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

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Object

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

Q1

Representation ID: 31455

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

Please see below

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q2

Representation ID: 31456

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

Please see below

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q3

Representation ID: 31457

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

Please see below

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q4

Representation ID: 31458

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

We believe that it is important that traveller provision is provided upon
suitable sites with allocations focused upon suitable sites with willing
landowners.

We confirm that due to ongoing issues with unauthorised encampments
across our landholdings we are not willing to make land within our
ownership available for this use.

Please see full representations and attachments.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q5

Representation ID: 31459

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

SCS would raise the need for utilities to be actively engaged with in the
plan making process, with particular emphasis on UK Power networks
given the scale of proposed electricity demand generated by the proposed
developments.

Please see full representations and attachments.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q6

Representation ID: 31460

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

We believe that the option of development within the strategic gap
between Hastings, St Leonards and Bexhill, is an option that should be
seriously considered given the integrated nature of the two local
economies which is recognised within the HENDA.

There are areas that have been allocated, protections within this that
appear to artificially constrain settlements that would otherwise form part
of a larger singular integrated conurbation.

Given that the three settlements are heavily economically integrated the
sustainability of retaining the strategic gap as a policy should be considered
as it creates a pattern of development that encourages longer journeys and
reliance on private cars.

Given the nature of the strategic gap in some locations previously not
considered for development due to this policy are otherwise well suited to
sustainable development.

Please see full representations and attachments below.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q7

Representation ID: 31461

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

Please see full representations and attachments below.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q9

Representation ID: 31462

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

As outlined within our response to question 3 we have concerns over the
quantum of commercial space required to meet demands associated with
the new housing and the corresponding population growth.

We welcome the allocation of additional land but consider that more land
may be required if sites are to serve as the commercial elements to an
urban extension scale project such as this.

In our view development at below 40% plot ratio as suggested in some
parts of the HEDNA would be challenging in viability terms as the costs of
servicing the sites would be excessive relative to the values unlocked.

Please see full representations and attachments below.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q10

Representation ID: 31463

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

As outlined in our responses to questions 3 and 9, we believe that the total
employment and commercial floorspace should be considered carefully
taking into account the wider uses proposed on some allocations, and
discrepancies in population forecast.

We would question the status of the Combe Valley Countryside Park and
how objectives will be achieved given its non-statutory status and the lack
of public ownership across much of the designated area. Policy should
consider providing suitable means for landowners to see benefit from
participating in projects that seek to enhance the policy objectives.

Please see full representations and attachments below.

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

Object

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

Q17

Representation ID: 31464

Received: 23/03/2026

Respondent: Sea Change Sussex

Representation Summary:

BX35 comments in relation to:

- Removal of site the wide master plan and site wide strategy ambitions from policy
- Proposed development density of only 25%
- The omission of Phase 3 from the draft allocation
- Commercial Demand
- Concern over development contributions
- Concern Over Habitat Buffers

Full text:

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019

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