Full text:
Dear Planning Strategy team.
RE: Kitewood Estates Limited Response to Rother Local Plan 2025- 2042 Regulation 18: Development Strategy and Site Allocations
Kitewood Estates Limited (‘Kitewood’) welcome the opportunity to comment on the Regulation 18 Local Plan: Development Strategy and Site Allocations.
We understand that this consultation follows the first Regulation 18 consultation that was carried out in summer 2024. However, this is the first time that the proposed site allocations have been published for consultation.
As currently drafted, the Plan only seeks to meet 54% of its objectively assessed need, by planning to deliver just 495 per annum against an annual requirement of 912. This represents a significant shortfall. This shortfall is even more significant in the context of neighbouring authorities such as Lewes District, which is also only planning to meet only 54% of its housing requirement. There is therefore not only a local but a cumulative significant shortfall in the provision of housing across the wider housing market area.
In the absence of any clear or compelling evidence to demonstrate why the Council’s housing requirement cannot be met in full, it is likely that the Plan will fail to comply with the legal requirements1 in failing to satisfy the requirements of the NPPF (paras 61 & 62) in respect of housing delivery and being Positively Prepared. There is also nothing to suggest in the current consultation NPPF, that this position will change, with Local Plans still expected to be based on meeting “as a minimum” the areas identified housing need based on the Standard Method.
1 As set out in the Planning & Compulsory Purchase Act 2024 (as amended by the Localism Act 2011) and the Town and Country Planning (Local Planning) (England) Regulation 2012
7 Dacre Street, London, SW1H
0DJ t 020 7929 5911
WWW.KITEWOOD.CO.UK
Kitewood Estates Ltd. Registered Office: 7 Dacre Street, London, SW1H 0DJ Registered in England No: 02852063 Vat Reg No: 725
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Current proposed allocations must therefore be retained and additional sites identified to meet the housing need in full or compelling evidence must be prepared which demonstrates why the full housing need cannot be met. This must include testing meeting the full need in the Interim Sustainability Appraisal, which does not even include this as an option, noting all options tested fall significantly below the identified housing need.
Furthermore, there appear to be significant gaps in the evidence base at present and it is therefore difficult to comment on the proposed Plan as a whole. However, we understand that the Regulation 19 Local Plan is expected to be published for consultation in summer 2026 and we trust that relevant the evidence base documents will be available at that time, which also reflects the guidance in the consultation NPPF, which directs Plan makers “not to prepare new or additional evidence after a Plan has been submitted for examination” (Policy PM8)
At this time our comments are limited to proposed site allocation PE1: Land South of Main Street, Peasmarsh.
PE1: Land South of Main Street, Peasmarsh.
Kitewood is a privately owned development company, and we part own and part control the land located to the south of Main Street, Peasmarsh (including the dwellinghouse to be demolition to facilitate access) that is proposed for allocation under policy PE1: Land South of Main Street, Peasmarsh. A full planning application (ref: RR/2025/1499/P) was submitted in August 2025 and it is currently being determined comprising the following proposed development: Demolition of The Garden House and the erection of 70 dwellings with access taken off Main Street, together with the provision of parking, landscaping, open space and associated infrastructure
The application is supported by a full suite of technical reports which demonstrate that 70 homes can be comfortably accommodated on the Site.
Kitewood first submitted the site to the Council to be assessed as part of the HELAA process and has undertaken extensive pre-application engagement with Officers prior to the application being submitted. We therefore fully support the proposed site allocation PE1: Land South of Main Street, Peasmarsh for approximately 70 dwellings and confirm that the site is deliverable in the early years of the emerging Local Plan.
Whilst we fully support that proposed site allocation, we have the following detailed comments on the ‘Density Statistics’ table and the proposed ‘Policy Text’ that is being consulted on. The proposed changes and additions are shown in bold and underlined below.
The application site measures 3.1 ha rather than 3.2 ha currently suggested at the site size in the ‘Density Statistics’ table. There is also an inconsistency shown on the ‘Online Policy
7 Dacre Street, London, SW1H
0DJ t 020 7929 5911
WWW.KITEWOOD.CO.UK
Kitewood Estates Ltd. Registered Office: 7 Dacre Street, London, SW1H 0DJ Registered in England No: 02852063 Vat Reg No: 725
4830 33
Map’ that suggests the site size is 3.08ha. The mapping and text should therefore be revised to ensure consistency.
Development on this site should (rather than ‘must’) to provide flexibility:
1.
Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan
2.
Provide vehicular, pedestrian and cycle access from Main Street (which is likely to require demolition of a dwelling), to the satisfaction of the Highway Authority;
3.
Include reasonable and proportionate improvements to off-site highway infrastructure (and necessary financial contributions), including: a new pedestrian crossing on Main Street, a new bus stop on the westbound side of Main Street, improvements to the existing eastbound bus stop, and financial contributions towards bus services, all in accordance with the requirements of the Highway Authority;
4.
Include new pedestrian links to Jempsons and south-eastwards towards School Lane integrating (and diverting as necessary) the existing public right of way and including any necessary improvements, to the satisfaction of the Rights of Way Officer; Proposed deletion of point 4) as Jempsons is accessible via Main Street and it’s not clear why a link to School Lane would be necessary.
5.
Where feasible provide for new pedestrian and cycle links to the adjoining allocated site to the south-east (“Land at Pippins, Main Street”);
6.
Where feasible, retain and enhance the existing hedgerows/ trees on the boundaries of the site and within the site, and include an additional landscaped buffer area of Green Infrastructure in the southern part of the site and along the south-western boundary, which could also include sustainable drainage, public open space and new tree planting to screen the site in views from the south-west and protect and enhance the adjoining area of Priority Habitat (traditional orchard) to the south-east;
7.
Include an assessment and evaluation of the site’s archaeological potential and the implementation of any mitigation measures identified through the assessment. Proposed deletion of point 7) as this requirement could be secured by the validation requirements.
Kitewood agree that the site is sustainably located on the edge of the village and it is enclosed from views from the wider countryside. Whilst it falls within the National Landscape designation, there is the opportunity to incorporate a landscape buffer and seek to retain and enhance the historic field boundaries.
We look forward to the publication of the Regulation 19 Local Plan for consultation in summer 2026 and to continued engagement with Officers in relation to the proposed site allocation PE1: Land South of Main Street, Peasmarsh.
