2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

Draft Rother Local Plan (Regulation 18) - National Highways' response

Thank you for your email of 26 January 2026 consulting National Highways on the draft Rother Local Plan 2025-2042 - Development Strategy and Site Allocations (the draft Plan).

We are concerned about the safety, reliability, and operational efficiency of the Strategic Road Network (SRN). In the case of Rother district, the SRN comprises the A259 and the A21.

We have read the consultation document and understand that the focus is on the proposed site allocations. We have also read the Local Development Scheme (LDS) (March 2025) which maps out the timetable for the production of the Local Plan.

We have set out below our comments.

SRN policy context - vision-led approach:
We would like to draw your attention to the Department for Transport (DfT) Circular 01/2022: Strategic road network and the delivery of sustainable development (December 2022) which represents the government's policy for the SRN.

Plan-making needs to respond to the expectations of this policy including a vision-led approach to development. The objective of vision-led development is to manage down traffic impacts by maximising opportunities for sustainable travel and by internalising movements as far as possible through layout and design. There is also a specific section in the Circular on 'Engagement with plan-making'.

The vision-led approach to development now features in the updated National Planning Policy Framework (NPPF) (December 2024) - please see section 9. The updated NPPF also includes a requirement for Local Plans to look ahead over a minimum 15-year period from adoption. It is important to highlight this at this early stage because the time horizon for the Local Plan is relevant to the evidence that needs to be prepared to inform plan-making.

A key part of the vision-led approach, where appropriate, is monitor and manage. This is an important strategy for overseeing the appropriateness and phasing of identified highway mitigation to support the delivery of large developments. This would need to be informed by an Infrastructure Delivery Plan that should be kept live by regular monitoring during the implementation of the development strategy for the Local Plan.

We are happy to work with you on the development of appropriate policies that address the vision-led approach and monitor and manage.

Rother Local Plan 2025-2042 - Development Strategy and Site Allocations Draft (Regulation 18) Version, January 2026:
The draft Local Plan sets out proposed site allocations across the district along with some area specific policies.

We understand that 'Additional technical evidence will be prepared to ensure the potential impacts (including cumulative impacts) of the level of growth planned in Rother is appropriately considered, as well as to ensure new development is suitably located and can be adequately supported by infrastructure, and is viable, in line with national policy and guidance.'

We would encourage Rother District Council (RDC) to continue to engage with us in respect of the transport modelling and assessments in order to ensure that the approach is consistent with the guidance set out in DfT Circular 01/2022.

Furthermore, we suggest that the Local Plan considers cumulative impacts of development in neighbouring authorities. This is in line with DfT Circular 01/2022 paragraph 29 and the NPPF on strategic cross-boundary matters.

Infrastructure Needs:
We note that an updated Draft Infrastructure Delivery Plan (IDP) has been prepared in support of this Regulation 18 consultation and our comments on this document are detailed within a later section of this letter.

However, it is also important to note that we understand the draft IDP will require further revisions once the updated strategic transport modelling using the countywide model is complete. As such, the infrastructure needed to support the delivery of the Local Plan cannot be fully identified until this work is complete.

Development Strategy:
We note that following the first Regulation 18 consultation, several additional options for the development strategy have been identified, these included the 'A21 Corridor Option'.

We note that this option would have the most direct implications for the SRN. This option provides for development along the A21 trunk road within an identified corridor of settlements, together with a sustainable transport corridor (including improved sustainable travel options such as bus routes, cycling and walking infrastructure).

We would highlight that any proposed changes/improvements to any part of the SRN will require consultation with and approval from us.

Furthermore, the full impact of this option is required to be assessed as part of the updated modelling, to be undertaken in compliance with the guidance set out in DfT Circular 01/2022.

We strongly advise that RDC continue to engage with us regarding the updated modelling and preparation of the associated transport evidence base documents to ensure that any potential impacts on the SRN are appropriately assessed.

Development Strategy for Rother:
It is noted that Bexhill will be the key focus for sustainable residential and commercial growth with potential to deliver circa 4,764 dwellings and 54,672 sqm. of employment.

It is evident that the proposed development strategy will place additional strain on the SRN in this area and this will need to be fully assessed through the updated modelling work being undertaken to support the draft Local Plan.

RDC must consider Circular 01/2022 paragraph 29:
"there cannot be any presumption that such infrastructure will be funded through a future RIS [Road Investment Strategy]. The company will therefore work with local authorities in their strategic policy-making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy."

The draft Local Plan notes there are 'opportunities for sensitive development in the sub-area during the timeframe of the Local Plan, where sustainable and related to an existing settlement, including those alongside the A21. Longer term (beyond the timeframe of the new Local Plan), the delivery of significant improvements to create a sustainable transport corridor could open up opportunities for future development along the A21 corridor, which could be addressed in a plan review.'

RDC states that there is potential to deliver 996 dwellings and 4,350 sqm of employment floorspace across the Northern Rother sub-area.

Paragraph 6.85 of the draft Local Plan states:

'The A21 provides road connections between the villages north and south. In the long- term, the A21 could become a sustainable travel corridor with buses given priority, linked to walking, cycling and wheeling routes. The Transport for the South-East (TfSE) Strategic Investment Plan identifies bypasses on the A21 at Flimwell and Hurst Green as necessary transport interventions to decarbonise transport in the south-east by 2050. However, these are not currently funded and there is a lack of evidence they will come forward at any point, including during the timescale of the Local Plan.'

Introducing a sustainable travel corridor along the A21 aligns with DfT Circular 01/2022 policy by encouraging walking, wheeling, cycling and public transport use as the natural first choice. However, we would again reiterate that the need for any SRN mitigation must be considered after all options have been assessed to maximise the accessibility by sustainable transport modes. There cannot be any presumption that SRN-related infrastructure to mitigate Local Plan impacts will be funded through a future government's Road Investment Strategy (RIS). Funding and delivery of necessary SRN infrastructure to support planned growth is a matter for the Local Planning Authority (LPA) to lead on through the Local Plan process.

Furthermore, it is also important to note that while RIS3 has yet to be published, the interim statement (2025/2026) highlights that RIS3 will be focused on maintenance and renewal (para.4.3):

'While RIS3 has yet to be agreed, it is likely that investment will be increasingly focussed on maintaining and renewing the existing Strategic Road Network, including replacing and renewing major bridges, viaducts and other structures.'

Site Allocations:
We note that there are circa 162 site allocation policies (some are area specific and can also encompass more than one site).

Our review has sought to identify immediately apparent site-specific matters of interest to us, which are:
- Sites which would require a new access onto the SRN (this includes sites that do not abut the SRN but would require a new access onto the SRN as part of their wider transport strategy)
- Sites which propose to use an existing SRN access Sites which abut the SRN but would take access onto the Local Road Network
- Sites located near the SRN.

Sites requiring a new access onto SRN All sites seeking a new access onto the SRN must demonstrate evidence of: Policy compliance regarding new accesses on the SRN as per DfT Circular 01/2022, in particular paragraphs 18 to 25 Design Manual for Roads and Bridges (DMRB) compliance and Stage 1 Road Safety Audit (RSA), Walking, Cycling and Horse-riding Assessment and Review (WCHAR) etc.

In relation to policy compliance, we would highlight paragraph 19 of the Circular (our emphasis):

"19. On this basis the principle of creating new connections on the SRN should be identified at the plan-making stage in circumstances where an assessment of the potential impacts on the SRN can be considered alongside whether such new infrastructure is essential for the delivery of strategic growth. Moreover, the company will need to be satisfied that all reasonable options to deliver modal shift, promote walking, wheeling and cycling, public transport and shared travel to assist in reducing car dependency, and locate development in areas of high accessibility by sustainable transport modes (or areas that can be made more accessible) have been exhausted before considering options for new connections to the SRN. There may also be limited opportunity for new connections to be considered as part of public funding programmes to support new development, although necessary infrastructure in up- to-date plans and strategies should be favoured in such instances."

We would therefore expect an appropriate assessment to be undertaken and included - either within the Local Plan transport evidence or as part of the explanation of the development strategy - demonstrating how this has been addressed through plan-making by RDC. It may be the case that it can be drawn from other existing sources that form part of the Local Plan evidence base.

It is important that RDC demonstrates that they have followed this process as any new connections on the SRN can create additional risk to safety and reduce the reliability and efficiency of journeys.

In respect of these sites, it is also strongly advised that individual site-specific advice be sought from us as soon as possible.

Sites proposing to utilise an existing SRN access:
All sites which propose to utilise an existing SRN access will need to fully assess any impacts arising from the proposed development traffic.

It is important to note that we would not support the intensification of use of an existing SRN access where there would be a detrimental impact on safety.

Any proposed upgrade/improvement of an existing SRN access would need to be fully assessed in line with the relevant guidance set out in DfT Circular 01/2022 and DMRB.

