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

Object

Representation ID: 31336

Received: 23/04/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The Interim Sustainability Appraisal (SA) provides an assessment of the proposed options
for growth, including the sites identified for allocation. The SA scores the proposed
allocations against the objectives of the emerging Local Plan, with reference to SA
indicators for more specific assessment under each objective.

We make the following general observations on the assessment methodology, where it
relates to matters that can be addressed through detailed design. 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.

Please see attached representation document for full comments.

Object

Representation ID: 31337

Received: 23/03/2026

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: 31338

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The updated housing supply identifies 8,427 homes over the 17‑year Plan period (495 homes per annum), reflecting a substantial increase in draft allocations since April 2024. While this exceeds the adopted Core Strategy target of 355 homes per year, it falls well below the standard method requirement of 912 homes per annum (15,504 homes). The Hastings & Rother HEDNA confirms Rother forms a shared housing and functional economic market area with Hastings, Wealden, Eastbourne and Tunbridge Wells, all of which are constrained and under‑delivering. Even excluding unmet needs, the Plan underdelivers by 417 homes per year, creating a shortfall of over 7,000 homes, rising further with a buffer. This presents significant soundness risks, increases exposure to a 20% buffer, and weakens the Council’s ability to resist speculative development unless additional sites are identified through allocations and the Call for Sites process.

Please see attached documents for full representation.

Object

Representation ID: 31339

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Please refer to our comments on BX39 which provide comments on the one-form entry
primary school with Early Years nursery provision required for the North Bexhill Growth
Area.

Object

Representation ID: 31340

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

The NPPF requires that where housing land is constrained, policies should avoid low densities and ensure sites make optimal use of land. While greater efficiency is supported, this should not undermine context‑appropriate development or local market demand. The 45–60 dph range proposed in the 2024 consultation for Live Well Locally areas at the Bexhill urban edge is inconsistent with the Density Study (2026), which recommends 35–55 dph. Case studies show this can be achieved through coherent neighbourhood design, balanced amenity space, distributed parking and varied building heights, with lower heights in sensitive edge locations and taller buildings focused on hubs. The 2026 consultation introduces three density options, with the Council’s preferred Option B aligning with the 35–55 dph range. Density policy should remain flexible, as a blanket approach is inappropriate for settlement edges and meeting family housing needs.

Please see attached documents for full representation

Object

Representation ID: 31341

Received: 23/03/2026

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 not sufficiently ambitious to deliver a positively prepared Plan. In particular, the Interim Sustainability Appraisal (January 2026) scores the strategy ‘++’ for housing delivery, which appears overly generous given it would provide 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 intensifying urban opportunities and expanding 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 conservative and whether impacts could be appropriately mitigated.

Please see attached documents for full comments.

Support

Representation ID: 31342

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 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: 31343

Received: 23/03/2026

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: 31344

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

We strongly support the inclusion of Policy BX39, reflecting its alignment with strategic growth in North Bexhill and its suitability for a landscape‑led mixed‑use extension to Bexhill and the Lunsford’s Cross area. The draft policy supports up to 500 dwellings, or 445 dwellings alongside a one‑form entry primary school with early years provision, together with retail, community facilities and a mobility hub. While a residential‑led mixed‑use scheme is deliverable, we have concerns regarding the appropriateness and timing of a primary school on this site. BX39’s western edge location would not meet the objective of walkable access for most pupils, and evidence shows sufficient surplus primary places to accommodate early growth. A standalone, more centrally located alternative school site is therefore preferable and available within the plan period.

Please see attached documents for full comments, including appendices.

Object

Representation ID: 31345

Received: 23/03/2026

Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited

Agent: DHA Planning

Yes. We propose an alternative site for the one‑form entry primary school with early years provision required by Policy BX29. The 2.2‑hectare site is available and deliverable within the plan period, with no known viability, legal or third‑party constraints. It comprises agricultural pastureland adjoining BX36 to the south, with established woodland and hedgerows providing strong containment. The gently rising topography allows built form to the south, visually integrated with the Growth Area, while the northern section could accommodate playing fields and sports pitches. Access could be taken from Watermill Lane via the southwest corner of BX36, avoiding the need for road widening and allowing flexible delivery before or after adjacent housing. Parking and drop‑off could be accommodated within the site. The site has been assessed against HELAA Stage 1 and 2 criteria and is supported by an indicative layout.

Please see attached documents for full text, including Appendix 4.