all those of us who live and work in Rye.

Regarding proposed development in policy RY6. I completely object to this development for the reasons below:

First is the fact that you are going to remove Rye Hire from the town centre, which is completely unacceptable. This successful family business has been in Rye on the same site since 1994 & is still going strong today. Andy Polley & his team are valued members of the community & everyone appreciates their knowledge, expertise, & advice. The services provided by Rye Hire are vital to numerous businesses and charities operating in the area, not to mention farmers, smallholders, the fishing community, builders, DIYers, visitors and the townspeople generally. The wide range of services offered by Rye Hire and its ultra-convenient location are unparalleled. Rye Hire is an invaluable asset to the town & there is nowhere else to go for the services it provides. If this business was moved out of the town to accommodate this development, it would really harm the business & affect all the people that use & rely on it.

Second, as a family we live directly behind this proposed development & this would greatly affect our quality of living. The proposed height of the buildings would lead to a very large loss of light to our windows due to overshadowing, orientation, & proximity. Since the house was built our windows have had uninterrupted daylight for more than 130 years! This means that I have acquired a right to light as detailed in the Prescription Act 1832. In Section 3 it details specific arrangements for claims to the use of light, as follows :
‘When the access and use of light to and for any dwelling house, workshop, or other building shall have been actually enjoyed therewith for the full period of twenty years without interruption, the right thereto shall be deemed absolute and indefeasible’
So it clearly states that a right to light is acquired after 20 years enjoyment ‘without interruption’. This is not something I should have to give up just to accommodate this development.

Adding to this, our privacy would also be greatly affected & reduced by this intrusive development. Overlooking neighbours would be able to see into the bedroom, conservatory, kitchen, & back garden, resulting in unacceptable views into those areas. This would lead to uneasiness, feeling exposed, & create a sense of overbearing presence which would affect my family on a day-to-day basis. This would also significantly lower the value & marketability of our property which is unacceptable.

Dear Sirs,

Rother Local Plan and Planning proposals in Rye

I am a councillor on Rye Town Council but this letter is written in my private capacity, not on behalf of Rye Town Council.

Site RY6 in the local plan is the old council depot and is let to Rye Hire, a flourishing and much loved local business. Being able to walk to the depot and get a wide range of tools and equipment for property and garden maintenance is much appreciated by the people of Rye.

I understand that Rother District Council's plan is to evict this local business and grant itself planning permission to build seven houses on the site.

My family owns a small house in Ferry Road which backs onto the Rye Hire site. Until recently it has been occupied by a refugee Ukrainian family. They have now moved to Ireland so we have a local family moving in next month. One of the attractions of the house is that the back of the house and its garden look to the west and get the benefit of light and sun, especially in the afternoon, whereas the front opens to the busy main road. The present neighbours at Rye Hire are and always have been peaceful and pleasant neighbours and their building is far enough away to the west not to block out the light. Rother Council's proposal will cut out the sun and the light from our garden and destroy our privacy.

I strongly oppose this idea both on behalf of Rye Hire and on behalf of the family moving in to our house in Ferry Road.

Yours faithfully,

William Everett FALA LLM LETAPAEWE Land Agent Agricultural Consultant

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.