For all sites where SRN access is critical to the deliverability of the development, the required assessments should be undertaken as soon as possible, in advance of the Regulation 19 submission.

Sites which abut the SRN:
All sites which abut the SRN will need to consider any boundary issues, eg drainage, lighting, geotechnical, boundary treatments, in consultation with us.

Sites near the SRN:
For sites located near to the SRN, it will be particularly important that they are supported by an appropriate Transport Assessment at the planning application stage and are advised to seek early engagement with us at the pre-application stage. However, this does not preclude the need for Transport Assessments for sites which are located further away which are of a development quantum which could have a material traffic impact on the SRN.

We note that the cumulative traffic impact of all proposed site allocations is to be assessed as part of the updated modelling based on the East Sussex Countywide model.

Evidence-base: Strategic transport modelling It is important that plan-making is informed by proportionate up-to-date evidence.

In respect of transport, we expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Rother District, with our focus being on the SRN. We note that the transport evidence which has been published as part of the
current consultation dates from 2023 and therefore is not able to specifically consider the impacts of the specific sites identified in the main Regulation 18 consultation document.

We understand that the intention is to utilise the East Sussex Countywide Transport Model (ESCWTM/ 'countywide model') in advance of subsequent consultation stages to 'underpin and develop a detailed Shared Transport Evidence Base'.

This needs to set out current and future baseline (end of plan period + extant permissions) information on the performance of junctions across the highway networks. We understand that this will be informed by updated transport modelling using the Countywide strategic model.

Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the site selection process and needs to be produced in advance of the detailed Regulation 19 Local Plan to inform its preparation.

We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues at East Sussex County Council who are responsible for the Local Road Network (LRN).

Once established, the strategic transport model can then be used to test development strategy options being considered by the council for the Local Plan.

Evidence base: Infrastructure Delivery Plan (IDP) January 2026. The IDP is a useful piece of evidence to identify what, where and when in terms of the infrastructure needed to support the development strategy in the Local Plan. It can identify schemes, estimated costs, and when the mitigation will be phased alongside the build-out of the development strategy.

We have reviewed the IDP Part A and Part B (The Schedule) and would note the following points:

Strategic Corridor Improvements The A21 and A259 corridors have been identified as requiring capacity management and selective enhancements to accommodate forecast growth. The IDP confirms that any improvements along this corridor should be aligned with National Highways' RIS3 (2026 - 2031), and the LTP4 Investment Plan priorities. We would note that RIS3 is yet to be published, however, the outlined approach would be acceptable in principle. It is important to appreciate that the focus of RIS3 will be on maintenance and renewal; there is uncertainty about the future of RIS3 pipeline projects identified in RIS2. The current position on the A21 Safety Package scheme is available from our website: https://nationalhighways.co.uk/our-roads/south-east/a21-safety-package/

Integration with multi-modal travel: We welcome the statement in Paragraph 3.40 of the IDP which outlines that road interventions must support sustainable travel choices, with new and upgraded infrastructure planning alongside priority measures, cycle lanes, and pedestrian infrastructure. Such improvements should be designed in accordance with appropriate DMRB standards with any proposals submitted to us for approval.

Phased delivery and prioritisation: We agree that road network improvements should be phased in line with housing and employment delivery to ensure new capacity and infrastructure is in place at the right time as development comes forward.

Financial & delivery requirements: It should be noted that any improvement schemes on the SRN would be expected to be delivered via a s.278 (Highways Act 1980) agreement between the developer and National Highways. We do not accept developer contributions, with priorities for the SRN set in the government's RIS.

It is also important to note that RIS3 has yet to be published and as such there should be no reliance on any schemes that may be included within it. As highlighted above, there is uncertainty about RIS3 pipeline projects identified in RIS2.

We would also highlight paragraph 29 of DfT Circular 01/2022 (our emphasis):

'New connections and capacity enhancements to the SRN which are necessary to deliver strategic growth should be identified as part of the plan-making process, as this provides the best opportunity to consider the cumulative impacts of development (including planned growth in adjoining authorities) and to identify appropriate mechanisms for the delivery of strategic highway infrastructure. However, there cannot be any presumption that such infrastructure will be funded through a future RIS. The company will therefore work with local authorities in their strategic policy- making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy.'

We welcome the reference to the 'vision and validate' approach (also known as 'monitor and manage') in Paragraph 10.9 of the IDP.

We consider that it could be beneficial to discuss the suitability of a 'Monitor and Manage' approach for individual proposed developments on a case-by-case basis at the appropriate time during the planning process, as part of a collaborative approach involving us, the LPA, developers and ESCC.

The IDP Part B (the Schedule) lists a number of schemes which directly impact the SRN.

We note that we have been identified as a 'Delivery Partner' for some of these schemes. As previously noted, Paragraph 10.21 of the IDP states that a 'Delivery Partner' is defined as: 'any strategic stakeholder (public or private) involved in the planning, design, technical approval, or funding of infrastructure; they are not necessarily the body that directly delivers the infrastructure itself.'

Based on RDC's definition, we would be a 'Delivery Partner' for all schemes on the SRN as technical approval from us would be required. Any proposed changes to the layout or operation of the SRN will need to be approved by us, with the changes designed in accordance with appropriate DMRB standards and assessed in compliance with DfT Circular 01/2022.

For the avoidance of doubt, unless otherwise specified by us, any identified SRN schemes necessary to support planned growth will not be funded or delivered by National Highways.

With regard to the Schedule itself, it would be useful to have additional information presented in relation to the presented schemes, where applicable, particularly for those classified as critical or essential:

Scheme drawing number reference LPA planning application reference(s) if scheme is linked/conditioned to development(s) Any identified trigger points (development thresholds) at which scheme is required.

We have not undertaken a detailed review of all SRN schemes included within the Schedule as we understand that the transport modelling evidence for the draft Local Plan, based on the latest site allocations, may result in changes to infrastructure requirements. As such, we anticipate that there will need to be a further update to the IDP once the modelling is completed. We have no further comments at this stage.

National Highways will need to participate in discussions involving East Sussex County Council (ESCC) and RDC, to ensure that the agreed modelling scope, specifications, and assumptions are appropriate and proportionate to the needs of the emerging Local Plan.

The IDP is a useful piece of evidence for documenting the outputs from the monitor and manage strategy which needs to form part of the implementation of the Plan. It would benefit from a chart plotting the phasing of essential transport infrastructure alongside the build-out of the development strategy to ensure identified mitigation is delivered at the right time in the development cycle. We are happy to be engaged with the development of further updates to the IDP and the monitor and manage strategy.

Expectation management: We must be clear that the funding and delivery of mitigation to the SRN that is necessary to support the development strategy in the Local Plan are matters for the LPA to decide and manage through the Local Plan process, including during its implementation.

Priorities for investment in the SRN are set in the government's Road Investment Strategy (RIS). There cannot be a presumption that improvements to the SRN necessary to support planned growth in the Local Plan will be funded and supported through a future RIS. RIS3 (2026-2031) will be focused on maintenance and renewal.

We are happy to be engaged in the process of assessing proposed mitigation, e.g. safety and design standards, but will not be responsible for funding or delivery.

Keep informed: We hope these comments are clear and helpful. We are happy to work with Rother District Council on an on-going basis as the Local Plan, including the evidence base, progresses.

Please keep us informed about the development of transport related evidence and the next stage of the Draft Rother Local Plan.

We would also like to share with you our 'Planning for the future - A guide to working with National Highways on planning matters' (October 2023), which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.

We have also prepared a short explainer video outlining how we engage with planning. This video is available from our website under the heading 'Our support for plan-making and decision-taking': https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road- network-in-england/. In addition, we have prepared a Local Plan brochure outlining how we engage with plan-making which is available from the same section of our website.

Should you or any others have any queries regarding our response, please contact us.

Draft Rother Local Plan (Regulation 18) - National Highways' response

Thank you for your email of 26 January 2026 consulting National Highways on the draft Rother Local Plan 2025-2042 - Development Strategy and Site Allocations (the draft Plan).

We are concerned about the safety, reliability, and operational efficiency of the Strategic Road Network (SRN). In the case of Rother district, the SRN comprises the A259 and the A21.

We have read the consultation document and understand that the focus is on the proposed site allocations. We have also read the Local Development Scheme (LDS) (March 2025) which maps out the timetable for the production of the Local Plan.

We have set out below our comments.

SRN policy context - vision-led approach:
We would like to draw your attention to the Department for Transport (DfT) Circular 01/2022: Strategic road network and the delivery of sustainable development (December 2022) which represents the government's policy for the SRN.

Plan-making needs to respond to the expectations of this policy including a vision-led approach to development. The objective of vision-led development is to manage down traffic impacts by maximising opportunities for sustainable travel and by internalising movements as far as possible through layout and design. There is also a specific section in the Circular on 'Engagement with plan-making'.

