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

Support

Representation ID: 31059

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and 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: 31060

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and 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: 31064

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and 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: 31066

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and 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: 31067

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and 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: 31068

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

We support the overarching vision for Southern Rother and the Hastings Fringes.

Support

Representation ID: 31070

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Strongly support Policy WS2 (land east of Beaney’s Lane). The site represents a sustainable opportunity for housing delivery and should be allocated at a higher capacity than currently proposed. Evidence demonstrates a developable area of 3.42 ha with potential for around 130 homes at approximately 38 dph, compared with the draft policy’s 2.3 ha and 70 dwellings. The northern parcel is visually contained, suitable for development, and allows meaningful open space and a transition to the countryside. Impacts on Ancient Woodland and nearby SSSI can be mitigated through layout, buffering and further ecological and hydrological assessment. The allocation boundary and capacity should be revised accordingly.

Support

Representation ID: 31071

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Comments on Draft Policy WS2 Wording:
Green infrastructure (Criterion ii): Request removal of the phrase “across the northern two‑thirds of the site” to allow design flexibility while still delivering substantial open space.
Landscape sensitivity (Criterion iii): Support requirement, but request revised wording that recognises the site’s location within the High Weald National Landscape rather than requiring enhancement where localised impacts are inevitable.
Access (Criterion v): Support amendment to replace reference to “east” with “south”.
Trees and ponds (Criteria x & xi): Support retention in principle but request flexibility to allow removal where required for access or due to condition, and design‑led integration of ponds where possible, informed by ecological surveys.
Highway and land stability (Criteria xii–xiii): Support, with technical evidence to be provided at application stage.

Object

Representation ID: 31073

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The Interim Sustainability Appraisal (SA) applies a scoring methodology that risks prematurely discounting suitable sites by treating design‑responsive constraints as fixed negative impacts. Indicators relating to Ancient Woodland, priority habitat, protected trees, flood risk, groundwater risk, and National Landscape designation apply adverse scores without sufficient allowance for mitigation through layout, buffering and technical design. This approach is inconsistent with plan‑making principles where mitigation is expected to be secured via policy. The SA should distinguish between unmitigable impacts and constraints that can be addressed at application stage, particularly given the scale of housing need. Without refinement, the methodology may undervalue deliverable, sustainable sites.

Object

Representation ID: 31074

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Key Methodology Issues Identified in the SA:
Ancient Woodland & Priority Habitat (SA2b, SA2d): Automatically scored adversely despite potential to retain habitats with appropriate buffers in line with Natural England guidance.
Tree Preservation Orders (SA2c): Minor negative scores applied even where development can avoid impacts on protected trees.
Flood & Groundwater Risk (SA5b, SA5c): Significant adverse scores given without accounting for avoidance or drainage mitigation through SuDS.
National Landscape (SA15a): All sites within the High Weald scored as “significant adverse” regardless of whether impacts could be localised and sensitively managed at settlement edges.