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

We (Southern Housing) support the objectives on the basis they’ve been amended following the previous consultation feedback. We welcome the inclusion of references to local businesses within point 6 and active travel within point 8. We also welcome the inclusion of point 11 as it ensures the plan focuses on making optimal use of land including brownfield sites, which is in accordance with both adopted and emerging national planning guidance.

While we note the constraints set out within the supporting text (e.g. 90% of the District is located within the High Weald national Landscape designation, paragraph 3.21), we believe a more proactive approach to meeting housing need could be taken. We refer to our previous response to question 76 of the previous consultation (Rother Local Plan Regulation 18 Consultation, July 2024). At the time we referred to research by the Consortium of Associations in the South East (CASE - of which Southern Housing is a member) which showed Rother could see a net undersupply of between 2,910 and 3,720 affordable homes over the next decade. This type of shortfall could deprive Rother of the development it needs and lead to further under-delivery for the next local plan period. We note that a number of sites put forward in response to the call for sites exercise have been rejected as part of the Housing and Economic Land Availability Assessment (HELAA). As some of these remain deliverable, consideration should be given to re-assessing these sites to see whether additional housing can be delivered. Meeting the District’s housing need will require a flexible approach to site allocation, tenure mix, and infrastructure planning to ensure schemes remain viable and deliverable.

Notwithstanding the above, we welcome the fact that the commitment to engage with neighbouring authorities will continue (paragraph 3.23). We also welcome the fact that the Council has considered the various options (as set out at Section 5) for the development strategy. All options need to be explored to ensure every opportunity is taken to maximise development delivery and the District benefits from the homes, services, infrastructure and employment opportunities that it needs. Please also see our response to Question 6.

Southern Housing sees the Council’s assessment of the extra Development Strategy options as sensible overall, but the final choice needs to focus on places where new homes can actually be delivered. Some options rely too much on small or highly restricted areas, which would slow delivery and make affordable housing harder to provide. Options that direct growth to better connected areas or larger sites are more realistic and give housing providers a better chance of delivering the homes the district needs.

We welcome the fact that the original 13 options have been tested through the Sustainability Appraisal (SA) process to inform the proposed strategy.

With regard to the other options considered at paragraphs 5.9-5.15, we believe it is positive the Council has assessed these, especially given the constraints facing the District (Section 4).

We note that objections were received to the A21 Corridor option, but that the Council is still considering this option further in light of the HELAA findings. We consider this to be a positive approach as it aims to resolve conflicting views whilst responding to the evidence available with the aim of meeting the District’s development needs. As stated in our response to Question 2, all options need to be considered to help ensure the delivery of an appropriate level of development.

We agree with the Council’s decision not to take forward the Strategic Gap option as a main component of the strategy. It would be contrary to the brownfield-first approach promoted in the current and emerging National Planning Policy Framework (NPPF).

While we welcome the fact that the option to review settlement boundaries remains under consideration, the approach set out at paragraph 5.14 indicates the boundaries will only be amended to take account of new site allocations. As the principle of development is broadly acceptable within the settlement boundaries, this approach is unlikely to bring forward any additional development to that already being delivered through the proposed site allocations. Once these sites are included within the development boundaries, the principle of development is likely to be acceptable regardless of the site allocations. Given the constraints set out at section 4 of the draft plan, consideration should be given to allocating sites and amending the settlement boundaries of settlements to deliver more development and help meet the needs of these local communities. While protection of the countryside is a key priority of national guidance and local policy, some growth is required at all settlements to avoid stagnation and to sustain local services. Therefore, we suggest undertaking a more detailed review of settlement boundaries, as there may be opportunities to incorporate brownfield sites on the edge of settlements and/or natural infill locations. These types of changes will help deliver more development in addition to the site allocations and therefore help meet identified needs.

We welcome the fact that the density options are based on evidence of best practice from across the District and other authority areas (paragraph 5.21) and an updated Density Study (paragraph 5.22). The preferred approach (Option B) is broadly in line with the Density Study, which indicates that “higher densities should be the starting point where design, infrastructure and site conditions allow” (Density Study, paragraph 12.1).

While the above is positive, we believe further assessments are necessary to ensure appropriate densities are achieved. There seems to be some disparity/lack of justification between the evidence and the preferred option. For example, section 11 of the Density Study recommends a density of 25-45 dph for villages. However, the supporting text (Density Study, paragraph 11.1) indicates there is a historic precedent of 25-55 dph in village centres. The draft policy states that Option B is preferred which sets a density of 25-45 dph for villages. The supporting text doesn’t appear to explain how this figure has been chosen given the evidence set out in the Density Study. Given the constraints to development across the District, further consideration should be given to increasing the density for villages to be in line with the historic precedent. A range of 25-55 dph for villages will increase the potential to deliver more development whilst maintaining the character of the area. The fact that the upper limit may be higher does not mean all developments will be appropriate, but does allow more denser development in suitable locations. This is a particularly important consideration in light of both the current and emerging NPPF, which aim to make effective use of land.