The vision-led approach to development now features in the updated National Planning Policy Framework (NPPF) (December 2024) - please see section 9. The updated NPPF also includes a requirement for Local Plans to look ahead over a minimum 15-year period from adoption. It is important to highlight this at this early stage because the time horizon for the Local Plan is relevant to the evidence that needs to be prepared to inform plan-making.

A key part of the vision-led approach, where appropriate, is monitor and manage. This is an important strategy for overseeing the appropriateness and phasing of identified highway mitigation to support the delivery of large developments. This would need to be informed by an Infrastructure Delivery Plan that should be kept live by regular monitoring during the implementation of the development strategy for the Local Plan.

We are happy to work with you on the development of appropriate policies that address the vision-led approach and monitor and manage.

Rother Local Plan 2025-2042 - Development Strategy and Site Allocations Draft (Regulation 18) Version, January 2026:
The draft Local Plan sets out proposed site allocations across the district along with some area specific policies.

We understand that 'Additional technical evidence will be prepared to ensure the potential impacts (including cumulative impacts) of the level of growth planned in Rother is appropriately considered, as well as to ensure new development is suitably located and can be adequately supported by infrastructure, and is viable, in line with national policy and guidance.'

We would encourage Rother District Council (RDC) to continue to engage with us in respect of the transport modelling and assessments in order to ensure that the approach is consistent with the guidance set out in DfT Circular 01/2022.

Furthermore, we suggest that the Local Plan considers cumulative impacts of development in neighbouring authorities. This is in line with DfT Circular 01/2022 paragraph 29 and the NPPF on strategic cross-boundary matters.

Infrastructure Needs:
We note that an updated Draft Infrastructure Delivery Plan (IDP) has been prepared in support of this Regulation 18 consultation and our comments on this document are detailed within a later section of this letter.

However, it is also important to note that we understand the draft IDP will require further revisions once the updated strategic transport modelling using the countywide model is complete. As such, the infrastructure needed to support the delivery of the Local Plan cannot be fully identified until this work is complete.

Development Strategy:
We note that following the first Regulation 18 consultation, several additional options for the development strategy have been identified, these included the 'A21 Corridor Option'.

We note that this option would have the most direct implications for the SRN. This option provides for development along the A21 trunk road within an identified corridor of settlements, together with a sustainable transport corridor (including improved sustainable travel options such as bus routes, cycling and walking infrastructure).

We would highlight that any proposed changes/improvements to any part of the SRN will require consultation with and approval from us.

Furthermore, the full impact of this option is required to be assessed as part of the updated modelling, to be undertaken in compliance with the guidance set out in DfT Circular 01/2022.

We strongly advise that RDC continue to engage with us regarding the updated modelling and preparation of the associated transport evidence base documents to ensure that any potential impacts on the SRN are appropriately assessed.

Development Strategy for Rother:
It is noted that Bexhill will be the key focus for sustainable residential and commercial growth with potential to deliver circa 4,764 dwellings and 54,672 sqm. of employment.

It is evident that the proposed development strategy will place additional strain on the SRN in this area and this will need to be fully assessed through the updated modelling work being undertaken to support the draft Local Plan.

RDC must consider Circular 01/2022 paragraph 29:
"there cannot be any presumption that such infrastructure will be funded through a future RIS [Road Investment Strategy]. The company will therefore work with local authorities in their strategic policy-making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy."

The draft Local Plan notes there are 'opportunities for sensitive development in the sub-area during the timeframe of the Local Plan, where sustainable and related to an existing settlement, including those alongside the A21. Longer term (beyond the timeframe of the new Local Plan), the delivery of significant improvements to create a sustainable transport corridor could open up opportunities for future development along the A21 corridor, which could be addressed in a plan review.'

RDC states that there is potential to deliver 996 dwellings and 4,350 sqm of employment floorspace across the Northern Rother sub-area.

Paragraph 6.85 of the draft Local Plan states:

'The A21 provides road connections between the villages north and south. In the long- term, the A21 could become a sustainable travel corridor with buses given priority, linked to walking, cycling and wheeling routes. The Transport for the South-East (TfSE) Strategic Investment Plan identifies bypasses on the A21 at Flimwell and Hurst Green as necessary transport interventions to decarbonise transport in the south-east by 2050. However, these are not currently funded and there is a lack of evidence they will come forward at any point, including during the timescale of the Local Plan.'

Introducing a sustainable travel corridor along the A21 aligns with DfT Circular 01/2022 policy by encouraging walking, wheeling, cycling and public transport use as the natural first choice. However, we would again reiterate that the need for any SRN mitigation must be considered after all options have been assessed to maximise the accessibility by sustainable transport modes. There cannot be any presumption that SRN-related infrastructure to mitigate Local Plan impacts will be funded through a future government's Road Investment Strategy (RIS). Funding and delivery of necessary SRN infrastructure to support planned growth is a matter for the Local Planning Authority (LPA) to lead on through the Local Plan process.

Furthermore, it is also important to note that while RIS3 has yet to be published, the interim statement (2025/2026) highlights that RIS3 will be focused on maintenance and renewal (para.4.3):

'While RIS3 has yet to be agreed, it is likely that investment will be increasingly focussed on maintaining and renewing the existing Strategic Road Network, including replacing and renewing major bridges, viaducts and other structures.'

Site Allocations:
We note that there are circa 162 site allocation policies (some are area specific and can also encompass more than one site).

Our review has sought to identify immediately apparent site-specific matters of interest to us, which are:
- Sites which would require a new access onto the SRN (this includes sites that do not abut the SRN but would require a new access onto the SRN as part of their wider transport strategy)
- Sites which propose to use an existing SRN access Sites which abut the SRN but would take access onto the Local Road Network
- Sites located near the SRN.

Sites requiring a new access onto SRN All sites seeking a new access onto the SRN must demonstrate evidence of: Policy compliance regarding new accesses on the SRN as per DfT Circular 01/2022, in particular paragraphs 18 to 25 Design Manual for Roads and Bridges (DMRB) compliance and Stage 1 Road Safety Audit (RSA), Walking, Cycling and Horse-riding Assessment and Review (WCHAR) etc.

In relation to policy compliance, we would highlight paragraph 19 of the Circular (our emphasis):

"19. On this basis the principle of creating new connections on the SRN should be identified at the plan-making stage in circumstances where an assessment of the potential impacts on the SRN can be considered alongside whether such new infrastructure is essential for the delivery of strategic growth. Moreover, the company will need to be satisfied that all reasonable options to deliver modal shift, promote walking, wheeling and cycling, public transport and shared travel to assist in reducing car dependency, and locate development in areas of high accessibility by sustainable transport modes (or areas that can be made more accessible) have been exhausted before considering options for new connections to the SRN. There may also be limited opportunity for new connections to be considered as part of public funding programmes to support new development, although necessary infrastructure in up- to-date plans and strategies should be favoured in such instances."

We would therefore expect an appropriate assessment to be undertaken and included - either within the Local Plan transport evidence or as part of the explanation of the development strategy - demonstrating how this has been addressed through plan-making by RDC. It may be the case that it can be drawn from other existing sources that form part of the Local Plan evidence base.

It is important that RDC demonstrates that they have followed this process as any new connections on the SRN can create additional risk to safety and reduce the reliability and efficiency of journeys.

In respect of these sites, it is also strongly advised that individual site-specific advice be sought from us as soon as possible.

Sites proposing to utilise an existing SRN access:
All sites which propose to utilise an existing SRN access will need to fully assess any impacts arising from the proposed development traffic.

It is important to note that we would not support the intensification of use of an existing SRN access where there would be a detrimental impact on safety.

Any proposed upgrade/improvement of an existing SRN access would need to be fully assessed in line with the relevant guidance set out in DfT Circular 01/2022 and DMRB.

For all sites where SRN access is critical to the deliverability of the development, the required assessments should be undertaken as soon as possible, in advance of the Regulation 19 submission.

Sites which abut the SRN:
All sites which abut the SRN will need to consider any boundary issues, eg drainage, lighting, geotechnical, boundary treatments, in consultation with us.

Sites near the SRN:
For sites located near to the SRN, it will be particularly important that they are supported by an appropriate Transport Assessment at the planning application stage and are advised to seek early engagement with us at the pre-application stage. However, this does not preclude the need for Transport Assessments for sites which are located further away which are of a development quantum which could have a material traffic impact on the SRN.

We note that the cumulative traffic impact of all proposed site allocations is to be assessed as part of the updated modelling based on the East Sussex Countywide model.

Evidence-base: Strategic transport modelling It is important that plan-making is informed by proportionate up-to-date evidence.

In respect of transport, we expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Rother District, with our focus being on the SRN. We note that the transport evidence which has been published as part of the
current consultation dates from 2023 and therefore is not able to specifically consider the impacts of the specific sites identified in the main Regulation 18 consultation document.

