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

Fairlight Parish Council - Response to Local Plan Consultation.

Q1) The overall objectives are acceptable. However, in Section 5, the proposed amount of development in the Bexhill area is excessive. It raises the question of why the Bexhill–Hastings link road is not being progressed as initially planned and discussed. Developments on the Hastings Fringe must be carefully evaluated to ensure genuine sustainability, without placing undue strain on existing road networks due to reliance on private vehicles. In Section 8, the proposed sustainable transport hierarchy is unlikely to be effective in rural areas. Achieving a truly sustainable transport model in these locations would require extensive and significant infrastructure upgrades.

Q2) The target appears reasonable when taking into account the demographic changes in Rother. However, many of the proposed sites are scattered, selective, and appear to have been chosen primarily based on availability. A significant number of these locations are not sustainable, making reliance on private motor vehicles almost inevitable.

Q3) The target seems reasonable given the demographic changes in Rother. However, many of the proposed sites are scattered and appear to have been selected mainly for their availability. Numerous locations are unsustainable, making reliance on private vehicles almost unavoidable.

Q4) Although the need is relatively small, these sites should be located closer to major link roads. It is noted that Battle currently has a cluster of sites; would it not be more appropriate to locate them along the A21, A259, or A27?

Q5) Infrastructure upgrades must correspond to the locations of major new allocations. Bexhill, Battle, and Rye, along with their proposed developments, will all require significant infrastructure improvements.

Q6) The proposed strategic gap infill between Fairlight and Hastings, and to some extent Crowhurst towards Hastings, would conflict with existing spatial policies. Unsustainable rural infill is also problematic due to insufficient infrastructure, leading to increased reliance on private vehicles to access essential amenities.

Regarding development between Hastings and Fairlight, a comprehensive assessment of flooding risks in Marsham Valley is essential. While most of the area falls within Flood Zone 1, the terrain slopes for approximately one and a half miles into areas already designated as Flood Zone 3. Any additional development within Marsham Valley would increase the risk of flooding downstream at Pett Level and beyond. Furthermore, the C92 road is already constrained by its width and steepness, and additional traffic would exacerbate existing issues, creating further detriment.

Q7) To preserve the character and appeal of Rother’s villages and rural areas, a lower allocation for villages with development boundaries would likely be more appropriate for the communities affected.

Q8) With 83% of the district falling within the High Weald National Landscape (HWNL), some development in the area is inevitable. However, it is the scale of certain proposed sites that poses a risk of harm. While it is straightforward to meet housing targets by focusing on site availability, many of the larger sites in rural, unsustainable locations are unnecessary. Greater emphasis should be placed on development in areas where sustainability objectives can be achieved and infrastructure upgrades are more cost-effective.

Q9) With such a significant increase in both housing and employment floor space in the Bexhill area, the road network will need to be addressed to accommodate this growth. There is no doubt that the link road connection to the A21 will experience a substantial increase in traffic. Rother, ESCC, and National Highways will need to address this issue. The new connecting layout has been poorly designed to manage this level of growth. The original concept for the link road included the possibility of a trunk connection to join the A21 north of Battle, which now appears to be a necessity.

Q10) The growth is substantial and requires the necessary infrastructure to be delivered without fail. Although some development in the northern area takes advantage of the link road, this could be expanded to reduce the pressure of infill in other parts of the town. There are, without doubt, significant challenges to address regarding roads and traffic around Little Common..

QA|11) The width and condition of Rock Lane and Austin Way is concerning. At present, these roads cannot accommodate the planned developments. Any building sites where surface water drains into Marsham Valley should be carefully assessed due to existing flooding issues and the harmful effects on SSSI and Ramsar sites

Q13) A disproportionate number of housing allocation for Peasmarsh considering its sewage capacity.

Q15) The objectives are reasonable. However, as has been seen in the past, farming and arable land outside development boundaries, when ‘offered up’ by landowners, has later been incorporated within development boundaries. Provided that such actions are not repeated, as they have been previously, the strategy should be effective.

Q 16) As per question 4

Site allocation response.

