Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Battle for Trees strongly objects to the Strategic Spatial Objectives as presented, on the basis that the development strategy proposed within the Local Plan fundamentally undermines and contradicts these stated aims. As drafted, the objectives are aspirational in tone but are not reflected in the reality of the plan’s policies, site allocations, or growth strategy.
The plan claims to mitigate and adapt to climate change, deliver net zero ambitions, and promote green and blue infrastructure. However, the heavy reliance on greenfield development in Battle directly conflicts with these objectives. Building on undeveloped land increases carbon emissions, removes natural carbon sinks, reduces biodiversity, and contributes to surface water runoff and flood risk. This approach makes a nonsense of any stated ambition to address climate change.
Similarly, the objective to maximise opportunities for nature conservation, biodiversity net gain, and the preservation of the High Weald National Landscape is fundamentally undermined by the scale and distribution of development proposed within it. With approximately 83% of the district lying within this protected landscape, the plan actively facilitates its gradual erosion through incremental greenfield development. This is not conservation it is managed tree destruction and environmental decline.
The objective to promote high-quality design and protect heritage is also contradicted by the allocation of sites in highly sensitive historic settings, such as BT7. Development in these locations will inevitably harm the setting of heritage assets and alter the character of historic settlements.
While the plan seeks to respond to the housing crisis and deliver sustainable, inclusive communities, the reality is that much of the proposed development is likely to result in high-cost, market-led housing on greenfield sites. This does little to meet the actual needs of local people, particularly first-time buyers, younger residents, and older people seeking to downsize. At the same time, more suitable brownfield opportunities such as those in Bexhill and Hastings remain underutilised.
The objective to deliver sustainable growth and regeneration is particularly inconsistent with the strategy being proposed. Rather than prioritising regeneration of underused urban areas, including town centres suffering from vacancy and decline, the plan promotes outward expansion with much tree destruction into the countryside. This diverts investment away from areas in need of renewal and instead accelerates sprawl.
The stated aim to focus growth in sustainable locations is also not supported by the evidence. Many proposed developments are in locations with limited infrastructure, poor transport connectivity, and existing congestion issues. There is insufficient clarity on how infrastructure will be delivered in a timely or effective manner to support this growth.
Furthermore, the objective to prioritise brownfield land is clearly not being met. The plan overwhelmingly favours greenfield development, despite the availability of brownfield sites in sustainable, well-connected locations. This represents a failure to follow one of the most fundamental principles of sustainable planning.
In conclusion, there is a clear and significant disconnect between the Strategic Spatial Objectives and the development strategy proposed in the Local Plan. The current plan makes a nonsense of its own objectives by promoting development patterns that directly contradict them. The Council must either fundamentally revise the strategy to align with these objectives or acknowledge that the objectives themselves are not being meaningfully delivered.

Battle for Trees strongly object to the proposed housing target of 8,427 dwellings over the plan period (495 annually) on the grounds that it is unsustainable, unjustified, and inconsistent with both national planning policy and the acknowledged constraints of the district.
The Council’s own evidence confirms that Rother is heavily constrained, with approximately 83% of the district within the High Weald National Landscape and around 90% affected by environmental or habitat protections. Under the National Planning Policy Framework (NPPF), these constraints represent a “strong reason for restricting development” (paragraph 11(b)(i)). The scale of housing proposed fails to properly reflect this fundamental limitation.
Furthermore, paragraph 180 of the NPPF requires planning policies to contribute to and enhance the natural environment, including protecting and enhancing valued landscapes and minimising impacts on biodiversity such as the loss of our valued trees. The proposed level of development, which will inevitably result in significant greenfield loss, directly conflicts with this requirement.
In addition, paragraph 189 of the NPPF states that great weight should be given to conserving and enhancing landscape and scenic beauty in National Landscapes, which have the highest status of protection. The proposed housing target will drive development within the High Weald National Landscape at a scale that is incompatible with this requirement.
Paragraph 190 of the NPPF is also clear that major development within National Landscapes should only take place in exceptional circumstances and where it is in the public interest. Given that the proposed housing target will necessitate multiple large-scale developments within the National Landscape, it is not credible to suggest that all such development can meet this exceptional circumstances test.
The proposed target is also unrealistic when considered against past delivery. Paragraph 67 of the NPPF requires that strategic policy-making authorities establish a housing requirement figure that is deliverable and based on evidence. Historic delivery in Rother has averaged approximately 215 dwellings per year, significantly below both the previous target and the proposed figure of 495 dwellings per year. The plan does not provide sufficient evidence to demonstrate that this substantial increase is achievable.
While paragraph 60 of the NPPF supports the use of the standard method as a starting point, it does not require housing need to be met in full where constraints apply. Indeed, paragraph 11(b) explicitly recognises that environmental and policy constraints may justify a lower housing requirement. The Council’s own evidence acknowledges a significant shortfall, reinforcing the conclusion that the standard method figure cannot be sustainably achieved.
The proposed housing target will also result in increased reliance on greenfield development with a high level of tree destruction contrary to paragraph 125(c) of the NPPF, which encourages the effective use of land, including the reuse of previously developed (brownfield) land.
In conclusion, the proposed housing target fails to comply with key provisions of the NPPF. It does not adequately account for environmental constraints, is not supported by evidence of deliverability, and will lead to unacceptable harm to the High Weald National Landscape and other protected assets. The Council should instead adopt a lower, locally derived housing requirement that aligns with national policy, reflects the district’s constraints, and prioritises sustainable development.

Battle for Trees objects to the destruction of greenfield and trees especially in a time of climate emergency. So the sites that are greenfield make no sense to be permitted:
BT1 -Object
BT2 -Object
BT6 - Object
BT7 - Object
BT9 - Object
BT10 - Object
BT11 -Object

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