We understand that the intention is to utilise the East Sussex Countywide Transport Model (ESCWTM/ 'countywide model') in advance of subsequent consultation stages to 'underpin and develop a detailed Shared Transport Evidence Base'.

This needs to set out current and future baseline (end of plan period + extant permissions) information on the performance of junctions across the highway networks. We understand that this will be informed by updated transport modelling using the Countywide strategic model.

Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the site selection process and needs to be produced in advance of the detailed Regulation 19 Local Plan to inform its preparation.

We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues at East Sussex County Council who are responsible for the Local Road Network (LRN).

Once established, the strategic transport model can then be used to test development strategy options being considered by the council for the Local Plan.

Evidence base: Infrastructure Delivery Plan (IDP) January 2026. The IDP is a useful piece of evidence to identify what, where and when in terms of the infrastructure needed to support the development strategy in the Local Plan. It can identify schemes, estimated costs, and when the mitigation will be phased alongside the build-out of the development strategy.

We have reviewed the IDP Part A and Part B (The Schedule) and would note the following points:

Strategic Corridor Improvements The A21 and A259 corridors have been identified as requiring capacity management and selective enhancements to accommodate forecast growth. The IDP confirms that any improvements along this corridor should be aligned with National Highways' RIS3 (2026 - 2031), and the LTP4 Investment Plan priorities. We would note that RIS3 is yet to be published, however, the outlined approach would be acceptable in principle. It is important to appreciate that the focus of RIS3 will be on maintenance and renewal; there is uncertainty about the future of RIS3 pipeline projects identified in RIS2. The current position on the A21 Safety Package scheme is available from our website: https://nationalhighways.co.uk/our-roads/south-east/a21-safety-package/

Integration with multi-modal travel: We welcome the statement in Paragraph 3.40 of the IDP which outlines that road interventions must support sustainable travel choices, with new and upgraded infrastructure planning alongside priority measures, cycle lanes, and pedestrian infrastructure. Such improvements should be designed in accordance with appropriate DMRB standards with any proposals submitted to us for approval.

Phased delivery and prioritisation: We agree that road network improvements should be phased in line with housing and employment delivery to ensure new capacity and infrastructure is in place at the right time as development comes forward.

Financial & delivery requirements: It should be noted that any improvement schemes on the SRN would be expected to be delivered via a s.278 (Highways Act 1980) agreement between the developer and National Highways. We do not accept developer contributions, with priorities for the SRN set in the government's RIS.

It is also important to note that RIS3 has yet to be published and as such there should be no reliance on any schemes that may be included within it. As highlighted above, there is uncertainty about RIS3 pipeline projects identified in RIS2.

We would also highlight paragraph 29 of DfT Circular 01/2022 (our emphasis):

'New connections and capacity enhancements to the SRN which are necessary to deliver strategic growth should be identified as part of the plan-making process, as this provides the best opportunity to consider the cumulative impacts of development (including planned growth in adjoining authorities) and to identify appropriate mechanisms for the delivery of strategic highway infrastructure. However, there cannot be any presumption that such infrastructure will be funded through a future RIS. The company will therefore work with local authorities in their strategic policy- making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy.'

We welcome the reference to the 'vision and validate' approach (also known as 'monitor and manage') in Paragraph 10.9 of the IDP.

We consider that it could be beneficial to discuss the suitability of a 'Monitor and Manage' approach for individual proposed developments on a case-by-case basis at the appropriate time during the planning process, as part of a collaborative approach involving us, the LPA, developers and ESCC.

The IDP Part B (the Schedule) lists a number of schemes which directly impact the SRN.

We note that we have been identified as a 'Delivery Partner' for some of these schemes. As previously noted, Paragraph 10.21 of the IDP states that a 'Delivery Partner' is defined as: 'any strategic stakeholder (public or private) involved in the planning, design, technical approval, or funding of infrastructure; they are not necessarily the body that directly delivers the infrastructure itself.'

Based on RDC's definition, we would be a 'Delivery Partner' for all schemes on the SRN as technical approval from us would be required. Any proposed changes to the layout or operation of the SRN will need to be approved by us, with the changes designed in accordance with appropriate DMRB standards and assessed in compliance with DfT Circular 01/2022.

For the avoidance of doubt, unless otherwise specified by us, any identified SRN schemes necessary to support planned growth will not be funded or delivered by National Highways.

With regard to the Schedule itself, it would be useful to have additional information presented in relation to the presented schemes, where applicable, particularly for those classified as critical or essential:

Scheme drawing number reference LPA planning application reference(s) if scheme is linked/conditioned to development(s) Any identified trigger points (development thresholds) at which scheme is required.

We have not undertaken a detailed review of all SRN schemes included within the Schedule as we understand that the transport modelling evidence for the draft Local Plan, based on the latest site allocations, may result in changes to infrastructure requirements. As such, we anticipate that there will need to be a further update to the IDP once the modelling is completed. We have no further comments at this stage.

National Highways will need to participate in discussions involving East Sussex County Council (ESCC) and RDC, to ensure that the agreed modelling scope, specifications, and assumptions are appropriate and proportionate to the needs of the emerging Local Plan.

The IDP is a useful piece of evidence for documenting the outputs from the monitor and manage strategy which needs to form part of the implementation of the Plan. It would benefit from a chart plotting the phasing of essential transport infrastructure alongside the build-out of the development strategy to ensure identified mitigation is delivered at the right time in the development cycle. We are happy to be engaged with the development of further updates to the IDP and the monitor and manage strategy.

Expectation management: We must be clear that the funding and delivery of mitigation to the SRN that is necessary to support the development strategy in the Local Plan are matters for the LPA to decide and manage through the Local Plan process, including during its implementation.

Priorities for investment in the SRN are set in the government's Road Investment Strategy (RIS). There cannot be a presumption that improvements to the SRN necessary to support planned growth in the Local Plan will be funded and supported through a future RIS. RIS3 (2026-2031) will be focused on maintenance and renewal.

We are happy to be engaged in the process of assessing proposed mitigation, e.g. safety and design standards, but will not be responsible for funding or delivery.

Keep informed: We hope these comments are clear and helpful. We are happy to work with Rother District Council on an on-going basis as the Local Plan, including the evidence base, progresses.

Please keep us informed about the development of transport related evidence and the next stage of the Draft Rother Local Plan.

We would also like to share with you our 'Planning for the future - A guide to working with National Highways on planning matters' (October 2023), which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.

We have also prepared a short explainer video outlining how we engage with planning. This video is available from our website under the heading 'Our support for plan-making and decision-taking': https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road- network-in-england/. In addition, we have prepared a Local Plan brochure outlining how we engage with plan-making which is available from the same section of our website.

Should you or any others have any queries regarding our response, please contact us.

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent to the Pevensey Levels SSSI (Site of Special Scientific Interest),
SAC (Special Area of Conservation) and the Ramsar designated wetlands. It is
essential that the ecological integrity of this area is preserved. Any drainage water
flowing onto it requires a Sustainable Drainage System, to exclude any water-borne
pollutants, as well as the creation of an attenuation pond. These requirements are
proving very difficult to fulfil for the smaller development BX20. Building any more
houses, particularly a high-density estate with its polluting run-off, would severely
compromise the ecological integrity of this special area.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow sewer pipe under Barnhorn Road
cannot cope with the current quantity of sewage from the buildings on both sides of
the road in storm conditions. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed that the narrow 9” sewer pipe under
Barnhorn Road cannot cope with the current quantity of sewage from the buildings
on both sides of the road in storm conditions. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

See attached.

See attached.

See attached.

See attached representations from Homes England regarding sites RB6a and RB6b and questions 2, 5, 7, 8, 14, 57 and 68.

See attached response from Hastings Borough Council in response to questions 1, 2, 3, 4, 5, 6, 10, 11, 28, 29, 33 and 69.

See attached representations in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 56, 59, 61, 64, 65, 68 and 69.

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations
Comments:
1. The amended Rother Local Plan Strategic Spatial Objectives shown in Figure1
• There is a significant difference between the National Strategic Objectives as set out in Levelling Up & Regeneration Act (LURA) and the Local Strategic Objectives for Bexhill on Sea.
• I agree with ‘working towards’ a net zero carbon emissions but not by having a single power source or doing so in isolation from other countries. We produce less that 1% of carbon emissions and penalising our industries/commerce in competition with other countries. Ideology needs to incorporate Reality.
• The Strategic Objectives for Bexhill on Sea should reflect the requirements for its resident population. It should take account of the actual additional housing needs, not a ‘one size fits all’ need as calculated and identified Nationally.
• It should reflect that of the local residents of Bexhill on Sea, of which some 50% are >65years; compared to the National Ave of 19%.
• This has significant demand on the needs for employment and population growth/housing. Unless of course the Governments strategic objective is to increase the population of Bexhill on Sea, by provision of homes for an influx of non-local Residents, which would change it from being a predominantly retirement location town to which people choose to relocate to for a better quality of life.