Fairlight Cove Policy reference: FA1

This site should be removed from the Local Plan/DASA once and for all for the following reasons.
This site has had numerous planning applications submitted for development dating back to the 1970s. All have been refused by Rother, and many have failed on appeal. The reasons for refusal have consistently related to spatial and sustainability strategies, and, most importantly, water issues, both surface and sewage, which cannot be adequately addressed.
The site is subject to groundwater flooding. Fairlight Cove suffers from unique subsurface problems caused by two main earth fault lines: the Haddocks Fault and the Fairlight Cove Reverse Fault. The Fairlight Reverse Fault crosses this site and is responsible for the majority of groundwater issues. Water from the elevated land at Fairlight Village and Hastings Country Park flows downhill to the lowest-lying land and is forced to the surface by this underground fault. Any development of any size, even with attenuation SUDS, could potentially result in land collapse. No land stability study has ever been conducted for this site, and this risk has been overlooked for years, despite the known dangers of development.
In addition to the natural fault, there are other water-related issues. The southern boundary is in Flood Zone 3 and contains a watercourse that flows through the lower part of Fairlight Cove into the Marsham Brook system. This area has flooded numerous times, and the addition of 35 dwellings would exacerbate this flooding. Furthermore, there is a Combined Sewer Overflow (CSO) on the site that currently discharges raw sewage into the watercourse around 20 times per year, contaminating watercourses all the way to SSSI and Ramsar sites. Connecting 35 dwellings would further strain the local treatment plant, which is already handling a population of approximately 700–800, well below its design capacity of 1,500. The CSO on the site is served by a 450mm sewer, while the outgoing sewer for site connection is only 175mm. Existing back pressure causes the CSO discharges, and additional housing would increase this pressure, resulting in further untreated effluent and stormwater being released. The additional flood risk and watercourse contamination are unacceptable.
The most recent planning refusal appeal was not upheld, primarily because the site had not been sequentially tested. This requirement still applies and must be met for any planning application. With 14 potential sites identified within a two-mile radius in the latest HELAA, and given the known surface water and sewage issues, this site would not qualify for an exception and would fail a sequential test.
Considering the water hierarchy, this site fails on the first three criteria: sequential testing, surface water flooding, and local sewer infrastructure. It would also likely fail on treatment plant capacity, despite Southern Water’s current statements. Recently obtained release records via a Freedom of Information request confirm that the treatment plant is operating beyond its designed capacity.
Beyond the inherent and unresolvable water issues, the site also fails on sustainability, spatial, and transport grounds. Fairlight Cove is not a service village and lacks essential amenities. The only pedestrian access to the site is via a discontinuous, unlit, and narrow footpath less than 2 metres wide. Sustainable transport cannot be achieved; private vehicles would be the only practical means to reach amenities, most of which are in Hastings. The nearest NHS provision is in Sedlescombe or Westfield. Due to its location, the site would be highly visible as a satellite development within the High Weald Landscape. The access road crosses a highway drainage SUDS network in a known flood zone and is positioned in a dangerous location with limited visibility.
This site is not viable, as evidenced by the repeated refusals of planning applications and the extensive water-related challenges. Simply being offered in a call for sites and meeting housing requirement figures does not make it a suitable or safe site for development.

Fairlight Parish Council - Response to Local Plan Consultation.

Q1) The overall objectives are acceptable. However, in Section 5, the proposed amount of development in the Bexhill area is excessive. It raises the question of why the Bexhill–Hastings link road is not being progressed as initially planned and discussed. Developments on the Hastings Fringe must be carefully evaluated to ensure genuine sustainability, without placing undue strain on existing road networks due to reliance on private vehicles. In Section 8, the proposed sustainable transport hierarchy is unlikely to be effective in rural areas. Achieving a truly sustainable transport model in these locations would require extensive and significant infrastructure upgrades.

Q2) The target appears reasonable when taking into account the demographic changes in Rother. However, many of the proposed sites are scattered, selective, and appear to have been chosen primarily based on availability. A significant number of these locations are not sustainable, making reliance on private motor vehicles almost inevitable.

Q3) The target seems reasonable given the demographic changes in Rother. However, many of the proposed sites are scattered and appear to have been selected mainly for their availability. Numerous locations are unsustainable, making reliance on private vehicles almost unavoidable.

Q4) Although the need is relatively small, these sites should be located closer to major link roads. It is noted that Battle currently has a cluster of sites; would it not be more appropriate to locate them along the A21, A259, or A27?

Q5) Infrastructure upgrades must correspond to the locations of major new allocations. Bexhill, Battle, and Rye, along with their proposed developments, will all require significant infrastructure improvements.

Q6) The proposed strategic gap infill between Fairlight and Hastings, and to some extent Crowhurst towards Hastings, would conflict with existing spatial policies. Unsustainable rural infill is also problematic due to insufficient infrastructure, leading to increased reliance on private vehicles to access essential amenities.

Regarding development between Hastings and Fairlight, a comprehensive assessment of flooding risks in Marsham Valley is essential. While most of the area falls within Flood Zone 1, the terrain slopes for approximately one and a half miles into areas already designated as Flood Zone 3. Any additional development within Marsham Valley would increase the risk of flooding downstream at Pett Level and beyond. Furthermore, the C92 road is already constrained by its width and steepness, and additional traffic would exacerbate existing issues, creating further detriment.

Q7) To preserve the character and appeal of Rother’s villages and rural areas, a lower allocation for villages with development boundaries would likely be more appropriate for the communities affected.

