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

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.