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

Dear Sir/Madam
Re: Representation to the Regulation 18 Consultation on the Rother Local Plan 2025-2042
HURST GREEN SITE ALLOCATIONS: HG1–HG4
1. Introduction
This representation is submitted in response to the Regulation 18 consultation on the emerging
Rother Local Plan, speciGically in relation to the proposed site allocations for Hurst Green (HG1–
HG4).
It is submitted on behalf of the Chair of CPRE Sussex, the Sussex branch of the Campaign to
Protect Rural England.
This response should be read alongside CPRE Sussex’s wider representation on the Local Plan. It
focuses speciGically on the proposed allocations for Hurst Green, where particular concerns arise
regarding scale, sustainability, and impact on the High Weald National Landscape.
2. Status of the Hurst Green Neighbourhood Plan [HGNP]
The HGNP:
- establishes a deGined development boundary;
- provides a clear spatial strategy for growth;
- allocates sites to meet identiGied housing need;
- has been independently examined and democratically endorsed.
In accordance with national policy, the Local Plan must have regard to the Neighbourhood Plan
and should not undermine its strategy without clear and compelling justiGication.
The proposed allocations, particularly HG3 and HG4, represent a signiGicant departure from that
strategy.
3. HG1 and HG2 – Existing Commitments
The inclusion of HG1 and HG2 is supported, as these sites beneGit from extant planning
permission and are consistent with the established development strategy for Hurst Green.
4. HG3 – Land to Rear of The Olde Bakery
The proposed allocation of HG3 is not supported due to:
- ConGlict with the Neighbourhood Plan;
- Access constraints via Pringle Close and Foundry Close;
- Surface water Glood risk;
- Landscape impact within the High Weald National Landscape.
5. HG4 – Land at The Lodge
The proposed allocation of HG4 is strongly objected to, as it does not represent genuinely
sustainable development and fails to meet the requirements for major development within a
National Landscape.
Key concerns include:
- Scale signiGicantly exceeding HGNP strategy;
- Location within the High Weald National Landscape;
- Failure to meet the major development test;
- Infrastructure and highway constraints;
- SigniGicant environmental mitigation required.
The plan does not demonstrate that less harmful or previously developed alternatives have been
exhausted before proposing development at this scale within a protected landscape.
6. BrownQield and Previously Developed Land Opportunities
There are at least two brownGield sites within Hurst Green associated with Caravan Tech:
- A larger site with workshops, storage, and sales facilities;
- A smaller storage-based site within the village.
Both lie within the development boundary and have direct A21 access.
The Plan does not demonstrate that these sites have been properly assessed or prioritised.
National policy and CPRE Sussex’s established position both emphasise the need to prioritise
previously developed land before releasing greenGield sites, particularly within protected
landscapes.
7. Community Engagement
A public consultation held on 28 February 2026 demonstrated clear and widespread opposition
to HG3 and HG4.
8. Soundness
The proposed allocations for Hurst Green raise signiGicant concerns in relation to the tests of
soundness. The Plan is not:
- Positively prepared;
- JustiGied;
- Effective;
- Consistent with national policy.
9. Conclusion
While it is recognised that Rother District Council faces signiGicant challenges in meeting
national housing requirements, this does not justify the allocation of sites that are
unsustainable, poorly evidenced, or in conGlict with the development plan.
In particular:
- HG1 and HG2 are supported as existing commitments;
- HG3 is not supported due to access, Glooding, landscape impact, and conGlict with the HGNP;
- HG4 is strongly objected to as a major greenGield allocation within the High Weald National
Landscape that is not justiGied, not demonstrated to be necessary, and not supported by
evidence of deliverability or infrastructure capacity.
The Plan should instead:
- prioritise previously developed land;
- respect the strategy established through the recently made Neighbourhood Plan;
- ensure that development is genuinely sustainable and consistent with national policy.
Without signiGicant revision, the Plan risks being found unsound.

