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

8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.