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

Question 2 - Housing Target for the Local Plan
Position
HGPC has significant concerns about how the district-wide housing target of 8,427 dwellings is being
translated into settlement-level allocations. The target itself may or may not be justified at the district
level - but that is a separate question from whether specific villages have been allocated appropriate
shares of that growth based on local evidence.
The Parish Council's concern is not with the principle of planning for housing growth. It is with the
absence of any demonstrable link between the district-wide target and the scale of growth directed at
Hurst Green. A district-wide number is a starting point for spatial planning, not an end in itself. The
task is to distribute that growth based on the sustainability credentials and evidence of need for each
settlement. The community’s own Neighbourhood Plan Vision is explicit on what housing in Hurst
Green should achieve: the Parish will “support 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.” A proposal for 185 dwellings that is unsupported by
local evidence, directed at a location without the facilities to support it, and in conflict with the
community’s own planning framework is not sustainable and sensitive development. It is the opposite.
The Distribution Process
For Hurst Green, the distribution process has produced a result that cannot be reconciled with
evidence-based planning:
• The housing requirement increased by 487% in six months - from 38 dwellings in the Summer
2024 consultation to 185 dwellings in the January 2026 draft - with no published settlement
specific justification.
• The AECOM Housing Needs Assessment (2019) and parish-level survey work identify need at a
materially lower level, and that need has already been met by extant permissions.
• No settlement-level assessment has been published that explains why Hurst Green - a village
with no GP surgery, no secondary school, no supermarket, limited other facilities, over 90% car
dependency, and a documented highway safety crisis - has been identified as a location for
growth on this scale.
A district-wide housing target does not, of itself, provide the evidence base required to allocate a
specific quantum of development to a specific settlement. That requires local evidence. In the case of
Hurst Green, that evidence does not exist and has not been published. The proposed housing
requirement of 185 dwellings is therefore not justified regardless of the district-wide target, and the
allocation of Site HG4 is not justified regardless of the housing requirement.
Conclusion on Question 2
HGPC requests that the Council publishes the settlement-level evidence underpinning the allocation
of 185 dwellings to Hurst Green before the Regulation 19 stage. In the absence of such evidence, the
Local Plan cannot be considered sound in respect of its distribution of growth within the Northern
Rother sub-area.
Suggested Modifications
The following modifications are suggested to render this aspect of the plan sound:
Amendment 2 - Revision of Housing Requirement for Hurst Green
Suggested Modification
Delete the housing requirement of 185 dwellings for Hurst Green.
Replace with:
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“Housing provision for Hurst Green will be proportionate to the settlement’s role, function, and
constraints, and will be based on robust, up-to-date, settlement-level evidence of local housing need.
Committed development (HG1 and HG2) will be credited against any revised requirement.”
Reason: The increase from 38 to 185 dwellings has no published evidential basis. The current figure
creates legal and examination risk.
Consequence if unmodified: The plan contains a housing requirement that is not evidence-based,
creating a clear point of failure at Examination and generating continued pressure for unsuitable
allocations.

Question 5 - Infrastructure Needs and Priorities
Position
HGPC welcomes the opportunity to comment on infrastructure needs across the district. The Parish
Council's observations relate primarily to Northern Rother, and specifically to the infrastructure
constraints that make Hurst Green an unsuitable location for significant growth - but the issues raised
also reflect wider problems across the sub-area that the Local Plan must address.
Highway Infrastructure
The condition of the road network in Northern Rother is a serious and documented problem. The A21
and all key routes connecting the sub-area to the wider road network - including routes towards the
M25 - pass through or close to Hurst Green. The cumulative impact of the existing traffic volume,
combined with the poor structural condition of rural roads across the sub-area, makes this one of the
least well-served parts of East Sussex in terms of strategic road connectivity.
Potholed and poorly maintained roads are not merely an inconvenience - they are a direct safety risk
to all road users and represent a constraint on the viability of any significant development without prior
and substantial investment. The Local Plan must demonstrate that the infrastructure required to
support its proposed growth is deliverable and funded. In Northern Rother, that case has not been
made.