We support the overall direction of the Development Strategy but believe it should stay focused on what can realistically be delivered, with growth directed to the places that have the capacity, infrastructure and viability to support new homes, especially affordable ones.

We welcome the fact that the proposed strategy is based on elements of some of the 14 options considered. This creates a strategy that doesn’t rely on one particular option and therefore increases the chance of meeting the level of development identified as necessary by the local plan.

We note the strategy references settlements on radial routes, Hastings Fringes, sensitive development in other rural settlements and development along the A21 corridor. While we consider this generally positive for meeting need, these areas are predominantly within the High Weald National Landscape (HWNL). The supporting text at paragraphs 6.2-6.6 indicates some of the “major” site allocations may not be appropriate within the HWNL. Noting the approach to settlement boundaries (paragraph 5.14), which focuses on site allocations, if these major schemes are not taken forward, there is a risk that this strategy may not deliver the intended level of development and that it may need to be reconsidered.

Therefore, we welcome the intention to undertake further assessment of major sites in the HWNL set out at paragraph 6.6. Given the plan is already underdelivering against identified need, the Council needs to be certain that the proposed site allocations are appropriate. If following these assessments, they’re not found to be appropriate, the strategy should be amended accordingly. From a review of the HELAA, there are other sites which fall outside the HWNL which have not been taken forward and can potentially help meet identified need.

There are also other HELAA sites within the HWNL which are not being taken forward. In light of the constraint posed by the HWNL, the Council should assess whether any of these sites can be used to make up the development shortfall.

Southern Housing supports the idea of spreading growth across the sub areas. However, it’s important that the chosen locations are the ones where new homes can genuinely be delivered, with the right infrastructure and viability to support affordable housing.

As set out in our response to Question 8 above, there are a number of sites within the sub areas which have not been taken forward. As the current draft plan is falling short of meeting identified need, consideration should be given to whether any of these sites can help make up the shortfall. For example, HELAA sites located outside of the HWNL may still have potential to meet local need. While we accept these have been rejected for a number of reasons, there may be opportunities to mitigate against some of the site constraints which could be incorporated into the policy wording. For example, there are sites which have been rejected which adjoin sites taken forward which have similar constraints (for example site reference: BEX0165). This type of site should be reconsidered to help boost the supply of homes and other development to meet the District’s needs.

We support the approach to Bexhill in principle on the basis that it is the District’s main settlement and therefore one of the most sustainable locations for new development. As discussed in our response to question 11, additional sites within this area should be considered to help meet identified need.

We welcome the introduction of “Bexhill Urban Core” in principle on the basis it should allow for more dense forms of development in a sustainable location. However, the extent of the Bexhill Urban Core should be assessed and based on suitable evidence. It may be that the boundary needs to change in light of more detailed assessments.

We support the approach in principle on the basis the Council has considered the alternative locations and is prioritising the most sustainable parts of the District for development. While this is the case, we’re concerned the “major” developments within this area may not be considered appropriate (paragraphs 6.5-6.6) and require further assessments. Depending on the outcome of these assessments, the strategy may need to be reconsidered. If this is the case, consideration should be given to a greater focus on Bexhill and the immediate surrounding area falling outside of the HWNL and Battle and Rye as they are some of the largest settlements in the District. Part of the Rye area also falls outside the HWNL area and may offer greater potential for development (subject to other considerations – please also see our responses to questions 12 and 13 below). Following the ongoing assessments, the figures for this area may also need to be revised.

The second to last paragraph of the vision states that larger opportunities for development will help support existing facilities. Notwithstanding the comments above regarding further assessments, we believe this could be more positively worded to encourage major developments in the area and the benefits they can bring to communities. This may help bring forward more development in the area and help address the shortfall against identified need.

We support the approach in principle on the basis the Council has considered the alternative locations and is prioritising the most sustainable parts of the District for development. Battle is one of the District’s largest settlements and is therefore well placed to accommodate new development.

As with our response to Question 11, the end development figures should be reconsidered following the ongoing site assessments. This is to ensure a balance is struck between the impact on the HWNL and meeting the housing and other needs of communities and the District as a whole.

We support the approach in principle on the basis the Council has considered the alternative locations and is prioritising the most sustainable parts of the District for development. Rye is one of the District’s largest settlements and is therefore well placed to accommodate new development.

As with our response to Questions 11 and 12, the end development figures should be reconsidered following the ongoing site assessments. This is to ensure a balance is struck between the impact on the HWNL and meeting the housing and other needs of communities and the District as a whole. We note part of the area surrounding Rye falls outside the HWLN and therefore may have greater potential to accommodate more development. This will be dependent on other constraints, but warrants further consideration given the District is heavily constrained in a number of ways and the emphasis the Council places on the HWNL.