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

The Parish Council is concerned that the proposed housing target of 8,427 dwellings (495 per annum) is not supported by credible delivery evidence. Historic completion rates within Rother have averaged approximately 200 dwellings per annum over a sustained period. No clear trajectory has been presented demonstrating how delivery will increase to more than double this rate.
Without such evidence, the Plan risks failing the soundness test of effectiveness (NPPF paragraph 35), as it is unlikely to be deliverable over the plan period.
Furthermore, approximately 92% of the District lies within the High Weald National Landscape (HWNL), where there is a statutory duty under Section 85 of the Countryside and Rights of Way Act 2000 to conserve and enhance landscape character. Inflated housing targets risk driving unnecessary allocations within protected landscapes.
The Parish Council recommends that the housing requirement be reassessed using a realistic delivery-based approach that properly reflects environmental constraints.

The Parish Council notes that previously allocated Traveller sites remain undeveloped, while permissions have been granted for windfall sites. This raises concerns regarding the justification for further allocations and whether the Plan meets the soundness test of being justified, namely that it is based on proportionate evidence. Allocating additional sites without understanding why existing allocations have not been delivered risks undermining confidence in the plan-led system. A criteria-based policy, allowing sites to come forward where need is demonstrated, may represent a more flexible and effective strategy.

The Infrastructure Delivery Plan (IDP) appears disproportionately focused on towns, with insufficient consideration given to rural settlements. This is particularly concerning given that a significant proportion of Community Infrastructure Levy (CIL) receipts are generated within rural communities.
Parish Councils do not appear to have been meaningfully consulted in shaping the IDP priorities, which risks:

• Misalignment between infrastructure provision and growth; In Catsfield the proposed sites have limited water supply and some have no access to sewage disposal.
• Under-investment in rural infrastructure;
• Reduced community confidence in the planning process, in particular cycling & walking, and public transport driving the development of over scale housing in village centres with no realistic access to public transport or safe cycling on rural roads.

A more balanced and consultative approach is required.

The plan defines live well locally to include sensitive development in rural settlements of the district; Over development in Catsfield which has a very high allocation compared to other villages will provide neither of the above. The proposed sites will overwhelm the village, which cannot be sensitive development. Developments of this size, on green field must have a negative impact on biodiversity, contrary to the stated aims for the local plan and be adverse to dark skies policy.

The Parish Council is concerned that the strategy relies heavily on the standard method housing figure without sufficient regard to local constraints, delivery capacity, and landscape sensitivity.

Land allocation — particularly within a National Landscape — should be supported by robust, locally specific evidence demonstrating need and deliverability. For Catsfield the allocations substantially change the landscape of the village from linear to estate configuration.

Once allocated, sites are rarely removed from the development framework. Premature allocation therefore risks long-term landscape harm without corresponding community benefit. For Catsfield the one of the new proposed sites on green fields has previously been rejected for development, and second new site will be dependent for access on site already in the local plan that has also been rejected for development. This will create a false capacity for development. Better to focus on smaller plots and affordable housing.

To be positively prepared and justified, the Plan must clearly demonstrate why this scale of growth is required locally. For Catsfield the scale of development proposed will overwhelm the village with no evidence of local need. How allocations conserve and enhance the HWNL as required by national policy. That development can realistically be delivered. Not proven for Catsfield.

The scale of growth proposed across the HWNL appears difficult to reconcile with national policy protections. The NPPF is clear that great weight should be given to conserving and enhancing landscape and scenic beauty in National Landscapes.
Given the disparity between historic delivery rates and proposed allocations, the Parish Council considers the current level of growth insufficiently evidenced and potentially inconsistent with national policy.
A landscape-led strategy should form the starting point for spatial distribution.
and distribution of growth within the High Weald National Landscape appear inconsistent with:
• The National Planning Policy Framework (NPPF);
• The statutory duty under the Countryside and Rights of Way Act 2000 (CROW Act) to conserve and enhance the landscape.
Given the clear disparity between historic build-out rates and proposed allocations, the level of growth proposed across the HWNL appears excessive and insufficiently justified.

Evidence from the adopted plan period raises serious questions regarding deliverability within Catsfield, especially given that two of the three sites allocated in the plan have failed applications and the third relies on access from one of the other two to be viable.
• 30 dwellings allocated or with planning permission
• 50 additional dwellings allocated in the local plan.

Item 6.54 in the plan states Catsfield has a good range of services including a village hall, primary school and convenience store, however its overall sustainability is constrained by a lack of employment opportunities. (it does not indicate how building new estates in a small village will create employment). The proposed sites are considered to have potential for small to medium scale development which could facilitate better public transport accessibility and active travel accessibility through the settlement to the primary school. This is false. New residents in new dwellings will use cars as their primary method of transport. Buses are infrequent and only run in the day time. Residents need access to a variety of services (Groceries, Trains, Health, restaurants, and entertainment) which buses cannot provide adequate access to. Some new residents may walk young children to the primary school but most will not have children and have no need to walk to the school, which is already oversubscribed. This is not a valid policy or driver for the allocation of houses in the centre of the village. The Parish Council recommends that allocations be revisited in light of demonstrable delivery constraints, realistic transport/walking/cycling potential and landscape impact.

The countryside strategy should prioritise landscape protection, delivery realism, and policy consistency.
The continued allocation of sites, including Traveller sites, without evidence of delivery risks creating long-term planning blight rather than supporting sustainable rural communities.
A more proportionate approach would focus on:
• Protecting landscape character
• Supporting organic, needs-led growth
• Ensuring allocations are genuinely deliverable

Do you have any comments on the proposed site allocations in Catsfield, detailed in Policies CT1 to CT3?

CT1. This site has had a planning application rejected, 0.8 of 1.66 Hectares for development. 30 dwellings
• Access is close to a zebra crossing and junction with a poor safety record. (for access to 30 dwellings in CT1 and 20 from CT2)
• Infrastructure insufficient with no access to sewers and a water supply not secured.
• Site flood regularly with run off requiring huge rainwater tanks.

Do you have any comments on the proposed site allocations in Catsfield, detailed in Policies CT1 to CT3?

CT2
This a new site, with no access from the highway. It requires CT1 to be built first. 0.6 from 1.23 hectares for development. 20 dwellings.
The proposed access is via narrow public right of way used by walkers, horse riders and some rural residents. This access is unsuitable for a development of 20 houses.
This site should not be included in the plan. It is not deliverable.