Hurst Green sits at the junction of the A21, A229, and A265. All three routes out of the village - north
and south on the A21, east on the A229, and west on the A265 - are A-roads carrying high volumes of
traffic at speeds incompatible with the absence of safe pedestrian and cycling infrastructure. This is
not a settlement that can accommodate major growth without first resolving its strategic highway
position. The Council's own Cabinet Report acknowledges that A21 improvements are currently
unfunded.
Of note, Hurst Green is one of very few settlements (and by far the largest) on the A21 that is not
bypassed. Additionally, having a primary school situated directly on the A21, and which is poorly
accessed with a narrow pavement on the western side of the A21 only, adds to the considerable road
safety and health risks the A21 represents to residents of Hurst Green. There has never been a
stronger argument for dualling this stretch of the A21 carriageway. The community’s Neighbourhood
Plan Vision states that the Parish will “seek to remove all non-local traffic from the Parish’s existing
roads, creating an environment that reduces the speed of motor traffic and encourages walking,
cycling and low carbon transport over car-use for shorter journeys.” Every additional dwelling directed
at Hurst Green without first resolving the A21 makes that vision harder to achieve, not easier.
Active Travel Infrastructure
There is no safe cycling provision anywhere in Northern and North-West Rother. The roads are too
narrow, too fast, and too heavily used by HGVs to support cycling without dedicated infrastructure.
There are no footpaths connecting settlements. Walking between villages - even short distances -
requires using A-roads with no pavements, no lighting, and no safe crossing points.
This is not a marginal concern. National planning policy (NPPF paragraph 110) requires that
development should be located and designed to give priority to pedestrian and cycle movements and
create access to high-quality walking and cycling networks. A strategy that directs major growth to
settlements where these conditions do not exist, and where there is no funded plan to create them, is
not consistent with national policy.
HGPC requests that the Infrastructure Delivery Plan sets out specific and funded proposals for active
travel improvements in the Northern Rother sub-area before the Regulation 19 stage. In the absence
of such proposals, the housing allocations directed at settlements such as Hurst Green cannot be
considered sound. This matters not only as a planning policy issue but as a fundamental community
health concern. The Neighbourhood Plan Vision commits the Parish to becoming “a thriving, safe and
friendly village within the High Weald which fosters a healthy lifestyle and encourages residents to live
active, social and meaningful lives.” An infrastructure framework that cannot provide safe routes for
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children to walk to school, or residents to cycle to a neighbour’s village, is incompatible with that
vision.
Water Supply and Drainage
Hurst Green and the surrounding area have experienced persistent and well-documented problems
with water supply. South East Water has faced significant challenges in maintaining supply reliability
across parts of East Sussex, and local residents have experienced supply interruptions and pressure
issues. These are not trivial inconveniences - they reflect structural capacity constraints that must be
resolved before additional significant housing development is appropriate.
Sewerage and drainage infrastructure in the village is similarly constrained. The surface water
flooding associated with the HG4 site - including the lake and watercourse - has not been assessed in
an appropriate Flood Risk Assessment. The allocation has been made without any demonstrated
evidence that the necessary utilities infrastructure can be delivered.
Conclusion on Question 5
The infrastructure constraints facing Hurst Green and Northern Rother are severe, documented, and
in most cases unfunded. The Local Plan must not proceed to Regulation 19 with significant growth
allocations in this sub-area until a credible, funded Infrastructure Delivery Plan is in place that
demonstrates how these constraints will be resolved. HGPC requests that the Council addresses this
before the next consultation stage.

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.

Question 68 - Interim Sustainability Appraisal
Position
HGPC has reviewed the Interim Sustainability Appraisal (SA) produced in support of the Regulation
18 consultation and has serious concerns about its robustness, independence, and internal
consistency, particularly in respect of the Hurst Green site assessments.
Concerns Regarding Independence and Professional Standards
A Sustainability Appraisal is a statutory requirement of plan-making under the Planning and
Compulsory Purchase Act 2004 and the Environmental Assessment of Plans and Programmes
Regulations 2004. It is intended to provide an objective and independent assessment of the social,
economic, and environmental implications of the plan's proposals.
