Full text:
Question 56 - Proposed Site Allocations HG1–HG4
Overview of Positions
Planning permission has already been granted for sites HG1 (28 houses) and HG2 (26 houses). Sites
HG3 and HG4 are therefore the focus of this submission.
Both proposed sites are outside the existing development boundary, which was expanded in
November 2025. Both sites are within the High Weald National Landscape (HWNL) and as such are
afforded the protection of a “duty to conserve and protect the environment.” Development, especially
on such a major scale as that proposed for HG4, is directly at odds with the purpose of National
Landscape designation. Further, large housing estates are not characteristic of High Weald villages.
• HG1 (Land South of Iridge Place, 28 dwellings): Supported. The site benefits from planning
permission and represents a proportionate and well-related extension to the settlement.
• HG2 (Land South of Lodge Farm, 26 dwellings): Supported on the same basis.
• HG3 (Land to rear of The Olde Bakery): Supported in principle, subject to modification - see
response.
• HG4 (Land at The Lodge, London Road): Objected to in full - see response.
Site HG3 - Land to rear of The Olde Bakery
HG3 occupies a relatively sustainable location close to the village centre and would represent a
modest and reasonably integrated addition to the settlement. The community’s Neighbourhood Plan
Vision supports “sustainable and sensitive housing development that enables us to deliver on our
vision and objectives, developing the facilities that are needed to address the current and future
needs of our community.” HG3, properly conditioned, has the potential to meet that test. HGPC
supports the principle of this allocation subject to: reduction in residential density to fewer than 35
dwellings per hectare; parking provision at above-guidance standards, to address the significant
existing community parking deficit; and affordable housing prioritised for those with a local connection
to Hurst Green or surrounding parishes. Without these modifications, the allocation risks conflict with
the Hurst Green Design Codes and Neighbourhood Plan policies on character, density, and local
need.
Suggested Modifications
The following modifications are suggested to render this aspect of the plan sound:
Amendment 3 - Modification to Policy HG3
Suggested Modification
Amend Policy HG3 to:
(a) Reduce the indicative density to fewer than 35 dwellings per hectare;
(b) Require parking provision at above-guidance standards for all residential dwellings;
(c) Require the provision of dedicated community parking within or immediately adjacent to the site, to
alleviate the existing parking pressure on neighbouring residents who currently have no adequate
parking provision;
(d) Require affordable housing to be prioritised for those with a local connection;
Codes.”
(e) Insert: “Development must reflect the prevailing character of Hurst Green, provide a sensitive
transition to the surrounding countryside, and demonstrate compliance with the Hurst Green Design
Reason: Without modification, HG3 risks delivering development that conflicts with the Hurst Green
Design Codes and Neighbourhood Plan. These modifications ensure consistency with local character
policy and respond to the documented parking deficit.
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Site HG4 - Land at The Lodge, London Road
HGPC objects in the strongest terms to the allocation of Site HG4. The allocation is fundamentally
unsound on all four tests under NPPF paragraph 35 and should be deleted from the Local Plan.
Not Justified: No Evidence of Local Need
There is no settlement-specific evidence that supports the allocation of 150 dwellings at Hurst Green
beyond what is already committed. The AECOM Housing Needs Assessment (2019) and parish-level
survey identify need at a fraction of this scale - need that has already been met by existing
permissions at HG1 and HG2. The site was not present in the Council’s Summer 2024 consultation
and appeared, without explanation, in the January 2026 draft. The Parish Council notes with concern
that this reflects a pattern consistent with developer-led rather than plan-led allocation.
The site was previously assessed through the Neighbourhood Plan process under the reference
HG25 and was rejected by AECOM on grounds of remoteness, landscape sensitivity, and highway
conflict. The current proposal is substantially larger than the assessed site and none of the material
constraints have changed.
Not Justified: Major Development in a National Landscape
The proposal for approximately 150 dwellings constitutes major development within the High Weald
National Landscape. NPPF paragraphs 176–177 require refusal of major development except in
exceptional circumstances where it can be shown to be in the public interest. The three-part test -
addressing nature of need, absence of alternatives, and whether public benefit clearly outweighs
environmental harm - has not been addressed in any part of the draft allocation. No exceptional
circumstances case has been advanced.
A Planning Inspector dismissed a proposal for a single dwelling on part of this site in April 2020, citing
“significant harmful effect on the character and appearance of the AONB.” The current proposal is
materially larger, and the material considerations are unchanged.
Not Consistent with National Policy: Countryside and Settlement Character
Rother’s own draft Local Plan states that development in the countryside must be “strictly limited” and
must “maintain or improve rural character.” HG4 comprises isolated greenfield agricultural fields at the
northern edge of the settlement, outside the development boundary, and constitutes countryside by
the Council’s own definition.