2. Infrastructure
• If it is the intended objective to change Bexhill on Sea from what it’s always been and significantly increase the Housing requirements in line with National Strategic Objectives, which is effectively a Levelling Down, then:
• It is essential that planning approval for additional housing to meet the Governments Housing targets should only be provided once all necessary increases in infrastructure are in place, to cope with the increased demand.
• It is essential that Planning approval must take into account and include all sectors that provide the necessary infrastructure to meet the planned housing demand.
o Water services currently are not included in the planning application process, they are only requested to say they have a ‘strategy’ to supply. This may be long after planning applications have been approved and houses built. We’ve already recently seen problems with water supply, treatment of wastewater and flooding. Indeed, I believe their current strategy was developed pre the Governments recent Housing targets.
o Health Services are not included, GP services; A&E; Community services and Inpatient facilities are already under significant strain and not able to provide services for the existing local resident. This does not include all the housing developments already built and those approved and being developed!
I’ve only mentioned two services, but the situation is the same for all others. The provision of appropriate infrastructure is essential and is an integral element of the provision of housing and relevant to meet both Rother’s housing target and the National LURA Target which is not relevant to Local Resident Housing Needs, it is not a one size fits all target.
From discussions with neighbouring Local Councils, all have similar issues regarding availability of land and meeting the National LURA Housing targets and the ability to ensure the provision of necessary infrastructure. I would seem appropriate for Rother District Council, if they have not already done so, to develop links with other Local District Councils to explore a joint approach to the Government in respect of ‘Local Residents’ Housing Targets.
3. Turning to Development of Needs - Housing:
• Although the previously the number of houses built has not met the housing target that was set, it should be recognised that the number of sites allocated by Planners in the site plan for Developers to build on, was greater than the target required to be met. Indeed, sites that were not included in the consulted and approved Plan, I believe classified ‘windfall sites’ (though significantly greater in numbers to the 39 mentioned in the document), were discussed with Developers, put forward for planning approval and rejected but approved following an Appeal.
• Having been involved with the planning approval process as a resident and recognising the demands placed on the Council Officers to deliver housing on a top-down National level calculation, the involvement of the local residents is basically tokenism. The housing target is given is out of their control and the availability of land is finite, Developers will only choose sites that are financially viable, what influence do the residents have. None………. only once approved, to try and influence the developer on the impact of the site to the local residents.
• Rother District is fortunate to be surrounded by Areas of Natural Beauty, but this is a two-edged sword as all the green areas where you can walk are gradually disappearing and Bexhill is losing its appeal and becoming a New Town surrounded by housing estates. It’s not really planning it’s filling in all the green spaces.

4. Objections to Specific Site Allocations

• BX 14 - Although already approved 210 dwellings (420 cars) this site has serious traffic implications car and pedestrian as access and egress is via Ellerslie Lane which is a narrow lane with no footpath.
• BX 15 – 35 dwellings (70 cars) identified site allocation additional accessed via BX 14, increasing traffic concerns for cars and pedestrians on Ellerslie Lane.
• BX 22 – Additional 400 dwellings (800 cars) Access onto Barnhorn Road at peak times is extremely congested, recently made worse following Rosewood Park major housing development on opposite side of Barnhorn Road.
• BX 27 – Additional 540 dwellings (1,080 cars) on Pevensey Levels (Marshes?) accessing onto an already congested Barnhorn Road .
• BX 39 – Additional 500 dwellings (1,000 cars)
Note the number of additional cars from these five sites alone. So much for reducing the eco footprint for Bexhill on Sea.

Question 5

Section 4 of the Local Plan sets out the approach to ensuring the timely delivery of infrastructure required to support the anticipated growth and new developments in Rother. The infrastructure needs to support the level of growth is to be set out within the existing Infrastructure Delivery Plan, which will also include consideration towards how infrastructure will be funded including through CIL and planning obligations.
NHSPS recognise that health has been included in the general list of infrastructure to be considered when looking at the infrastructure provision needs resulting from the anticipated growth being considered in the Local Plan (Figure 6). Given the strategic importance of health, we would recommend that health infrastructure is prioritised and clearly identified in the Local Plan as essential infrastructure, with an expectation that development proposals will make provision to meet the cost of healthcare infrastructure made necessary by the development. In areas of significant housing growth, appropriate funding must be consistently leveraged through developer contributions for health and care services to mitigate the direct impact of growing demand from new housing. Additionally, the significant cumulative impact of smaller housing growth and the need for mitigation must also be considered by the Plan.

We also emphasise the importance of effective implementation mechanisms so that healthcare infrastructure is delivered alongside new development, especially for primary healthcare services as these are the most directly impacted by population growth associated with new development. The NHS, Council and other partners must work together to forecast the health infrastructure and related delivery costs required to support the projected growth and development across the Local Plan area. NHSPS recommend that the Local Plan have a specific section in the document that sets out the process to determine the appropriate form of developer contributions to health infrastructure. This would ensure that the assessment of existing healthcare infrastructure is robust, and that mitigation options secured align with NHS requirements.

The Local Plan should emphasise that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures. NHSPS recommends that the Council engage with the relevant Integrated Care Board (ICB) to add further detail within the Local Plan and supporting evidence base (Infrastructure Delivery Plan) regarding the process for determining the appropriate form of contribution towards the provision of healthcare infrastructure where this is justified. As a starting point, we suggest the following process:
•
Work with the ICB to understand the capacity of existing healthcare infrastructure and the likely impact of the proposals on healthcare infrastructure capacity in the locality.
•
Assess the level and type of demand generated by the proposal.
•
Identify appropriate options to increase capacity to accommodate the additional service requirements and the associated capital costs of delivery.
•
Identify the appropriate form of developer contributions.
Healthcare providers should have flexibility in determining the most appropriate means of meeting the relevant healthcare needs arising from a new development. Where new development creates a demand for health services that cannot be supported by incremental extension or internal modification of existing facilities, this means the provision of new purpose-built healthcare infrastructure will be required to provide sustainable health services. Options should enable financial contributions, new-on-site healthcare infrastructure, free land/infrastructure/property, or a combination of these. It should be emphasised that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures.

General Comments on Evidence Base relating to Healthcare Infrastructure

The provision of adequate healthcare infrastructure is in our view critical to the delivery of sustainable development. We recommend the Council engage with the NHS, particularly the ICB, on an on-going basis as part of preparing the Infrastructure Delivery Plan (IDP). A sound IDP must include sufficient detail to provide clarity around the healthcare infrastructure required to support growth, and to ensure that both planning obligations and the capital allocation processes for the CIL effectively support and result in capital funding towards delivery of the required infrastructure.
Related to this, appropriate healthcare costs should be factored into the Local Plan Viability Assessment for relevant typologies. Such an approach means that developers are adequately informed in advance that they may be required to make contributions towards healthcare infrastructure. A separate cost input for health infrastructure in the plan viability assessment would ensure that healthcare mitigation is appropriately weighted when evaluating the potential planning obligations necessary to mitigate the full impact of a development. This is particularly important in situations where a viability assessment demonstrates that proposals are unable to fund the full range of infrastructure requirements.

NHSPS thank Rother District Council for the opportunity to comment on the Draft Local Plan. We trust our comments will be taken into consideration, and we look forward to reviewing future iterations of the Plan. Should you have any queries or require any further information, please do not hesitate to contact me.
NHSPS would be grateful to be kept informed of the progression of the Local Plan and any future consultations via our dedicated email address [redacted].

See attached representations and supporting documents from Burwash: Save Our Fields in response to questions 1, 2, 3, 4, 5, 6, 7, 8, 9, 14, 15, 16, 53, 54, 61, 64, 65, 66, 67, 68 and 69.

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.

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.

Please see attached documents for representations relating to BX39 Land west of Ninfield Road, Bexhill:

- Representation Document
- Appendices Part 1
- Appendices Part 2

Re: Draft Rother Local Plan 2025-2042 – Development Strategy and Site Allocations –
Regulation 18 Public Consultation

Thank you for consulting Kent County Council (hereafter referred to as the County Council)
on the Draft Rother Local Plan – Development Strategy and Site Allocations.

The County Council has reviewed the Draft Local Plan and for ease of reference, has
provided comments structured under its services below.

Highways and Transportation

The County Council notes that Rother District Council and East Sussex County Council have
prepared a Shared Transport Evidence Base (STEB) which sets out an Interim Assessment
of the potential transport impacts of future growth.

Initial observations from the Interim Assessment and Mitigation Strategy (Transport No e
001) indicate that there will be significant traffic increases on the A268 approach to the A21
at Flimwell crossroads and the A229/A229 Cooper’s Corner junction ‘will see an increase in
up to 300 vehicles per hour during the peak periods.’ Both these junctions are gateways to
the junction of A229/A268 Hawkhurst crossroads which is constrained and has historically
suffered capacity issues. There are also likely to be significant traffic increases along the
A228 and other Kent roads which are intended to serve as ‘strategic network corridors’.

