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

Object

Representation ID: 31262

Received: 23/03/2026

Respondent: Rubix Estates

Recognising that the Environment Act sets the 10% as a minimum and Government statements indicate that Councils can go further in local plans, this would need to be justified that there is both a need to go beyond 10% and that this requirement will not, when considered in combination with other policies impact on the deliverability of the Local Plan.
BNG is still in its infancy and as such there is great uncertainty as to the most effective way of delivering BNG, the cost of delivering 10% net gain, and whether there will be sufficient local offsite credits in the short and medium term to support schemes that cannot deliver a 10% gain on site. Generally we are supportive of achieving a 10% net gain on site and will ensure that development leaves more biodiversity than was previously the case.

Object

Representation ID: 31263

Received: 23/03/2026

Respondent: Rubix Estates

This policy is seeking to ensure that new developments are well designed, attractive and healthy places sufficient flexibility should be afforded to the densities of new development to ensure good place making. We consider that flexibility should be applied to these development densities and should be site specific rather than a blanket policy.

Object

Representation ID: 31264

Received: 23/03/2026

Respondent: Rubix Estates

The draft Local Plan states that this is a landscape-led spatial strategy that will deliver between 258 to 364 dwelling per annum (dpa) over the plan period. This is between 369 and 475 homes each year below what the minimum required by the standard method. The failure to meet needs in full also means that affordable housing delivery will be substantially below what is needed and will naturally exacerbate the housing crisis and capital values.
There are a range of constraints in Rother District such as the NL and flooding and the council must also take full account of the social and economic impacts of not meeting needs, not just the potential harms.
It will also be vital that the council seeks to maximise development on each site it does allocate given the significant shortfall between housing needs and supply. The Council should look to ensure that all land within submitted sites that are considered suitable for development are allocated for development. In our opinion several sites that have been shaded as “potentially developable” are constrained by legal issues or landowners not motivated in bringing them forward for development.
The landowners and Rubix Estates support the important role that west of Bexhill plays in the spatial strategy for the district and this land could contribute to the timely delivery of housing within the plan period.

Support

Representation ID: 31265

Received: 23/03/2026

Respondent: Rubix Estates

The current LHN for the district is also far higher than the adopted Core Strategy requirement.There can be no dispute that Rother represents an area of high housing need. Despite the above, the proposed Spatial Strategy proposes only;
“a minimum of [5,158 to 7,287] dwellings, at an average rate of [258 to 364] per year.”
The Plan seeks to deliver between a third and just below half of the level of housing need.
Only a fraction of overall affordable housing needs will be addressed through the Plan’s current proposals.
RDC does not appear to argue that exceptional circumstances exist to justify a deviation from the Standard Method and the minimum Local Housing Need figure arrived through it.
A more specific concern is that the HELAA (and, by extension, the Draft Local Plan) has taken a ‘policy-on’ approach to the evaluation of site constraints. Local, non-statutory designations should be treated differently.

Object

Representation ID: 31266

Received: 23/03/2026

Respondent: Rubix Estates

Affordability and affordable housing delivery are significant issues that the Council need to address through the new Local Plan. Increasing the delivery of affordable housing will need to be balanced against infrastructure requirements/
Recognising previous affordable housing delivery issues, it is often medium sized greenfield developments such as this site in Bexhill that are most capable of delivering affordable housing. The landowner and other sites nearby have a proven track record of providing policy compliant levels of affordable housing.
Overall, Rubix Estates and the landowners believe that Rother District Council has not yet reached a point where it can credibly claim that an appropriate balance has been reached between meeting
Rother Local Plan Regulation 18 Consultation
Land off Barnhorn Road, Little Common, TN39 4Q
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housing needs and respecting the district’s environmental characteristics and constraints. As such, the proposed approach is not currently regarded as justified or positively prepared, nor does it appropriately contribute to the achieving of sustainable development.
We look forward to onwards participation in the Local Plan consultation, and to working with officers at the appropriate time in the preparation of a planning application.