The proposed density of approximately 35 dwellings per hectare is approximately 46% higher than the
densest existing development in Hurst Green (Coronation Gardens, 24 dph) and some seven to eight
times the density of comparable greenfield edge-of-village development in the area. It fails to provide
the sensitive and graduated transition to the surrounding countryside required by NPPF paragraph
130 and the Hurst Green Design Codes. It conflicts with Design Code policy HGNP.DC.2.5A, which
requires density to reflect the character of the surrounding area. This is not a natural extension of the
village - it is a high-density urban estate on open countryside.
Conflict with the Statutory Development Plan
The Hurst Green Neighbourhood Plan (made December 2025) is part of the statutory development
plan. The allocation conflicts with at least 11 of its 20 policies, including those relating to settlement
location and sprawl, countryside transition, density and character, A21 setback, dark skies, Local
Green Space, and protected views. The allocation was introduced into the draft Local Plan within
weeks of the Neighbourhood Plan’s adoption, without evidence and without justification. This directly
undermines the plan-led system. National policy (NPPF paragraphs 13–14 and 30–31) requires clear
and evidenced justification before departing from a made neighbourhood plan. None has been
provided.
Highway Safety
The A21 route through Hurst Green is considered one of the UK’s most dangerous stretches of road.
The increasingly high volume of traffic that passes through the village is not conducive to a safe and
healthy environment for Hurst Green’s community, and it is not appropriate to be considering any new
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major housing developments in the vicinity of the village which will contribute to traffic volumes. Hurst
Green is one of very few settlements – and by far the largest – on the A21 that is not bypassed.
The A21 presents a serious and documented pedestrian safety risk. A 151-resident petition in 2016
highlighted the dangers. The AECOM SEA (February 2023) validated those concerns. A child
pedestrian was seriously injured in a hit-and-run incident on the A21 in Hurst Green in February 2026,
during the consultation period itself. The primary school is situated directly on the A21, accessed via a
narrow pavement on the western side only. The development would add materially to pedestrian and
vehicle movements on this stretch of road, with no deliverable mitigation strategy identified.
The Parish Council notes the landowners’ suggestion that a roundabout at Cooper’s Corner
represents a community benefit capable of justifying the allocation. This is not a sound argument. Any
junction improvement at that location would be required as a direct consequence of the development
generating traffic: it is a standard planning obligation, not an independent public benefit. National
Highways reviewed and rejected the Cooper’s Corner roundabout proposal in 2025 as poor value for
money. It does not address speeding through the village or pedestrian safety on the A21 corridor.
Developer highway mitigation is not a justification for major development in a National Landscape.
Should a full bypass, as has been proposed in the past, remain on the table, then HG4 must
absolutely be kept free of development. Any future development options should avoid potential future
bypass and relief road locations. The allocation of 150 dwellings on this site would permanently
foreclose that option, and no assessment of this has been undertaken.
Physical and Environmental Constraints
The allocation has been advanced without adequate evidence. The following constraints - individually
significant and cumulatively severe - are not reflected in the capacity assessment of 150 dwellings:
• A high-pressure SGN gas transmission main crosses the northern portion of the site, creating a
no-build corridor and consultation zone that has not been accounted for in the capacity
calculations
• The northern field is required as the biodiversity receptor site for HG2. Development at HG4
would undermine the ecological function of that receptor site and create a fundamental conflict
with the Environment Act 2021 biodiversity net gain obligations
• Ancient woodland and hedgerow buffers requiring mandatory setbacks reduce the developable
area
• Surface water flood risk associated with the lake and watercourse
• The Lodge curtilage - identified in the draft policy as green infrastructure - is and would
presumably remain in private residential ownership and is not deliverable as public open space
unless it is demolished.
• The Lodge itself (Etchingham Lodge, c.1845) is a non-designated heritage asset. No heritage
impact assessment has been undertaken
When these constraints are properly excluded, the realistic developable area reduces to
approximately 2.2–2.7 hectares, supporting 22–40 dwellings at an appropriate density. The 150
dwelling figure is not credible.
Absence of Required Technical Evidence
The allocation has been made without the evidence required for a sound allocation at Regulation 18
stage. There is no Transport Assessment, Flood Risk Assessment, Ecological Impact Assessment,
Heritage Impact Assessment, Landscape and Visual Impact Assessment, Viability Assessment, or
Infrastructure Delivery evidence. This is inconsistent with sound plan-making practice and makes it
impossible to assess whether the allocation can be delivered.