The County Council requests that the impacts of the proposed growth in the Rother district
are assessed to ensure that the additional traffic generated does not have a severe impact
on congestion or is detrimental to highway safety on the Kent road network. The County
Council recommends use of the Kent Transport Model for this purpose and welcomes the
opportunity to scope out such an assessment.

The County Council, as neighbouring Local Highway Authority, would welcome engagement
with Rother District Council and East Sussex County Council to properly assess the impact
of the Draft Local Plan on Kent’s roads.

Original letter is attached.

My comments and objections on the Rother Local Plan Strategic Objectives are as follows:

I would like to comment in detail on question 1 as I believe that Rother are fundamentally failing to follow the guidelines of the current draft National Planning Policy Framework (NPPF) in respect of how they relate to the village of Peasmarsh. As such, I believe the draft proposals for Peasmarsh are not valid or acceptable and must be reconsidered with reference to the most recent NPPF.

I would request a written response to the points and issues raised in my reply to Question 1 below

Other comments in my reply to Question 1 below

The National Planning Policy Framework sets out the Government's planning policies for England and how these are expected to be used. It questions only is the primary document for all overall planning policy within England.

My grounds for objection are based on the statements with the NPPF we this paper itself.

Firstly, the entirety of the village of Peasmarsh was within the High Weald Area of Natural Beauty (AONB), and it is now a part of a Protected Landscape within the High Weald National Landscape.

Because of this, NPPF on p89 states that planning staff, when creating Plan Making Policies in this area should follow this guidance below :

N1: Identifying environmental opportunities and safeguards

c) Steer the location of development, including through site allocations, in ways which utilise land of least environmental value where that would be consistent with other policies in this Framework. This should include limiting the scale and extent of development within protected landscapes, avoiding the use of higher quality agricultural land where land of poorer quality is available and avoiding and minimising harm to designated sites of
importance for nature.. (my italics).

This is clearly not being upheld in the case in respect of Tanyard field which supports a thriving and diverse wildlife community, including being used by badgers, hedgehogs, frogs, toads, lizards, newts, bats, numerous birds and many other species of plants, animals and invertebrates.

The NPPF continues P89:

N4: Protected Landscapes 1) Development proposals within Protected Landscapes should be limited in scale and extent and sensitively located and designed to avoid harm to their statutory purposes and special qualities. Substantial weight should be placed on the importance of conserving and enhancing the natural beauty of these areas, and to conserving and enhancing wildlife and cultural heritage in National Parks and the Broads. (my italics)

How it be claimed that development within the Peasmarsh Protected Landscape is limited in scale and extent when as the 6th most populous village in the Rye and Eastern Settlement Cluster, we have the 2nd largest increase in housing being proposed! This is not limited development in scale and extent. It will cause great damage to the wildlife and cultural heritage of the area, as described above and will change (and is intended to change) Peasmarsh from being a rural village, (which as the local Neighbourhood Development plan showed, is willing to accommodate reasonable small scale building), into a suburb of Rye. Even though its inhabitants will still have to increase pollution and traffic when going into Rye as no changes to the inadequate bus services are planned (or budgeted for!).

The NPPF continues P89:

2) Proposals for major development within protected landscapes should only be supported in exceptional circumstances (70) where it can be demonstrated that the development is in the public interest. To inform a decision about whether exceptional circumstances exist, consideration of such proposals should include an assessment of:

a) The need for the development, including in terms of any national considerations.
b) The cost of, and scope for, developing outside the designated area, or meeting the need for the development in some other way; and
c) Any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which it could be moderated. (my italics)

I do not believe any such exceptional circumstances exist in the case of Peasmarsh.

a) It would be nonsense to claim any national considerations apply to our small rural village
b) The cost of building in Peasmarsh is the same as elsewhere in East Sussex. Other land has been found in many other areas which are not within the boundaries of the protected landscape. And the village has a recent Neighbourhood plan where it has accepted limited growth. But it does not wish to be turned into a suburb of Rye and should not be turned into one, simply because it is more convenient for planners to see it this way.
c) There would be a clear detrimental effect on the life of Peasmarsh as a rural village with the High Weald National Landscape under the current proposals. Once expanded and made into an extension of Rye, its environment, landscape and recreational opportunities will no longer exist in the traditional form which its current inhabitants were born, or came into, and which the National Landscape seeks to preserve. Any moderation should be to ensure that any major development should only take place outside the National Landscape environment.

The NPPF continues p89:

3) Where, exceptionally, proposals for major development are approved within protected landscapes, steps should be taken to mitigate potential adverse impacts on their special qualities and statutory purposes (71), including on features such as tranquillity and dark skies. (my italics)

There are no grounds for major development within our protected landscape as outlined above. The proposed changes would lead to at least a 50% increase in the size of the village. It would inevitably be a substantial intrusion on the tranquillity and starlit skies that are such a feature of village life at present. In other words, the character of the village within the National Landscape would no longer be in place.

The NPPF continues p89:

4) Development proposals within the setting of protected landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. (my italics)

Substantial adverse impacts will occur if the planned developments take place. I believe you will be informed in the consultation by many of the inhabitants that the clue is in the name - Peasmarsh. The large- scale sites that Rother are proposing are on sites that already have a substantial and well documented ground water problem.

Surface water flooding is endemic in many areas of the village, including runoff from Tanyard Field. The old houses have combined surface water and sewage drains, the surface runoff in the winter occasionally ices over and causes problems for traffic and risk for pedestrians. The sewage is frequently released into the local rivers,
and the proposed developments will only create further difficulties. We have power and internet outages. Any developers chosen will seek to avoid responsibility by pushing problems back to Rother Council, who will then have to the numerous complaints about the utility companies such as Southern Water whose woeful record is already well known.

I also want to comment on the Footnotes for p89 in the NPPF

(70) For the purpose of this policy and policy N5 only, whether a proposal is 'major development' is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the statutory purposes for which the area has been designated or defined.

(71) Where significant harm cannot be mitigated, it may be appropriate to consider whether suitable compensation would be acceptable. (my italics)

I believe that the developments proposed can only be described as major developments which would transform the nature of the village and are not compatible with the requirement to treat the village as being within a National Landscape, as made clear in the NPPF. The significant adverse impacts are discussed above, and will also be found in the other responses to the consultation that are being sent from the village.

It is also unclear how the decision maker in Rother planning has determined whether the proposals are major developments. Could it be made clear on what basis has the decision maker determined that Peasmarsh is to be a major development and why this has been allowed to override the standard definition in NPPF Glossary (Annex B) p112 (below.)

The lack of information and the way in which sites were surveyed (for example the fields chosen, have never been surveyed fully, and have generally been viewed distantly from the road at best. This suggests to me that the planning decisions have been driven by the location on a map and the availability of developer sites, rather than an analysis of the effects on a Protected Landscape, which is required by the NPPF

Finally for clarity, I attach the following information in NPPF Glossary (Annex B) p112

Protected landscapes: Refers to National Parks, the Norfolk and Suffolk Broads and National Landscapes in England.

Designated rural areas: National Parks, National Landscapes, areas designated as rural under Section 157 of the Housing Act1985, and other areas with a population of 3,000 or less and a population density of two persons or less per hectare. National Landscapes: Areas legally designated as areas of outstanding natural beauty under the National Parks and Access to the Countryside Act 1949 and Countryside and Rights of Way Act 2000. Major development: For housing, development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more. For non-residential development it means additional floorspace of 1,000m2 or more, or a site of 1 hectare or more, or as otherwise provided in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

Note that this definition of Major Development is amended as above for section N4 and N5 of the NPPF. I have therefore only commented on the definition i.r.o. footnote 70 (above).

5

Regarding Infrastructure needs, my comments relate solely to Utility 5 and Energy - with specific reference to the Peasmarsh area - which are the fundamental pre-requisites for any acceptable development. The Peasmarsh Neighbourhood Development Plan (PNDP) - accepted by Rother DC in April 2024 after an Inspection and local Referendum - highlighted in great detail the deficiencies of these services in Peasmarsh. The sewer system is grossly inadequate - the combined drain arrangement, combining storm water with sewage, taken together with the wet conditions, ensures not only flooding but the eruption into the road of raw sewage in particularly wet times. This is confirmed by many photos in the Appendices to the PNDP. The Sewage Pumping Station is at the limit of its' capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary. Both Power and Water Supply are clearly inadequate for the existing housing stock, without regard for any increases. In recent times alone, there have been many instances of power or water failure - some of these problems lasting for several days. It is foolish and irresponsible to consider any further development of the village without addressing these issues first.