Q8) With 83% of the district falling within the High Weald National Landscape (HWNL), some development in the area is inevitable. However, it is the scale of certain proposed sites that poses a risk of harm. While it is straightforward to meet housing targets by focusing on site availability, many of the larger sites in rural, unsustainable locations are unnecessary. Greater emphasis should be placed on development in areas where sustainability objectives can be achieved and infrastructure upgrades are more cost-effective.

Q9) With such a significant increase in both housing and employment floor space in the Bexhill area, the road network will need to be addressed to accommodate this growth. There is no doubt that the link road connection to the A21 will experience a substantial increase in traffic. Rother, ESCC, and National Highways will need to address this issue. The new connecting layout has been poorly designed to manage this level of growth. The original concept for the link road included the possibility of a trunk connection to join the A21 north of Battle, which now appears to be a necessity.

Q10) The growth is substantial and requires the necessary infrastructure to be delivered without fail. Although some development in the northern area takes advantage of the link road, this could be expanded to reduce the pressure of infill in other parts of the town. There are, without doubt, significant challenges to address regarding roads and traffic around Little Common..

QA|11) The width and condition of Rock Lane and Austin Way is concerning. At present, these roads cannot accommodate the planned developments. Any building sites where surface water drains into Marsham Valley should be carefully assessed due to existing flooding issues and the harmful effects on SSSI and Ramsar sites

Q13) A disproportionate number of housing allocation for Peasmarsh considering its sewage capacity.

Q15) The objectives are reasonable. However, as has been seen in the past, farming and arable land outside development boundaries, when ‘offered up’ by landowners, has later been incorporated within development boundaries. Provided that such actions are not repeated, as they have been previously, the strategy should be effective.

Q 16) As per question 4

Site allocation response.

Fairlight Cove Policy reference: FA1

This site should be removed from the Local Plan/DASA once and for all for the following reasons.
This site has had numerous planning applications submitted for development dating back to the 1970s. All have been refused by Rother, and many have failed on appeal. The reasons for refusal have consistently related to spatial and sustainability strategies, and, most importantly, water issues, both surface and sewage, which cannot be adequately addressed.
The site is subject to groundwater flooding. Fairlight Cove suffers from unique subsurface problems caused by two main earth fault lines: the Haddocks Fault and the Fairlight Cove Reverse Fault. The Fairlight Reverse Fault crosses this site and is responsible for the majority of groundwater issues. Water from the elevated land at Fairlight Village and Hastings Country Park flows downhill to the lowest-lying land and is forced to the surface by this underground fault. Any development of any size, even with attenuation SUDS, could potentially result in land collapse. No land stability study has ever been conducted for this site, and this risk has been overlooked for years, despite the known dangers of development.
In addition to the natural fault, there are other water-related issues. The southern boundary is in Flood Zone 3 and contains a watercourse that flows through the lower part of Fairlight Cove into the Marsham Brook system. This area has flooded numerous times, and the addition of 35 dwellings would exacerbate this flooding. Furthermore, there is a Combined Sewer Overflow (CSO) on the site that currently discharges raw sewage into the watercourse around 20 times per year, contaminating watercourses all the way to SSSI and Ramsar sites. Connecting 35 dwellings would further strain the local treatment plant, which is already handling a population of approximately 700–800, well below its design capacity of 1,500. The CSO on the site is served by a 450mm sewer, while the outgoing sewer for site connection is only 175mm. Existing back pressure causes the CSO discharges, and additional housing would increase this pressure, resulting in further untreated effluent and stormwater being released. The additional flood risk and watercourse contamination are unacceptable.
The most recent planning refusal appeal was not upheld, primarily because the site had not been sequentially tested. This requirement still applies and must be met for any planning application. With 14 potential sites identified within a two-mile radius in the latest HELAA, and given the known surface water and sewage issues, this site would not qualify for an exception and would fail a sequential test.
Considering the water hierarchy, this site fails on the first three criteria: sequential testing, surface water flooding, and local sewer infrastructure. It would also likely fail on treatment plant capacity, despite Southern Water’s current statements. Recently obtained release records via a Freedom of Information request confirm that the treatment plant is operating beyond its designed capacity.
Beyond the inherent and unresolvable water issues, the site also fails on sustainability, spatial, and transport grounds. Fairlight Cove is not a service village and lacks essential amenities. The only pedestrian access to the site is via a discontinuous, unlit, and narrow footpath less than 2 metres wide. Sustainable transport cannot be achieved; private vehicles would be the only practical means to reach amenities, most of which are in Hastings. The nearest NHS provision is in Sedlescombe or Westfield. Due to its location, the site would be highly visible as a satellite development within the High Weald Landscape. The access road crosses a highway drainage SUDS network in a known flood zone and is positioned in a dangerous location with limited visibility.
This site is not viable, as evidenced by the repeated refusals of planning applications and the extensive water-related challenges. Simply being offered in a call for sites and meeting housing requirement figures does not make it a suitable or safe site for development.