Summary of Grounds for Objection to HG4
For ease of reference, HGPC’s grounds of objection to Site HG4 are summarised below:
• This site was previously dismissed as unsuitable for development by RDC in 2020 and none of
the reasons for rejection have been addressed.
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• It violates at least 11 NPPF (December 2024) policy areas: paragraphs 8, 11, 36, 84, 110, 124,
135, 139, 187, 189, and 190.
• This is an unsustainable location and a major development would result in harm to the HWNL
and urban sprawl. The northern part of the site lies well beyond the development boundary and,
with dangerous, narrow, polluted pavements along the busy A21 trunk road in a Dark Skies
area, even short journeys, for example to Hurst Green Primary School, will inevitably be
undertaken by car. Additionally, with few facilities, amenities or employment opportunities in the
village, the vast majority of trips to and from the development will be made by car.
• Direct conflict with the very recently made (December 2025) Hurst Green Neighbourhood Plan,
including direct violation of the established guidance requiring properties to be set back from the
A21 due to heavy traffic, and disregard of the community’s adopted planning policies.
• Critical infrastructure constraint – a high-pressure gas main running under the northern part of
the site poses a significant limitation on the development potential of a significant portion of the
site and is not reflected in the capacity calculations.
• Constitutes a major development in the HWNL without demonstrated exceptional circumstances.
RDC’s policy advocates against large estates in rural areas and for smaller developments of
good design, which fit harmoniously into the landscape.
• The RDC-commissioned AECOM Strategic Environmental Assessment (February 2023)
independently validated community concerns, supporting the unsuitability of the site for
development.
• Conflicts with adopted Hurst Green Design Codes: the proposed density of 35 dwellings per
hectare is almost 50% higher than any existing character area in the village.
• Fails RDC’s own A21 Corridor Strategy criteria – no reasonable level of local services and no
existing opportunities for sustainable travel.
• Contradicts RDC’s vision for Northern Rother, requiring sensitive development, sustainable
forms, protection of landscape character and farmland capacity.
• Contradicts RDC’s vision for the countryside and its twin overall priorities of “Green to the Core”
and “Living Well Locally.”
• Unrealistic housing capacity once The Lodge curtilage (identified as green infrastructure), the
gas main corridor, ancient woodland buffers, the HG2 biodiversity receptor site buffer, hedgerow
buffers and flood zone areas are excluded.
• The site (northern part in particular) is isolated from the village centre.
• Such a large, prominent development would have a major detrimental impact on RDC’s aims to
promote a Dark Skies policy within the HWNL.
• Destruction of non-designated heritage asset (The Lodge).
Conclusion on HG4
Site HG4 is not justified, not effective, and not consistent with national policy. It conflicts with the
statutory development plan. It is not supported by an adequate evidence base and is not
demonstrably deliverable. It should be deleted from the Local Plan without qualification. The allocation
also conflicts with every strand of the community’s Neighbourhood Plan Vision: it does not support
health and happiness - it adds children to a road that has already seriously injured a child; it does not
support business and tourism - it replaces productive farmland with a dormitory estate; it is not
sustainable and sensitive housing - it is unjustified major development in a National Landscape; it is
incompatible with the travel and transport vision - it creates 150 car-dependent households on the
most dangerous road in the village; and it contradicts the land and nature vision by permanently
destroying countryside the community has committed to protect. On every measure the community
has set for itself, HG4 fails.
Suggested Modifications
The following modifications are suggested to render this aspect of the plan sound:
Amendment 4 - Deletion of Policy HG4 (Principal Modification)
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Suggested Modification
Delete Policy HG4 in its entirety, including:
• The site allocation policy
• The Proposals Map designation
• All supporting text and cross-references in the Local Plan
Reason: As demonstrated in Part 3, HG4 fails comprehensively:
• Not justified: No evidence of local need; no exceptional circumstances case; site previously
rejected through the Neighbourhood Plan process and on appeal in 2020
• Not effective: No confirmed access or infrastructure delivery; constraints reduce realistic
capacity to 22–40 dwellings; no viability evidence
• Not consistent with national policy: Fails the NPPF major development test (paragraphs 176
177); conflicts with countryside, sustainable transport, and design policy
• Conflicts with the development plan: Direct conflict with 11 policies of the made Hurst Green
Neighbourhood Plan
Consequence if unmodified: HG4 is the single greatest risk to the soundness of the Local Plan as it
relates to Hurst Green. It will be a focal point of challenge at Examination. There is a high probability
that an Inspector would recommend deletion. Its continued inclusion creates significant legal risk
under section 113 of the Planning and Compulsory Purchase Act 2004.