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

Support

Representation ID: 31038

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

No specific objection to the amendments to Spatial Objective 4, which explicitly recognises the housing crisis and the need to meet the full range of housing needs. Support the acknowledgement that the Standard Method figure of 912 homes per year reflects genuine population and affordability pressures, not an arbitrary target. Suggest a minor wording to add "in full" change to clarify that fully meeting objectively assessed housing needs is a minimum requirement, in line with the NPPF. Also support Spatial Objective 7, which prioritises growth in sustainable and deliverable locations supported by appropriate infrastructure and community facilities.

Object

Representation ID: 31039

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Note that although the Draft Local Plan has significantly increased identified allocations since 2024, it still proposes only 8,427 homes (495 dwellings per annum), leaving a shortfall of 7,077 homes against the Standard Method requirement of 912 dwellings per annum. This under‑delivery exists even before considering unmet needs from neighbouring authorities within the same housing and functional economic market area, particularly Hastings. With similar shortfalls in Eastbourne, Wealden and Tunbridge Wells, the Plan risks failing the “positively prepared” test of soundness. Exceptional circumstances may justify further site allocations to meet objectively assessed need and avoid loss of planning control post‑adoption.

Support

Representation ID: 31042

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Support the principle of making efficient use of land where housing land is constrained, in line with national policy. However, density policies must remain flexible and context‑led. While Option B (“Higher Density”) is supported in principle, density targets should not be overly prescriptive and must allow site‑specific responses to landscape sensitivity, settlement edges and protected landscapes such as the High Weald. Higher densities may be appropriate in some locations, but lower densities may be necessary at rural edges to ensure a sensitive transition to the countryside. Density should relate to the developed area only, not the gross site area, to avoid unnecessary landscape harm and to align with existing allocation policies.

Support

Representation ID: 31044

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Support the Overall Development Strategy in principle, recognising that meeting housing need will require development within the High Weald National Landscape given the scale of shortfall identified. While HELAA assessment of potential sites is appropriate, further work is needed to demonstrate the exceptional circumstances and public interest required by national policy to justify such development. A dedicated topic paper should be produced to evidence this. Welcome the recognition of Battle as a key settlement linked to Hastings within a shared housing market. However, concerns remain that the strategy lacks sufficient ambition and would deliver only around half of identified housing need. To improve soundness, the strategy should place greater emphasis on urban intensification and carefully expanded opportunities within the National Landscape.

Support

Representation ID: 31045

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Notwithstanding our comments on housing need, we are supportive of the overall strategy of allocating a portion of homes to Battle. This is appropriate to the scale and location of the settlement, whilst recognising the need for sensitive development within the boundaries of the High Weald National Landscape.

Support

Representation ID: 31046

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Support the general aims of the Vision and development strategy for Battle.

Support

Representation ID: 31047

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Strongly support Policy BT10. The site is sustainable, deliverable and capable of accommodating housing adjacent to the existing settlement while respecting the High Weald National Landscape. However, the allocation boundary should be amended to follow natural field boundaries and potentially include land to the south‑west as part of a comprehensive masterplan. Technical work demonstrates capacity for at least 70–75 dwellings at 30 dph, with potential for up to 85 dwellings if additional land is included. Key principles include significant buffers to Ancient Woodland, retention of hedgerows and trees, delivery of 35% affordable housing, new open space and play facilities, sustainable drainage in line with Policy ENV2, and safe vehicular and pedestrian access from Hastings Road.

Support

Representation ID: 31048

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Draft Policy BT10 wording:
Landscape sensitivity (ii): Support the requirement but request rewording to recognise the site’s location within the High Weald National Landscape, rather than requiring enhancement where some localised impact is inevitable.
Access and movement (iii–v): Illustrative Masterplan and Transport Technical Note confirm deliverability of vehicular, pedestrian and cycle access, including a new crossing on Hastings Road and upgraded shared routes.
Green infrastructure and buffers (viii–ix): Support retention of undeveloped buffers and alignment with Natural England’s 15m guidance for Ancient Woodland.
Hedgerows and trees (vii): Request clarification allowing limited removal only where necessary to form site access.
Flood risk and SuDS (x–xi): Support requirements; achievable through layout and drainage strategy shown in the masterplan.

Object

Representation ID: 31049

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

The Interim Sustainability Appraisal provides a high‑level, “policy‑off” assessment that risks prematurely discounting suitable sites given the scale of housing need. Several scoring criteria too heavily penalise sites for constraints that can be addressed through design, such as adjacency to Ancient Woodland, surface‑water flood risk, distance from open space, and location within the High Weald National Landscape. The methodology should allow for mitigation, site‑specific context and landscape‑led design, including the ability to provide buffers, SuDS and public open space. Without refinement, the SA may undervalue deliverable sites capable of contributing positively to housing supply.

Object

Representation ID: 31050

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Key Methodology Concerns Raised

Ancient Woodland / Priority Habitat (SA 2b, 2d): Adjacent sites are automatically penalised despite potential to retain and buffer habitats in line with Natural England guidance.
Flood Risk (SA 5b): “Significant adverse” scores do not account for avoidance and drainage mitigation through detailed design.
Open Space (SA 7b): Sites capable of providing on‑site open space are still scored negatively.
National Landscape (SA 15a): All sites within the High Weald receive a “significant adverse” score without distinction between exposed and settlement‑edge locations.