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

Support

Representation ID: 31276

Received: 23/03/2026

Respondent: Rurban Estates Limited

Rurban Estates Limited supports the allocation of Site SG2.
The site:
 Is sustainably located in relation to the existing settlement;
 Is available and deliverable in the short term;
 Will contribute positively to rural vitality, including supporting local services such as schools; and
 Is supported in principle by key consultees, including the High Weald National Landscape Unit.

The ESCC response further reinforces that:
 Growth in rural villages such as Stonegate is both necessary and beneficial, particularly in maintaining
community infrastructure.

The allocation should therefore be:
 Retained within the Local Plan, and
 Refined where necessary, rather than restricted.

The recommended modifications set out above will ensure that the policy is:
 Flexible and deliverable;
 Consistent with a landscape-led approach; and
 Capable of supporting a high-quality form of development.

Support

Representation ID: 31300

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

We have no specific comments to make on the amendments made; however, we note that
Spatial Objective 4 recognises the need to respond to the housing crisis and help facilitate
the delivery of housing to meet the needs to different groups. This will be achieved by
maximising the potential opportunities for residential development in sustainable and
deliverable locations. We strongly support this objective, and it is encouraging that the
Council specifically acknowledge the housing situation as a crisis.

Support

Representation ID: 31301

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

It is also
noted that the number of homes identified as new and updated draft allocations has
increased considerably since the April 2024 consultation, rising from 2,129 homes to 5,051
new homes. This brings the total housing figure for the Plan period accounting for all
sources of supply to 8,427 homes over the 17-year Plan period, equating to a target of
495 homes annually. we strongly support our client’s allocation, which must
form a valuable component of RDC’s deliverable supply. However, in the interests of ensuring a sound Plan, we strongly suggest that all draft allocation sites are appropriately considered and in addition, further suitable sites are sourced as part of the relaunched and ongoing ‘Call for Sites’ exercise to ensure the submission of a sound Plan.

Support

Representation ID: 31302

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

We support RDC’s approach and justification with regards to the A21 corridor and
opportunities for growth. Notwithstanding any future upgrades to the strategic road
network, it is clear that the A21 corridor is an appropriate and sustainable option for growth
as the main vehicular corridor through the district, with connections to the coastal
settlements and the national highway network (the M20 and M25) beyond Royal Tunbridge
Wells and Maidstone.
We support the inclusion of Robertsbridge as a focus area for growth within this spatial
development option.

Support

Representation ID: 31303

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

We support the proposed density for villages with development boundaries, the
policy wording should not be overly prescriptive to ensure that individual site
characteristics are appropriately considered, particularly those located in the National
Landscape. It is recognised that there will be opportunities where higher densities will be
appropriate but equally it can be necessary to incorporate lower densities at settlement
edges to provide a sensitive transition to the open countryside beyond. Further, a
prescriptive density to all sites doesn't necessarily provide an appropriate range of homes
to meet market demand, including family sized properties.

Support

Representation ID: 31304

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

Our client is supportive in principle of the overall development strategy, which recognises
the unavoidable need to utilise land within the High Weald National Landscape to deliver
the quantum of homes required across the Plan period. This is further demonstrated by
the recognised shortfall of housing land in the consultation document, even with the
identified site allocations and the potential need to accommodate some of the unmet needs
of neighbouring districts. we
would strongly suggest that the development strategy is revisited to further emphasise
the intensification of existing urban opportunities and expand the scope for development within the National Landscapes which is inevitably going to be required if RDC are to more
closely align with the standard method local housing need.

Support

Representation ID: 31305

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

We are supportive of the overall strategy of allocating a portion of homes to Northern
Rother. However, we repeat our concerns set out in response to Question 2 and Question
8 about the undersupply of housing land in the draft Local Plan and the substantial need
to reassess discounted sites and a further consideration of whether the identified
constraints can be overcome through further assessment and appropriate design.
As addressed throughout this representation, it is clear there are additional opportunities
for growth in Northern Rother, in recognition of the planned growth and the relative
sustainability of settlements in this part of the district.

Support

Representation ID: 31306

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

The consultation confirms that Robertsbridge has the highest settlement growth figure
within the Northern Rother sub-area. This reflects that fact that Robertsbridge is the
largest and most sustainable settlement within the sub-area, containing a primary and
secondary school and a train station on the Hastings to London line. The majority of
proposed residential allocations come from new sites identified through the HELAA,
although some sites form extensions to existing Neighbourhood Plan allocations.
We support the long-term ambitions for greater delivery upon completion of improvement
to the A21 corridor, however as recognised with the Local Plan, such works fall outside
either the scope or timeframe of the Local Plan.
It must therefore be ensured upon submission of the Plan that the housing allocations
proposed within this Plan period can be accommodated prior to the A21 upgrades, to
ensure much-needed housing delivery is not delayed further in rural areas.

Support

Representation ID: 31307

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

This representation seeks to promote the inclusion of land north of Knelle Road, Robertsbridge (Site Reference SAL0025 and SAL0047). A full assessment of the site is contained in Section 3 of this report, with reference to relevant technical studies and illustrative plans.
The allocation of the site would be in clear alignment with the planned pattern of
growth for Rother.
The submitted Landscape and Visual Appraisal demonstrates that landscape-led
development could be accommodated on the site without unacceptable impacts on
local landscape character and the wider High Weald National Landscape.
The site is sustainably located (as acknowledged by the SA – see response to Question
68 below) which would facilitate travel via alternative means of transport than the
private car.
There are no other identified constraints that cannot be overcome through further
assessment at application stage and sensitive design.

Object

Representation ID: 31308

Received: 23/03/2026

Respondent: Rurban Estates Limited

Agent: DHA Planning

We urge the council to
consider revising the assessment methodology to ensure that suitable sites are not
prematurely discounted given the considerable need for housing in the district.
 2b scores any site within Ancient Woodland as having a ‘significant adverse’ effect.
This disproportionately affects the assessment of sites that can suitably
accommodate the required ancient woodland buffer within a development proposal.
Similar comments can be made on 2d which refers to priority habitat.
 2c scores any site with a TPO as ‘minor negative’. The development of a site can
avoid any impacts on trees with a TPO.
 5b scores any site with land at high risk of surface water flooding as having a
‘significant adverse’ effect. As above, it is possible design around, and in many cases
improve, this risk through technical drainage design. Similar comments can be made
on 5c which refers to ground water risk.