6

The Development Option SDO13 - A21 Corridor Growth seems 6 sensible and should indeed be pursued. SDO14 - filling strategic gaps - should proceed as well though and the reasons given for abandoning it do not chime with the
achievement of the development targets the plan defines. Many of these reasons are well-meant, but the effect is to force unreasonable development targets onto areas which are technically totally unsuitable.

13

The proposed vision and development strategy for the Eastern 13 Settlements Cluster seems totally wrong. It has all the hallmarks of a paper exercise - conducted from a desk and totally ignoring real life and the situation on the ground. Firstly, the allocation of new homes to Peasmarsh is totally out of proportion to the existing size of the village and its' capacity to absorb additional development. Secondly, the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village - despite the very clear geographical limitations of the Village. Expecting Peasmarsh to take 20% of the additional homes in this area is clearly unbalanced and seeks for some reason to turn Peasmarsh into a dormitory suburb of Rye. The much-touted "commercial centres" in Peasmarsh are all on one site, part of one enterprise, and routinely exposed to commercial realities.

47

I have major objections to two of the site allocations in Peasmarsh - 47 PE3 Tanyard Field and PE5 Malthouse Business Park.

First PE3 Tanyard Field. You refer inaccurately and laughably to this as a "new" site. This is nonsense. The persistent Landowner has been seeking Planning Permission for this site, as a matter of certain knowledge, for more than 40 years and has repeatedly been rebuffed and rejected on appeal on at least one occasion. I hope that you will still be able to refer in your own files to the letter and document issued by Rother DC on 22nd February 1990 under Reference RR/90/0021/P which is
the earliest reference I can find to development being rejected. All the reasons for rejection remain valid today and indeed in some cases are more serious than they were then. In addition, this site was carefully investigated during the preparation of the PNDP, both by the village working group and by independent consultants, and subsequently rejected. There can be no reason, other than the persistence of the Landowner, to ride roughshod over the PNDP - endorsed as it was by decisive village democratic referendum and accepted by Rother DC in April 2024. The site is totally unsuitable for development on many grounds:

The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its' undulating park-like appearance is visible from many locations round the village. Development would have a catastrophic impact on the rural character of the area. The visual amenity of the entire village would also be thereby damaged. Acceptance of the site would encourage other similarly unsuitable applications in the vicinity. The suggestion that the site would accommodate 15 dwellings is a very naïve understanding of the issue. If the site went ahead, then this would be the thin end of the wedge. The Landowner has put forward various outlines for the site in recent years - the largest involved nearly 100 houses and relentless pressure would ensue to rise to this total. Any development would impact unfavourably on nearby listed buildings. The field has a historic right of way across the western end. For nearly a thousand years, villagers have used it to walk up to the church and the vista from this path would be irretrievably damaged. The field slopes very steeply downwards towards the North, making it totally unsuitable for housing and helping to generate the drainage problem referred to below. The major technical issue is the drainage of the site, which is totally wet. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. The heavy clay soil makes the surface completely impermeable, so heavy rain simply runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street - see comments on Infrastructure in response to question 5. Your own letter of 1990 - reference above - states "the local Planning Authority in consultation with Southern Water is not satisfied that the site can be adequately drained". The vehicular access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road, where the 30mph speed limit is regularly ignored to the despair of villagers. As stated repeatedly, the infrastructure around the site is completely inadequate for any further housing. The drains cannot cope. See copious photos in the Appendices to the PNDP.

Second PE5 Malthouse Business Park.

This small development of light industrial and commercial units is of great value to many in Peasmarsh. Its' loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work and it seems counterproductive to positively take steps to deter employment.

67

Regarding Development Strategy Options and Preferred Approaches in Appendix 3, I do NOT agree with the elimination of option SD09 which is at least worthy of further investigation on a case-by-case basis. However, it has to be remembered that no desk- chosen arbitrary option is necessarily going to produce a figure for a community that is achievable on the ground given local constraints.

Question 1: Looking at the first of the Strategic Spatial Objectives -the proposed Rother Plan does not fit with this objective "Mitigate and adapt to climate change, including by delivering net zero carbon ambitions, reducing flood risk from all sources and promoting the multifunctional benefits of green blue infrastructure through effective and supportive planning policies.

You emphasise this in several documents:

Climate and Nature Emergency Declarations - Rother District Council:
Climate and Nature Emergency Declarations 2019. The burning of fossil fuels and deforestation is causing an unprecedented increase in global temperatures" (One important comment is the coloured stripes methodology used to show temperature increases from 1850 onwards has no connection to actual temperatures - does each colour change mean degree or 1 degree - it is treating us like children and has no place in a Council document).
Further: "The Rother Environment Strategy 2020-2030 (Superseded by the Climate Strategy: 2030) Rother District Council has declared a Climate Emergency with the ambitious target of being carbon, and other noxious gas, neutral by 2030." This statement, in a Council document, does make one suspect that the writer is not fully cognisant of the topic being dealt with. Carbon is not a gas, carbon dioxide is, neither is it noxious - it is present at 0.04% in air (at 0.03% all plant life dies).

"The rights of trees, was carried on 15th September 2025 to strengthen the council's response to protecting wildlife. Council - Monday 15th September 2025 6.30 pm Agenda for Council on Monday 15th September 2025, 6.30 pm - Rother District Council:
B) This Council supports the introduction into law of legislation which would require those taking decisions affecting trees to have regard to the trees' rights to: 6. not to be killed"
Yet examining the sites shows many places where trees will be cut down, trees capture carbon, as does grass - yet you are planning on reducing their numbers and the area of green land!

"Environmental Management Background Paper: P24 East Sussex Environment Strategy 2020
2.56 And finally, looking at water, "the long term aim of this Strategy is for East Sussex to achieve a resilient and sustainable water supply for consumers and the environment."
However in Peasmarsh our water supply is already not resilient - the system has broken down, sometimes due to flooding, having to provide plastic bottles of water, as has been the case a couple of times in the past few years is not sustainable. Conversations with other Rother residents echo these problems.

The second Strategic Spatial Objective: "Maximise opportunities for nature conservation, recovery and biodiversity net gain and preserve the historic landscape character of the High Weald National Landscape and protected habitat areas of Rother and ensure sensitive development that allows communities to thrive."

Many of the proposed sites seem to be areas of greenery, fields that have existed since time immemorial with clumps of trees, Tanyard field in Peasmarsh being an example. The range of biodiversity is high with numerous birds and many other species of plants, animals and invertebrates.

The 4th Strategic Spatial Objective: "Respond to the housing crisis and help facilitate the delivery of housing to meet the needs of different groups in the community, ensuring a variety of high-quality sustainable, zero carbon ready dwellings that meet the needs and address the income levels of Rother's wider population for their lifetime"

"Economy Background Paper:

4.2 Rother's population is growing and ageing. Between 2008 and 2022, Rother's overall population increased by 4.48%. However, the number of residents in Rother aged 65 and over increased by over 22.9% in the same time period, while the number of Rother's 30-44 year old residents decreased by 9.4%. Trend-based population projections (2020-2040) find that the overall population will continue to increase, with the increase in residents aged over 75 particularly significant, but also that numbers in the younger age groups will decrease."

"Health and Wellbeing Background Paper P16 Figure 2 shows from the 2021 census Rother has 18% 0-19, 21% 20- 44, 28% 45-64, and 32% 65 and over (with 16% being 65-74, 11% being 75-84 and 5% being 85 and over)"

"Housing Background Paper: P32 Population and household change

4.2 Rother's birth rate (2002-2019) has been lower than the County, regional and national averages. Also in line with the older age profile, Rother's death rate (deaths per 1,000 population) is higher than the County, regional and national averages."

"4.3 The life expectancy of Rother residents is broadly in line with the county and regional averages"

"Housing Background Paper 4.10: 2021 figures show that Rother has a higher proportion of owner- occupied dwellings (72.7%) compared to the national average (61.3%)"

The demographics given show that no such crisis exists - in the short term it is rather about allocation, in the medium and long term it disappears completely. When The Maltings housing was built local people were told that they would be housed - yet not one local person was given a home. This is a source of great bitterness whenever you talk to local families. Instead councils from outside the area were able, due to greater financial resources, to take places available. Further these people then became a burden on local Social Services - as once living in the area their support falls on Rother Council.

Those of us who have families around the country know that the allocation of housing to non-locals due to changing priorities by both Governments and Councils is a source of great distress to those from the locality affected. Should housing be built, the local Peasmarsh homeless will again lose out.

However the age structure and ownership rates given also need to be examined. Rother has an exceptionally high number of old (and very old) people who are often home owners coupled with a lower than average birth rate. When these people pass on they leave their dwellings behind. These become available for local relatives to live in, sell to others or rent to people in the area.