The Interim SA as published does not clearly identify the qualifications or professional credentials of
those who produced it. For a statutory document of this significance, the certifications and
professional standing of the authors should be stated explicitly. Their absence makes it impossible for
consultees to assess the objectivity and competence of the assessment.
HGPC is concerned that the SA may not have been produced with sufficient independence from the
plan-making team. Where a Sustainability Appraisal is produced in-house, or without clearly
independent professional oversight, its conclusions carry less weight and are more susceptible to
challenge. The Council should confirm the basis on which the SA was produced and by whom.
Conflicting and Inconsistent Scoring for Hurst Green Sites
HGPC has identified what appears to be inconsistent and conflicting scoring in the SA in relation to
the sites proposed for allocation in Hurst Green. In particular:
• Sites that share substantially the same locational characteristics - the same A21 frontage, the
same distance from services, the same National Landscape constraints - appear to have been
assessed differently without explanation.
• The scoring for transport accessibility and sustainability criteria does not appear to reflect the
documented evidence of over 90% car dependency and the absence of safe walking and cycling
routes confirmed by the Council's own commissioned AECOM assessment.
• The assessment of landscape sensitivity does not appear consistent with the conclusions of the
AECOM Strategic Environmental Assessment (February 2023), which validated community
concerns about the unsuitability of the HG4 site for development.
These inconsistencies are material. Where a Sustainability Appraisal produces results that conflict
with the evidence base that the plan-making authority has itself commissioned, that conflict must be
explained and resolved. It cannot simply be ignored in the allocation process.
Subjectivity of Assessment
HGPC is further concerned that elements of the SA appear to reflect subjective judgements that are
not grounded in objective evidence. A robust SA should set out clearly the criteria applied, the
evidence relied upon, and the reasoning by which scores have been assigned. Where the SA lacks
this transparency, its conclusions cannot be relied upon as a sound basis for plan-making decisions.
Conclusion on Question 68
HGPC requests that the Council commissions a fully independent review of the Sustainability
Appraisal before the Regulation 19 stage, with particular attention to: the credentials and
independence of those producing the assessment; the consistency of scoring across comparable
sites; and the reconciliation of SA conclusions with the wider evidence base, including the AECOM
SEA. A flawed SA is a material risk to the soundness of the Local Plan at Examination.

Question 69 - Other Issues, Options or Other Matters
Hurst Green Parish Council supports a proportionate, evidence-based, and plan-led approach to
meeting housing needs in the district. The Parish Council does not object to growth in principle, and
supports the allocations at HG1 and HG2 and the principle of HG3 subject to modification.
In response to Question 69, HGPC wishes to place on record the following overarching concerns,
which cut across all the questions addressed in this representation and which the Parish Council
considers the Inspector should have regard to at Examination.
This representation addresses eight consultation questions. Across all of them, a consistent picture
emerges: the draft Local Plan is directing unjustified levels of growth to a settlement whose
constraints are well-documented in the Council’s own evidence, whose infrastructure is inadequate
and in many cases unfunded, and whose recently adopted Neighbourhood Plan is being overridden
without justification or explanation.
The current draft Local Plan, as it relates to Hurst Green:
• Proposes an unjustified housing requirement unsupported by any settlement-level evidence,
with no published explanation for an increase of 487% in six months.
• Applies the A21 Corridor Strategy inconsistently and against the Council’s own evidence,
directing growth to a settlement that fails its own sustainability criteria.
• Fails to apply its own Countryside Vision consistently, directing major development into the
National Landscape without exceptional circumstances.
• Proposes a density of development at HG4 that is inconsistent with the character of the
settlement, contrary to the Hurst Green Design Codes, and unsupported by the Density Study.
• Overrides a recently made Neighbourhood Plan without justification, evidence, or explanation, in
direct conflict with the statutory development plan.
• Includes a fundamentally unsound site allocation (HG4) that fails all four NPPF soundness tests.
• Is not supported by a credible Infrastructure Delivery Plan addressing documented road, water,
and active travel constraints.
• Is accompanied by a Sustainability Appraisal that is not demonstrably independent, contains
inconsistent scoring, and conflicts with the Council’s own commissioned evidence.
