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

Support

Representation ID: 31098

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Support the preparation and use of the Interim Sustainability Appraisal and its role in testing environmental, social and economic impacts alongside the Development Strategy. The Appraisal correctly recognises the established sustainability and suitability of Land at Northeye, justifying increased capacity beyond the existing allocation.

Object

Representation ID: 31099

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

The Appraisal assesses the three parcels within draft policy BX28 collectively rather than individually, despite the HELAA identifying their distinct characteristics and delivery potential. This risks obscuring the standalone merits and early deliverability of Northeye. The Sustainability Appraisal should therefore be updated to assess each parcel separately to ensure the Plan is evidence‑based, effective and sound.

Support

Representation ID: 31100

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

To ensure the Local Plan is positively prepared and evidence‑based, the Sustainability Appraisal and Infrastructure Delivery Plan should be updated to fully reflect all supporting evidence, particularly the HELAA. While the HELAA positively identifies Land at Northeye as suitable for increased housing and questions the continued appropriateness of a sports pitch, this is not consistently reflected in the IDP or draft Policy BX28. Further evidence on sports pitch provision should be prepared before policy assumptions are made. Additionally, the HELAA should record site constraints factually rather than pre‑judging areas as unsuitable, leaving detailed assessment to the application stage to avoid prejudicing deliverability.

Support

Representation ID: 31151

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

The housing need for RDC is a minimum of 912 dwellings a year, which we recognise is a significant increase against the housing requirement in the adopted Local Plan.

In this context, Homes England recognises the constrained nature of Rother District and therefore the Council’s difficulty in meeting its full local housing needs. Given the challenges in meeting the identified housing needs, it remains vitally important that full support is given to the reuse of brownfield sites and that sustainable sites within or adjacent to rural settlements are fully utilised.

Homes England supports RDC’s approach in optimising the indicative development capacities of draft allocations, either through exploring extensions to existing allocations or through site optimisation. Hodson’s Mill is one such suitably located site where we will support the council in achieving this.

Support

Representation ID: 31152

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

Homes England support the use of an Infrastructure Delivery Plan (IDP). However, the emerging Local Plan and the supporting IDP need to ensure that the infrastructure attributed to the draft allocations is proportionate.

It is not clearly evidenced within the IDP or supporting evidence base that all development, including Hodson’s Mill, would have an impact that would need to be mitigated by infrastructure items. The wider infrastructure requirements of the district should not hinder housing delivery on sites that are unrelated.

Overall, we are supportive of contributing towards and/or delivering infrastructure improvements which are supported by evidence. Homes England recognises the IDP is a living document and will be reviewed as the emerging Local Plan and its evidence base progresses. The IDP should clarify which infrastructure requirements are to be funded by Section 106 and/or CIL.

Support

Representation ID: 31153

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Homes England supports RDC’s proposed approach to optimising density on draft site allocations, where this is achievable and appropriate. However, we are of the view that the policy wording within the Draft Local Plan should be amended regarding suitable housing densities to allow for site-specific variations.

Homes England is supportive of the RDC’s preferred approach to progress Option B. However, the policy wording in the Draft Local Plan in relation to suitable housing densities should reflect the appropriacy of variations across development sites.

To this end, while the range of densities proposed are generally supported, the Illustrative Masterplan for Hodson's Mill demonstrates that any references to densities in the draft policy or emerging allocations should remain flexible to enable site-specific characteristics to be considered, while also promoting high quality placemaking by a design-led approach, meeting local needs and ensuring deliverability and viability.

Support

Representation ID: 31155

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

Homes England supports the overarching development strategy including growth areas and specific sites of varying scales to meet RDC’s housing needs. The proposed strategy is in accordance with the NPPF which outlines the importance of bringing forward a sufficient variety of land where it is needed and addressing the needs of groups with specific housing requirements.

In terms of the growth strategy, Homes England fully support RDC’s approach to utilising sustainable rural settlements to bring forward development, if done sensitively. We understand the importance of a hierarchal approach and directing development towards the larger towns first, but it is critical that local housing needs are met in rural areas and that suitable and available sites within the most sustainable rural settlements are utilised. The proposed strategy recognises this important role, and specifically the role that Robertsbridge can play.

Support

Representation ID: 31156

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

Importantly, Figures 26 and 27 identify Robertsbridge as a ‘good sustainability’ settlement, which Homes England are fully in agreement with. The Call for Sites submission (September 2025), which is appended to these representations, provides information on the ample services (both social and infrastructure related) which contribute towards the sustainability of Robertsbridge, making it a very good rural settlement for future residential development.

Object

Representation ID: 31157

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

Homes England query the appropriateness of the identified 1,200 sqm of new employment floorspace for Robertsbridge as set out in Figure 27. As stated in paragraph 6.91 of the Draft Local Plan, this relates solely to the proposed provision within the existing and proposed draft allocation at Hodson’s Mill (RB6a). Through our comprehensive work on the planning application and completion of market testing, the delivery of 1,200 sqm commercial floorspace at this site is not feasible and we subsequently request that the proposed quantum is reduced in line with the planning application which indicates that a maximum of 150 sqm can delivered on site. Further details on this are provided in response to Question 57.

Support

Representation ID: 31158

Received: 23/03/2026

Respondent: Homes England

Agent: WSP

Please refer to the attached written representations for the full response.

Homes England welcome the latest review of the HELAA (January 2026), are broadly in agreement with the assessment outcomes and support the inclusion of both sites. In future iterations, the site should be taken forward as a single allocation reflecting the ownership and scope of the forthcoming application.

The requirement to provide 1,200sqm of commercial floorspace at the Hodson’s Mill site (RB6a) is unfeasible. The emerging planning application proposes the provision of circa 150 sqm of commercial floorspace on the ground floor of the converted Mill Building.

It must be noted that there are a number of viability considerations associated with the redevelopment of the site. It is unlikely that a policy compliant level of affordable housing will be possible.

Additional flood modelling shows there is no longer a requirement to provide an additional access to accommodate emergency vehicles.