I object to this modification because the justification provided for it is unsound and it would conflict with national legislation and other policies in the local plan.

1. Unsound justification

1.1 The justification provided for removing provision for a new passenger rail station at Glyne Gap (the location of Ravenside Retail Park) from the Rother District Local Plan (RDLP) is that the most recent analysis suggests that the scheme offers poor value for money (Executive summary, Proposed New Passenger Station at Glyne Gap, Bexhill, Final Report, August 2013 - http://www.rother.gov.uk/media.cfm?mediaid=20676). This analysis is based on the assumption that it would only be possible for one train per hour to stop at a Glyne Gap station due to operating constraints.

1.2 According to the above report, operating constraints mean that westbound trains stopping at Glyne Gap would have to be integrated into the East Coastway service (Hastings to Brighton via Eastbourne) while eastbound trains stopping at Glyne Gap would have to be integrated into the service that runs from London Victoria via East Croydon, Lewes and Eastbourne to Hastings. Operational constraints are said to include interaction with other services at Bo Peep Junction (to the east of Glyne Gap) and on the Brighton Main Line. In particular, the report claims that while the eastbound service could accommodate two trains per hour stopping at Glyne Gap, the westbound service could only accommodate one train per hour within current timetables.

1.3 By default, the above report assumes that operational constraints will not change in the future. However changes to the signalling system between Eastbourne and Bo-Peep junction are currently being implemented. The Network Rail document "Network Rail Route Specifications 2011 - Sussex" (attached - http://www.rother.gov.uk/CHttpHandler.ashx?id=20676) states on page 30 that signalling improvements between Eastbourne and Bo-peep junction are planned for 2012-13. That these improvements seem to be coming in on schedule is obvious to train travellers, who can see new signalling equipment waiting by the track. The aim of the new signalling is to improve performance and journey times. More trains will be able to run on the track between Bo Peep Junction and Eastbourne. So these improvements will make it easier to accommodate more than one train per hour on the eastbound service stopping at Glyne Gap.

1.4 With two or more trains per hour stopping at Glyne Gap value for money would markedly improve, as previous analyses have shown. These are listed in table 1.1 of the document Proposed New Passenger Station at Glyne Gap, Bexhill, Final Report, August 2013.

1. 5 Moreover it must be recognised that it is inclusion in a plan which is being considered here, not a decision whether or not to build a station. Some operational constraints are already changing, and it is quite possible that other constraints may also change in the future. Therefore the correct way for Rother District Council to treat this matter is in terms of a range of scenarios. It is already admitted that under different assumptions (that is, a different scenario) a station at Glyne Gap could be viable (para 1.4). As long as this is the case provision for this station should remain in the Rother District local plan.

2. Conflict with national legislation

2.1 Under the Climate Change Act 2008 Rother District Council has a responsibility to take action to reduce carbon dioxide emissions. Provision of a station at Glyne Gap has the potential to reduce carbon dioxide emissions by enabling people to travel by train rather than by car, and so enabling such provision by including it in the Local Plan is an action that Rother District Council ought to take.

3. Conflict with other Rother District Council policies

3.1 This modification conflicts with Rother District Council policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport, and with Rother District Council policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport'. Trains use fossil fuels more efficiently than cars, and so train travel is more sustainable than car travel. By removing provision for a station at Glyne Gap Rother District Council would be taking an action that conflicts with both these policies.