In the absence of the modifications set out in the Schedule of Suggested Main Modifications above,
the plan is at significant risk of being found unsound at Examination, particularly in respect of the
Northern Rother strategy and Site HG4.
HGPC formally requests that:
1. The spatial strategy for Northern Rother be reconsidered with Hurst Green removed from
the A21 Corridor Strategy or reduced to a lower-tier designation consistent with its sustainability
profile.
2. The housing requirement for Hurst Green be reduced to a level supported by robust, up-to
date, settlement-specific evidence of local housing need.
3. Policy HG3 be modified as set out in Amendment 3 to ensure compliance with local character
and design policy.
4. Policy HG4 be deleted from the Local Plan in its entirety as set out in Amendment 4.
5. The Council publish the settlement-level evidence underpinning the proposed increase from 38
to 185 dwellings before the Regulation 19 stage.
6. The Council publish a credible, funded Infrastructure Delivery Plan for the Northern Rother
sub-area, addressing road condition, active travel, water supply, drainage, and utilities before
the Regulation 19 stage.
7. The Density Study be revised to set differentiated upper density limits for greenfield edge-of
settlement development within the High Weald National Landscape, consistent with the
character of existing development.
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8. The Countryside Vision be strengthened to explicitly require that development in the National
Landscape is strictly limited, and that its policies are applied consistently to all site allocations.
9. The Interim Sustainability Appraisal be independently reviewed before the Regulation 19
stage, with particular attention to the consistency of scoring for Hurst Green sites and
reconciliation with the AECOM Strategic Environmental Assessment.

Question 63 - Other Possible Sites in the Northern Rother Sub-Area
Position
The Parish Council does not propose any additional sites for allocation in Hurst Green. The sites
already committed - HG1 and HG2, totalling 54 dwellings - adequately meet the locally evidenced
level of housing need. The principle of HG3 is supported subject to modification. HG4 should be
deleted.
Why No Additional Sites Are Proposed
It would be inconsistent for HGPC to argue that the proposed scale of growth at Hurst Green is
unjustified and then propose additional sites that would increase growth further. The Council's case is
that housing provision should be evidence-led.
The constraints that apply to HG4 apply equally to any other significant greenfield site at the edge of
Hurst Green:
• The entire village and its surroundings lie within the High Weald National Landscape, where
major development requires exceptional circumstances.
• The A21 presents a documented and serious pedestrian safety constraint that limits the ability of
any significant site to the north of the village to function sustainably.
• Car dependency exceeds 90% and there are no realistic prospects for material improvement in
public transport or active travel within the plan period.
• The Hurst Green Neighbourhood Plan, recently made following community referendum,
establishes a clear framework for appropriate development in the village. That framework should
be the starting point for any assessment of additional sites.
Employment Land Must Not Be Treated as a Housing Alternative
HGPC notes that some representations may suggest that protected employment sites within the
village should be considered for housing on the grounds that they represent brownfield or previously
developed land. The Parish Council strongly resists this. The Hurst Green Neighbourhood Plan
protects employment sites specifically to preserve local employment opportunities, consistent with the
community’s Neighbourhood Plan Vision which commits to “strongly support local prosperity and will
create a thriving village community, that supports existing and new local businesses.” Releasing
protected employment land for housing would contradict that vision, require overriding the
Neighbourhood Plan, and remove the very limited employment land the village possesses.
Conclusion on Question 63
No additional sites are proposed. HGPC requests that the Council reduces the housing requirement
for Hurst Green to a level justified by local evidence, retains HG1 and HG2, supports HG3 with
modification, and deletes HG4 entirely.

Question 15 - Vision for the Countryside
Position
HGPC strongly supports a robust Vision for the Countryside that genuinely limits development in rural
and countryside locations. The Parish Council is concerned that the draft Vision is not being applied
consistently and that the HG4 allocation directly contradicts the countryside objectives the Vision sets
out.
The Draft Vision Must Be Applied Consistently
Rother's draft Local Plan states that development in the countryside must be "strictly limited" and
must "maintain or improve rural character." It also articulates priorities of "Green to the Core" and
"Living Well Locally." HGPC fully endorses these ambitions - but they are only meaningful if applied
consistently.
