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

Object

Representation ID: 30633

Received: 20/03/2026

Respondent: Historic England

The draft plan proposes an increase in densities for ‘Urban Areas’ in Bexhill, Battle, and Rye, moving from the previously consulted range of 60–90+ dph to a more ambitious 110–125 dph. While this uplift may be appropriate for certain contexts in Bexhill, although the Council’s evidence base should justify this, it is less clear how these higher figures would be practically delivered within Rye and Battle without potentially affecting their historic character. A point that is underlined by the Council’s own assessment of the potentially negative impacts of proposed policy approach on the historic environment in the Sustainability Appraisal. Unlike the approach taken for Bexhill, the current draft does not yet specify the precise locations where these higher density ranges would apply within the ‘Urban Areas’ of Rye or Battle. Given the high concentration of designated heritage assets in the historic cores of these towns, further clarity is needed to ensure that such densities can be reconciled with statutory duties and national policy regarding the preservation of the historic environment.

It is also worth noting that opportunities for high-density redevelopment within these historic cores appear relatively limited. It is therefore unclear what impact the proposed policy would have. Current site allocations suggest that development more frequently occurs on the fringes rather than within the historic core. The Council’s own allocations in Battle and Rye currently range from 35–65 dph; for example, Site BT11, though categorized as ‘Urban,’ is currently set at 65 dph, half the proposed density within this policy. The Former Lower School Site in Rye represents a notable exception, though its higher density is a function of its specific use as flatted accommodation for older persons, which may not be a representative model for general housing across the wider area.

Consequently, the Density Study (2026) would benefit from further demonstration of how 110–125 dph can be successfully integrated into the historic character of Battle and Rye to help justify the Council’s approach. The Rother case studies in Section 9 do not appear to show local examples exceeding 55 dph, and the contemporary best practice examples in Appendix 2 that exceed 100 dph are drawn from much larger urban centres like Newcastle and London.

For the reasons stated above, we raise concerns with the approach taken to housing density within Battle and Rye in particular.

Support

Representation ID: 30634

Received: 20/03/2026

Respondent: Historic England

Our focus for the Council’s overall development strategy is to ensure that where growth is proposed within or near historically sensitive towns, villages or assets that the Council has put in place appropriate policies to preserve the historic environment and that any opportunities to enhance heritage assets through development have been taken.

We are pleased to see the Council has integrated heritage considerations within the draft site allocations. Heritage assets that may be impacted by development sites have been identified with the allocations and suitable policy caveats have been included. Please see comments on specific site allocations below.

Object

Representation ID: 30635

Received: 20/03/2026

Respondent: Historic England

The vision is silent on the role and importance of the cultural offer centred on the Grade 1 listed De La Warr Pavillion, which is reflected in Policy BX2 but could also be incorporated into the vision for the town also.

Support

Representation ID: 30636

Received: 20/03/2026

Respondent: Historic England

We welcome the Local Plan’s vision for Battle, particularly its commitment to preserving the town’s historical character. The Council’s evidence base, including the Town Centre Study, highlights Battle’s strengths, notably its status as home to one of the nation's most significant historic sites and its connectivity via the train station. These align with the Neighbourhood Plan’s objective to enhance tourism within the parish. We believe there is an opportunity for the vision to build on these strengths. By adopting a more proactive framework to promote and protect Battle’s cultural heritage, the Vision can help to support the local economy while celebrating the town’s historic identity.

Support

Representation ID: 30637

Received: 20/03/2026

Respondent: Historic England

We support the inclusion of policy criteria that address heritage considerations. Increased development density within Bexhill Town Centre should avoid or minimise harm to the historic environment. See attachment for the wording that is suggested to be amended to better align with national policy.

Object

Representation ID: 30638

Received: 20/03/2026

Respondent: Historic England

The policy appears to suggest that the HER1 only applies within the Bexhill Town Centre Conservation Area rather than in any case where heritage assets might be affected. There are a number of listed buildings within the Bexhill Urban Area and an adjacent conservation area. We suggest the wording is amended to make this clearer.

Support

Representation ID: 30639

Received: 20/03/2026

Respondent: Historic England

We support this policy, the emphasis on reinstating historic features and the recognition of heritage assets such as the De La Warr to the cultural offer in Bexhill.

Support

Representation ID: 30640

Received: 20/03/2026

Respondent: Historic England

We support this policy. Sackville Road is a located within the Bexhill Town Centre Conservation Area and also forms part of the setting of the Grade 1 Listed De La Warr Pavillion. As such, we would welcome integration of heritage considerations into any future improvement scheme, such as:
v. Improvements preserve or enhance the character and appearance of Bexhill Town Centre Conservation Area and the setting of the Grade 1 De La Warr Pavillion.

Support

Representation ID: 30641

Received: 20/03/2026

Respondent: Historic England

We support this policy. The supporting text outlines the opportunity to enhance the setting of the Grade II listed Bexhill West Station and its role as a gateway to the wider enhancement area. This could be given greater weight by being included in the policy text. This could be done, for example, by including text such as:
Vi Take opportunities to enhance the significance of the Grade II listed Bexhill West Station.

Object

Representation ID: 30642

Received: 20/03/2026

Respondent: Historic England

Site Allocations BX22, BX27: Could be amended to preserve or enhance the significance of the listed building with the site rather than simply referring to the setting.