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

Object

Representation ID: 31075

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Site‑Specific Commentary (WS2) in the SA:
For Site WS2, evidence demonstrates that development can retain woodland, avoid flood‑risk areas, provide open space, and deliver sustainable access. When assessed with mitigation applied, impacts on landscape, biodiversity and flood risk would not be significant in sustainability terms. The SA should reflect this nuance.

Object

Representation ID: 31327

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Please refer to our comments made on the Strategic Spatial Objectives contained within
our representation on the 2024 consultation. We have no specific comments to make on
the amendments made.

Object

Representation ID: 31328

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The Council’s updated housing supply identifies 8,427 homes over the 17‑year Plan period (495 homes per annum), reflecting a significant increase in draft allocations since April 2024 (from 2,129 to 5,051 homes). While this exceeds the adopted Core Strategy target (355 dpa), it falls substantially below the Government’s standard method requirement of 912 dpa (15,504 homes). All neighbouring authorities within the shared housing and functional economic market area are also underdelivering due to constraints. As a result, the Plan would underdeliver by 417 homes per year (7,077 homes), excluding a further shortfall from a 5% buffer. This poses significant soundness risks, weakens housing supply resilience, and increases reliance on speculative development unless additional sites are identified.

Please see full text in attached representations document

Object

Representation ID: 31329

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The NPPF emphasises the importance of making optimal use of land where housing shortages exist, including avoiding unnecessarily low densities. While greater efficiency is supported, this should not undermine context‑appropriate development or local market needs. The 45–60 dph range proposed in the 2024 consultation for the Live Well Locally urban edge does not align with the Density Study (2026), which recommends 35–55 dph supported by coherent neighbourhood design, varied building heights and well‑integrated parking. The 2026 consultation therefore presents three density options, with the Council’s preferred Option B adopting the 35–55 dph range. While higher densities are appropriate in some locations, policy should remain flexible to reflect site characteristics, sensitive transitions at settlement edges, and the provision of family housing.

Please see full text in representations document

Object

Representation ID: 31330

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Our client supports the overall development strategy in principle but, for the reasons set out in response to Question 2, remains concerned that it is insufficiently ambitious to deliver a positively prepared Plan. In particular, the Interim Sustainability Appraisal (January 2026) scoring the strategy ‘++’ for housing delivery appears overly generous given it would meet only 52% of identified housing need. To reduce soundness risks and support successful examination, the development strategy should be revisited to place greater emphasis on the intensification of urban areas and to expand the scope for development within the National Landscape, which is likely to be necessary to better align with the standard method. The Council should also reconsider rejected sites to assess whether conclusions are overly cautious and whether impacts could be suitably mitigated.

Please see representations document for full representation

Support

Representation ID: 31331

Received: 23/04/2026

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 the largest proportion of homes to Bexhill. This is appropriate to the
settlement’s function as the district’s largest settlement and as a regionally important town
which benefits from a wide range of services including retail, employment, medical and
educational services and three train stations providing connections to Hastings,
Eastbourne and Ashford International.

The level of growth is also supported by the delivery of the Bexhill to Hastings Link Road
which has significantly improved connectivity within the district and wider south east
region by redirecting vehicular traffic out of the town centre.

Support

Representation ID: 31332

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

We support the general aims of the Vision and development strategy for Bexhill.

Support

Representation ID: 31333

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

We strongly support the inclusion of Policy BX36 in the emerging Local Plan, reflecting planned strategic growth in North Bexhill and the delivery of a landscape‑led mixed‑use extension. The allocation provides for up to 230 dwellings across BEX0164 and BEX0163, with BEX0164 accommodating around 130 homes at a density of 35 dph, consistent with the Live Well Locally density strategy and its edge‑of‑settlement location. Development would be set within a robust landscape framework and delivered with a legible, well‑connected network of pedestrian, cycle and vehicle routes, prioritising sustainable travel. Landscape corridors, integrated drainage, play areas and open space would support habitats and protect key views. While generally supportive of Draft Policy BX36, we note that additional land to the north could be included to enable delivery of a primary school with early years provision, as referenced in our response to Question 18.

Please see attached documents for full representation.

Support

Representation ID: 31334

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

This representation is supported by an Education Technical Note (Appendix 6) assessing school place needs in the North Bexhill Growth Area, with reference to Draft Policy BX29, which identifies a requirement for a new primary school with early years provision. Concerns are raised regarding the suitability of land west of Ninfield Road, given its location on the western edge of the Growth Area. An alternative site immediately north of BX36 is promoted, benefiting from shared access and pedestrian infrastructure. The Technical Note confirms sufficient existing capacity to accommodate early housing delivery, meaning a new school is not immediately required and will depend on phasing and funding. The 2.2‑hectare site is well contained, accessible from Watermill Lane, allows flexible delivery before or after adjacent housing, and is available, viable and free from known constraints within the plan period.

Please see attached documents including Appendix 6 for full comments.

Support

Representation ID: 31335

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Policy BX29 is the general infrastructure policy for the proposed allocated sites in the North
Bexhill Growth Area. It states that new development within the North Bexhill Growth Area
will be coordinated through a master-planning approach. Proposals must appropriately
contribute to the infrastructure required to create a sustainable, “Live Well Locally”
community, to be provided in a timely manner, either by direct provision or through
financial contributions attached to the respective planning permissions.

Please see representation document for full comments.