The HG4 site comprises isolated greenfield agricultural fields at the northern edge of Hurst Green,
outside the development boundary and within the High Weald National Landscape. It is countryside
by the Council's own definition. Allocating 150 dwellings at 35 dph on this land is not "strictly limited"
development. It does not "maintain or improve rural character." It removes productive farmland
permanently, creates a high-density urban estate at the edge of a National Landscape village, and
conflicts directly with the countryside vision the Local Plan sets out to deliver.
• Large housing estates are not characteristic of High Weald villages. The scale, form, and
density of what is proposed at HG4 would be out of place in any High Weald village. At Hurst
Green, the site is not a natural extension of the settlement but a separate incursion into open
countryside with no integration into the existing village fabric.
• Farmland loss is permanent. The two agricultural fields that comprise HG4 represent
productive rural land that, once developed, cannot be recovered. The countryside vision should
explicitly resist the loss of agricultural land where there is no compelling local need.
• Dark skies are incompatible with 150 dwellings. Hurst Green is within a designated Dark
Skies area. The light pollution from 150 homes and associated infrastructure would cause
irreversible harm to the dark skies character of this part of the National Landscape.
The Vision Should Be Strengthened
HGPC requests that the Vision for the Countryside be strengthened to:
• Explicitly state that development in the countryside within the High Weald National Landscape
will be refused unless it demonstrably conserves and enhances landscape character and meets
the major development test where applicable
• Require that any allocation of greenfield countryside land demonstrates a clear local need that
cannot be met within or adjacent to the settlement boundary
• Protect agricultural land and dark skies areas from development that does not meet a locally
evidenced need
Conclusion on Question 15
The countryside vision is sound in principle but is directly undermined by the allocation of HG4. The
Hurst Green community’s own vision commits the Parish to going “to great lengths to protect and
promote our outstanding natural environment and will seek to improve access to the countryside and
our nearby green spaces, restoring land for the benefit of people and wildlife.” Allocating 150 homes
on isolated countryside fields within the National Landscape is a direct contradiction of that
community commitment. HGPC requests that the Vision be strengthened as set out above, and that it
be applied consistently - including by deleting the HG4 allocation, which is irreconcilable with the
Council’s own countryside objectives and the community’s own vision for the land around their village.
Suggested Modifications
The following modifications are suggested to render this aspect of the plan sound:
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Amendment 5 - Strengthening of National Landscape Policy
Suggested Modification
Insert a plan-wide policy clarification:
“Within the High Weald National Landscape, development that constitutes major development will only
be supported where the applicant demonstrates exceptional circumstances and that the development is
in the public interest, applying the three-part test required by national policy (NPPF paragraph 177).”
Reason: The current draft understates the significance of the major development test and creates
ambiguity. Explicit policy language ensures consistent application and reduces the risk of legal
challenge following adoption.

Question 14 - Vision and Development Strategy for Northern Rother
Overall Position
The inclusion of Hurst Green within the A21 Corridor Strategy, and the scale of development
proposed, is neither justified by the evidence base nor consistent with national planning policy or the
Council’s own stated objectives. The strategy as drafted directs a disproportionate and unsustainable
quantum of development to a settlement whose constraints are well-documented in the Council’s own
commissioned evidence.
Soundness: Justified (NPPF paragraph 35(a))
The proposed housing requirement for Hurst Green has increased from 38 dwellings in the Summer
2024 consultation to 185 dwellings in the January 2026 draft - an increase of approximately 487%
within six months. No settlement-specific evidence has been published to justify this increase.
The most recent available local evidence - the AECOM Housing Needs Assessment (2019) and
parish-level survey work - identifies need at a materially lower level, measured in tens of dwellings.
That need has already been met by extant permissions at HG1 and HG2.
A district-wide housing requirement does not, of itself, justify allocating development to a specific
settlement at a scale that is unsupported by local evidence. The combined effect of committed and
proposed development would increase Hurst Green’s housing stock by 37%, from a base of
approximately 650 dwellings. There is no evidence base to support growth of this pace or scale in this
location.
