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:
2
“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.