Dear Sir/Madam
Re: Representation to the Regulation 18 Consultation on the Rother Local Plan 2025-2042
HURST GREEN SITE ALLOCATIONS: HG1–HG4
1. Introduction
This representation is submitted in response to the Regulation 18 consultation on the emerging
Rother Local Plan, speciGically in relation to the proposed site allocations for Hurst Green (HG1–
HG4).
It is submitted on behalf of the Chair of CPRE Sussex, the Sussex branch of the Campaign to
Protect Rural England.
This response should be read alongside CPRE Sussex’s wider representation on the Local Plan. It
focuses speciGically on the proposed allocations for Hurst Green, where particular concerns arise
regarding scale, sustainability, and impact on the High Weald National Landscape.
2. Status of the Hurst Green Neighbourhood Plan [HGNP]
The HGNP:
- establishes a deGined development boundary;
- provides a clear spatial strategy for growth;
- allocates sites to meet identiGied housing need;
- has been independently examined and democratically endorsed.
In accordance with national policy, the Local Plan must have regard to the Neighbourhood Plan
and should not undermine its strategy without clear and compelling justiGication.
The proposed allocations, particularly HG3 and HG4, represent a signiGicant departure from that
strategy.
3. HG1 and HG2 – Existing Commitments
The inclusion of HG1 and HG2 is supported, as these sites beneGit from extant planning
permission and are consistent with the established development strategy for Hurst Green.
4. HG3 – Land to Rear of The Olde Bakery
The proposed allocation of HG3 is not supported due to:
- ConGlict with the Neighbourhood Plan;
- Access constraints via Pringle Close and Foundry Close;
- Surface water Glood risk;
- Landscape impact within the High Weald National Landscape.
5. HG4 – Land at The Lodge
The proposed allocation of HG4 is strongly objected to, as it does not represent genuinely
sustainable development and fails to meet the requirements for major development within a
National Landscape.
Key concerns include:
- Scale signiGicantly exceeding HGNP strategy;
- Location within the High Weald National Landscape;
- Failure to meet the major development test;
- Infrastructure and highway constraints;
- SigniGicant environmental mitigation required.
The plan does not demonstrate that less harmful or previously developed alternatives have been
exhausted before proposing development at this scale within a protected landscape.
6. BrownQield and Previously Developed Land Opportunities
There are at least two brownGield sites within Hurst Green associated with Caravan Tech:
- A larger site with workshops, storage, and sales facilities;
- A smaller storage-based site within the village.
Both lie within the development boundary and have direct A21 access.
The Plan does not demonstrate that these sites have been properly assessed or prioritised.
National policy and CPRE Sussex’s established position both emphasise the need to prioritise
previously developed land before releasing greenGield sites, particularly within protected
landscapes.
7. Community Engagement
A public consultation held on 28 February 2026 demonstrated clear and widespread opposition
to HG3 and HG4.
8. Soundness
The proposed allocations for Hurst Green raise signiGicant concerns in relation to the tests of
soundness. The Plan is not:
- Positively prepared;
- JustiGied;
- Effective;
- Consistent with national policy.
9. Conclusion
While it is recognised that Rother District Council faces signiGicant challenges in meeting
national housing requirements, this does not justify the allocation of sites that are
unsustainable, poorly evidenced, or in conGlict with the development plan.
In particular:
- HG1 and HG2 are supported as existing commitments;
- HG3 is not supported due to access, Glooding, landscape impact, and conGlict with the HGNP;
- HG4 is strongly objected to as a major greenGield allocation within the High Weald National
Landscape that is not justiGied, not demonstrated to be necessary, and not supported by
evidence of deliverability or infrastructure capacity.
The Plan should instead:
- prioritise previously developed land;
- respect the strategy established through the recently made Neighbourhood Plan;
- ensure that development is genuinely sustainable and consistent with national policy.
Without signiGicant revision, the Plan risks being found unsound.