Soundness: Consistent with National Policy (NPPF paragraph 35(d))
National Landscape (High Weald)
Hurst Green lies entirely within the High Weald National Landscape. National policy (NPPF
paragraphs 176–177) requires great weight to be given to conserving and enhancing landscape
character, and the refusal of major development except in exceptional circumstances in the public
interest. Rother’s own Cabinet Report (December 2025) acknowledges that 83% of the district lies
within the National Landscape and characterises this as “a significant constraint to major
development.” The cumulative scale of development proposed at Hurst Green constitutes major
development. No exceptional circumstances or public interest case has been advanced. The strategy
is therefore inconsistent with national policy.
Sustainable Development and Transport
The strategy conflicts with national policy requiring sustainable patterns of development (NPPF
paragraphs 8, 11, 104–111). The Council’s own evidence confirms that car dependency in Hurst
Green exceeds 90% of households - a figure that has increased despite investment in bus services
such as the flexi-bus. The A21 presents a well-documented and serious pedestrian safety hazard.
Hurst Green is one of very few settlements of its size on the A21 not served by a bypass - a
circumstance that materially limits its capacity to absorb growth without increasing harm.
Soundness: Effective (NPPF paragraph 35(b))
Misapplication of the A21 Corridor Strategy
The A21 Corridor Strategy is intended to direct growth to settlements with adequate services,
sustainable transport options, and capacity for growth. Hurst Green demonstrably fails on every
criterion: there is no GP surgery, pharmacy, dentist, supermarket, or secondary school; public
transport is limited and infrequent; there is no safe walking or cycling route to Etchingham station; and
infrastructure constraints including water supply and drainage are known and unresolved.
The Council’s own Cabinet Report concedes that A21 bypass improvements are “currently unfunded”
with no evidence they will come forward in the plan period. Applying the A21 Corridor Strategy to
Hurst Green is internally inconsistent with its own stated criteria and fails the effectiveness test.
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The Parish Council also notes that the HG4 site lies on a possible alignment for a potential A21
bypass or relief road - an option that has been discussed for decades and which represents a
prerequisite for truly sustainable development at Hurst Green. Allocating this land for 150 dwellings
would permanently foreclose that option. No assessment of this interaction has been undertaken.
Conflict with the Development Plan
The Hurst Green Neighbourhood Plan was subject to independent examination, approved by
community referendum, and made by Rother District Council in December 2025. It forms part of the
statutory development plan. The proposed spatial strategy introduces a scale of growth not
contemplated by the Neighbourhood Plan and conflicts with multiple adopted policies. National policy
(NPPF paragraphs 13–14 and 30–31) requires that neighbourhood plans are upheld. No justification
for departure has been provided.
Infrastructure and Deliverability
The strategy is not supported by a credible Infrastructure Delivery Plan. There is no evidence of
deliverable improvements to the A21, education or healthcare capacity to accommodate additional
population, utilities and drainage capacity, or a funding mechanism for necessary infrastructure. This
absence undermines the strategy’s effectiveness and its deliverability over the plan period.
Hurst Green suffers problematic water supply, sewerage and drainage issues. The village has sparse
public transport, no local secondary school, no local healthcare provision, and has long experienced
extremely poor parking provision – an issue which a large population increase would significantly
exacerbate. No details are provided about how existing basic infrastructure capacity would
accommodate the substantially increased population that the proposed 239 houses would produce.
Conclusion on Question 14
The spatial strategy for Northern Rother, as it relates to Hurst Green, is not justified, not effective, and
not consistent with national policy. The community’s Neighbourhood Plan Vision reflects this directly:
it commits the Parish to going “to great lengths to protect and promote our outstanding natural
environment” and to developing “a thriving village community where people want to live, work and
visit.” A spatial strategy that overrides community evidence, bypasses the Neighbourhood Plan, and
directs major growth to an unsustainable location is incompatible with both of those aspirations.
HGPC requests that the strategy be revised to remove Hurst Green from the A21 Corridor Strategy
or, at minimum, to reduce its housing requirement to a level supported by robust, settlement-specific
evidence of local need.
Suggested Modifications
The following modifications are suggested to render this aspect of the plan sound:
Amendment 1 - Amendment to Northern Rother Spatial Strategy
Suggested Modification
Amend the Vision and Development Strategy for Northern Rother to:
(a) Remove Hurst Green from the A21 Corridor Strategy; or
(b) Reclassify Hurst Green as a lower-tier settlement where development is limited to meeting locally
evidenced needs only.
Insert supporting text:
“Within the High Weald National Landscape, the scale and distribution of development will be
determined by the requirement to conserve and enhance landscape and scenic beauty. Settlements with
limited services, high car dependency and documented highway safety issues will accommodate only
proportionate, evidence-based growth.”
Reason: The current strategy is not justified, not effective, and not consistent with national policy. It
applies the A21 Corridor Strategy to a settlement that demonstrably fails the strategy’s own
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sustainability criteria and fails to account for National Landscape constraints acknowledged in the
Council’s own evidence.
Consequence if unmodified: The plan relies on a spatial strategy that is internally inconsistent and
unsupported by evidence. This constitutes a clear point of failure at Examination and will generate
continued development pressure on unsuitable sites.
Amendment 6 - Neighbourhood Plan Safeguarding
Suggested Modification
Insert supporting text within the spatial strategy:
“The Council is committed to upholding made neighbourhood plans as part of the statutory development
plan. Site allocations and development proposals must demonstrate general conformity with made
neighbourhood plans unless clear, evidenced and material considerations justify departure. The Council
will not depart from a recently made neighbourhood plan on the basis of landowner promotion alone.”
Reason: The current approach effectively overrides the Hurst Green Neighbourhood Plan - made by
referendum weeks before this consultation - without justification or evidence. Explicit safeguarding
language is necessary to protect the integrity of neighbourhood planning.

Question 7 - Preferred Approach for Housing Density
Position
HGPC welcomes the opportunity to comment on the preferred approach to housing density. Density
policy is directly relevant to the HG4 allocation and to how growth should be shaped at the edge of
sensitive rural settlements within the High Weald National Landscape.
The Density Proposed for HG4 is Inconsistent with Local Character and Policy
The allocation at HG4 proposes a density of approximately 35 dwellings per hectare. This figure:
• Exceeds the highest density of any existing development in Hurst Green by approximately 46%.
The densest existing character area - Coronation Gardens - sits at 24 dph.
• Is approximately seven to eight times the density of comparable greenfield edge-of-village
development in the area, such as Burgh Hill West at 4.5 dph.
• Conflicts with the Hurst Green Design Codes, which require development density to reflect the
character of the surrounding area (Design Code policy HGNP.DC.2.5A).
• Fails to provide the sensitive, graduated transition from built form to open countryside required
by NPPF paragraph 130 and the Neighbourhood Plan.
National and local planning policy both recognise that density should be responsive to context. Higher
densities are appropriate in town and city centres with good public transport. They are not appropriate
at the rural edge of a High Weald village with over 90% car dependency, no adequate public
transport, and no safe walking or cycling routes to services.
The Density Study Should Reflect Landscape Sensitivity
HGPC requests that the updated Density Study (2026) explicitly differentiates between settlements on
the basis of their position within the settlement hierarchy, public transport accessibility, location within
the High Weald National Landscape, and the character and density of their existing built form.
For settlements within the National Landscape, the Study should set a clear upper density limit for
edge-of-settlement greenfield development that reflects the requirement to conserve landscape
character. HGPC considers that a density of 10-15 dph would be appropriate for greenfield sites at
the edge of High Weald villages, consistent with the prevailing character of comparable development
in the area.
Conclusion on Question 7
The proposed density of 35 dph at HG4 is not appropriate for an edge-of-village greenfield site within
the High Weald National Landscape. The Density Study should be revised to set differentiated limits
that reflect landscape sensitivity. Any allocation at the rural edge of a National Landscape settlement
should be required to demonstrate compliance with those limits and with the Hurst Green Design
Codes.

Question 5 - Infrastructure Needs and Priorities
Position
HGPC welcomes the opportunity to comment on infrastructure needs across the district. The Parish
Council's observations relate primarily to Northern Rother, and specifically to the infrastructure
constraints that make Hurst Green an unsuitable location for significant growth - but the issues raised
also reflect wider problems across the sub-area that the Local Plan must address.
Highway Infrastructure
The condition of the road network in Northern Rother is a serious and documented problem. The A21
and all key routes connecting the sub-area to the wider road network - including routes towards the
M25 - pass through or close to Hurst Green. The cumulative impact of the existing traffic volume,
combined with the poor structural condition of rural roads across the sub-area, makes this one of the
least well-served parts of East Sussex in terms of strategic road connectivity.
Potholed and poorly maintained roads are not merely an inconvenience - they are a direct safety risk
to all road users and represent a constraint on the viability of any significant development without prior
and substantial investment. The Local Plan must demonstrate that the infrastructure required to
support its proposed growth is deliverable and funded. In Northern Rother, that case has not been
made.
Hurst Green sits at the junction of the A21, A229, and A265. All three routes out of the village - north
and south on the A21, east on the A229, and west on the A265 - are A-roads carrying high volumes of
traffic at speeds incompatible with the absence of safe pedestrian and cycling infrastructure. This is
not a settlement that can accommodate major growth without first resolving its strategic highway
position. The Council's own Cabinet Report acknowledges that A21 improvements are currently
unfunded.
Of note, Hurst Green is one of very few settlements (and by far the largest) on the A21 that is not
bypassed. Additionally, having a primary school situated directly on the A21, and which is poorly
accessed with a narrow pavement on the western side of the A21 only, adds to the considerable road
safety and health risks the A21 represents to residents of Hurst Green. There has never been a
stronger argument for dualling this stretch of the A21 carriageway. The community’s Neighbourhood
Plan Vision states that the Parish will “seek to remove all non-local traffic from the Parish’s existing
roads, creating an environment that reduces the speed of motor traffic and encourages walking,
cycling and low carbon transport over car-use for shorter journeys.” Every additional dwelling directed
at Hurst Green without first resolving the A21 makes that vision harder to achieve, not easier.
Active Travel Infrastructure
There is no safe cycling provision anywhere in Northern and North-West Rother. The roads are too
narrow, too fast, and too heavily used by HGVs to support cycling without dedicated infrastructure.
There are no footpaths connecting settlements. Walking between villages - even short distances -
requires using A-roads with no pavements, no lighting, and no safe crossing points.
This is not a marginal concern. National planning policy (NPPF paragraph 110) requires that
development should be located and designed to give priority to pedestrian and cycle movements and
create access to high-quality walking and cycling networks. A strategy that directs major growth to
settlements where these conditions do not exist, and where there is no funded plan to create them, is
not consistent with national policy.
HGPC requests that the Infrastructure Delivery Plan sets out specific and funded proposals for active
travel improvements in the Northern Rother sub-area before the Regulation 19 stage. In the absence
of such proposals, the housing allocations directed at settlements such as Hurst Green cannot be
considered sound. This matters not only as a planning policy issue but as a fundamental community
health concern. The Neighbourhood Plan Vision commits the Parish to becoming “a thriving, safe and
friendly village within the High Weald which fosters a healthy lifestyle and encourages residents to live
active, social and meaningful lives.” An infrastructure framework that cannot provide safe routes for
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children to walk to school, or residents to cycle to a neighbour’s village, is incompatible with that
vision.
Water Supply and Drainage
Hurst Green and the surrounding area have experienced persistent and well-documented problems
with water supply. South East Water has faced significant challenges in maintaining supply reliability
across parts of East Sussex, and local residents have experienced supply interruptions and pressure
issues. These are not trivial inconveniences - they reflect structural capacity constraints that must be
resolved before additional significant housing development is appropriate.
Sewerage and drainage infrastructure in the village is similarly constrained. The surface water
flooding associated with the HG4 site - including the lake and watercourse - has not been assessed in
an appropriate Flood Risk Assessment. The allocation has been made without any demonstrated
evidence that the necessary utilities infrastructure can be delivered.
Conclusion on Question 5
The infrastructure constraints facing Hurst Green and Northern Rother are severe, documented, and
in most cases unfunded. The Local Plan must not proceed to Regulation 19 with significant growth
allocations in this sub-area until a credible, funded Infrastructure Delivery Plan is in place that
demonstrates how these constraints will be resolved. HGPC requests that the Council addresses this
before the next consultation stage.