Strategic Spatial Objective 8: " Enhance the sustainability and connectivity of local communities through sustainable transport measures, including to support active travel, and improved internet network coverage"

Here when Background papers are examined it becomes clear that those involved in drafting these documents are young fit adults probably living in towns, who have not sought out information from the older demographic or indeed locals.

So the buses are infrequent, stop early and do not connect with trains. Further other than pie in the sky ambitions, no real steps are taken e.g. allowing people to receive a bus pass at 60, putting on more frequent buses on market days eg. Buses going into Rye on Thursdays.

Instead we get statements that could help- if amended:

"6. Safer, healthier and more active travel | East Sussex County Council More active travel: This plan will improve connectivity to enable people to travel by walking, wheeling and cycling, making it a natural choice for short journeys to access key services, such as employment, education or GPs, in both urban and rural areas." A chronically ill person cannot cycle to a GPs appointment.

Strategic Spatial Objective 9: "Support and achieve safe, healthy, vibrant and mixed communities where the physical and mental health and well-being of residents is a high priority. Create high standards of inclusivity and accessibility to shared facilities for all the district's residents"

Those of us who have had to spend time worrying that our local area is going to be further changed utterly, that the already more crowded roads due to more people, much longer waiting times for GPs and the risk of flooding, power cuts etc, know that our mental health and well- being have been damaged already.

Strategic Spatial Objective 11: "Deliver sustainable development by making the optimal use of land, including by prioritising the use of brownfield land and ensuring all new development is designed and built to appropriate densities, having regard to local context and character."

Yet in many proposed developments it is not brownfield land - because agricultural land is worth less, greedy landowners who have large areas put it forward knowing that they will make a huge profit when sold on to developers.

We the custodians of this land have been gifted it by our ancestors and hold it in trust for our children. We do not want the rural area to recede and be lost for the generations to come.

Question 5: The Peasmarsh Neighbourhood Development Plan (PNDP) - accepted by Rother DC in April 2024 after an Inspection and local Referendum - highlighted the deficiencies of the water and sewage utilities in Peasmarsh. The sewer system cannot cope already -it combines storm water with sewage, leading to not only flooding but raw sewage in the road when wet weather occurs. (See many photos in the Appendices to the PNDP). The Sewage Pumping Station is at the limit of its' capacity. Any additional building of any consequence will cause further deterioration in this problem and make life particularly unpleasant and insanitary. Both Power and Water Supply are already inadequate for the existing housing stock. Power cuts happened in December and February, this affects the Pumping system making the situation worse.

Question 13: "Rother District Council - Rother Local Plan 2025-2042 - Development Strategy and Site Allocations - 6.75. Peasmarsh: Compared to most villages of its scale, has a less defined village centre, which increases the distances between services and facilities, therefore limiting the walkability of the settlement.

This taken from your own discussion paper mitigates against many other of your own ambitions - health etc. Further in surveys approx. 80% of the shoppers to Jempsons do not come from the village - it is an upmarket shop and therefore people come from settlements around. Also as only one complex volatility in the retail sector over the past 6 years in particular means that all these facilities could be lost at any time

Table 23 in the same document shows that the absolute number of new homes allocated to Peasmarsh is in excess of that for any other village: "Housing dwelling nos Existing allocations and sites with planning permission): 52; Housing (dwellings nos) (Proposed new allocations): 91; Total housing (dwelling nos): 143". Peasmarsh will be turned into a dormitory suburb of Rye and lose its rural aspect and countryside views visible from many parts of the village if 20% of the additional homes are designated for this area. See answer q1 also.


Question 47: Peasmarsh generally: Peasmarsh has already seen development in recent years (Farley's Way and The Maltings) which meant that ponds have been filled in, culverts that used to be able to drain to these ponds have also been filled in which has already led to flooding increasing. How can it be claimed that development within the Peasmarsh Protected Landscape is limited in scale and extent when as the 6th most populous village in the Rye and Eastern Settlement Cluster, we have the 2nd largest increase in housing being proposed! The proposed changes would lead to at least a 50% increase in the size of the village

The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England, it is the primary document for all overall planning policy within England. The NPPF states P89: 2) Proposals for major development within protected landscapes should only be supported in exceptional circumstances (70). The demographics of the Rother area in general (see response to q1) show that no such exceptional circumstances exist.

"Infrastructure Background Paper: P13 East Sussex County Council Local Flood Risk Management Strategy 2016-2026: The East Sussex Local Flood Risk Management Strategy provides the framework for the management of local flood risk in the county and focuses on the management of flood risk from surface water, groundwater and ordinary watercourses."

Yet you seem to specifically exclude the damage that surface water has caused in the past. Peasmarsh - it's in the name - has been classed as a flood plain since the 80s. Older houses have wells because the water table is so high. The names of older properties often reflect this fact. Previous developments in Farley's Way, removing turf, meant that the bungalows next to The Horse and Cart Pub flooded.

"The NPPF P89: N4: Protected Landscapes 1) Development proposals within Protected Landscapes should be limited in scale and extent and sensitively located and designed to avoid harm to their statutory purposes and special qualities. Substantial weight should be placed on the importance of conserving and enhancing the natural beauty of these areas, and to conserving and enhancing wildlife and cultural heritage in National Parks and the Broads" Tanyard field supports a diverse wildlife community, being used by hedgehogs, frogs, toads, lizards, newts with bats at dusk and many bird species

Tanyard field: Over 30 years ago building on Tanyard was rejected by the Secretary of State -February 1990 under Reference RR/90/0021/P.

"Guide to Sustainable Drainage Systems (SuDS) in East Sussex (2015) 2.57(p24): As the Lead Local Flood Authority, East Sussex County Council have provided guidance in June 2015 on the use of SuDS in the county. The guidance outlines that SuDS are needed due to, in part, the increasing impermeable surfaces being constructed restricting rain water from naturally soaking into the ground and therefore flowing into the sewerage network and overloading it."
You are proposing to build on a field that slopes in two directions which already causes flooding. All gardens adjoining Tanyard are like sponges - once houses are there this will increase hugely leading to more floods. Recently (Jan 26) an internet outage was directly caused by flooding. The field is full of Springs clearly noted on old maps. They remain there today. Photos are available of a waterspout rising from the middle of the field. Heavy rain runs off causing considerable problem and damage to the properties lining Main Street, which lie along the Northern boundary of the field. Development will only make this worse. This in turn overloads the main combined drain running down Main Street.
The field is located in the Area of Outstanding Natural Beauty/High Weald National Landscape and any development would be clearly detrimental to the character and appearance of the landscape. Its' undulating park-like appearance is visible from many locations round the village access to the site is inadequate and unsafe. There are two access points. At the western end, a narrow gateway, completely unsuitable for traffic, gives onto narrow School Lane at a particularly congested point near the school. Towards the Eastern end, the main access gives onto Main Street between two bends where the sight lines are insufficient given the nature, speed and volume of traffic on the main road.

Second PE5 Malthouse Business Park: Its' loss would clearly be detrimental to the establishment of small businesses in the village, who find this kind of facility essential. The people who live in the village have to have opportunities to work.

1. This is a letter of response to Rother’s Local Plan 2025–2042; a plan which Rother District Council has been developing over several years, yet upon which residents have only a couple of months to digest and respond.
2. Why is this consultation period so short, and do not those affected by Rother District Council’s Local Plan deserve better in terms of timescale—particularly when Rother DC is permitted to wait up to 20 working days to respond to questions from the public (FoI)?
3. What considerations has Rother District Council given to these timescales, and what impact assessments have been made in terms of the public’s ability to respond?
4. For example, I only found out about the St Mark’s Church (Little Common) consultation after it had taken place, although it was suggested there was no level (wheelchair) access into the premises anyway.
5. Rother’s Local Plan 2025–2042 is a blueprint for the unsustainable urbanisation of Bexhill on Sea and Robertsbridge (etc.) to the detriment of local wildlife and nature, including protected species such as badgers.
6. The word badger appears only once in the Local Plan, yet there are potentially multiple sites that will adversely affect their habitat. Why?
7. Indeed, site BX16 would lead to the unacceptable decimation of a meadow containing protected species, yet this impact is not mentioned in the Local Plan. Why the omission?
8. The Local Plan should (as a matter of urgency) be designating sites such as BX16 as protected wildlife sanctuaries. Why does it not do so?
9. There are numerous sites that will unacceptably decimate green natural areas, whether it be a pocket of greenery at Cooden (BX19) or the extensive urbanisation of greenfield sites such as BX20, BX22, BX23, BX24, BX32 and BX33.
10. In destroying the character of Bexhill, has Rother DC no shame?
11. The existence of the radio antenna and its two supporting towers have enabled the Local Authority to euphemistically describe this BX16 meadow as a “brownfield” site ready for development. Presumably, having built a car park on part of the public open space at The Gorses (BX19) enables the Local Authority to also use the euphemism “brownfield” in order to support its urbanisation plans?
12. What impact assessments have been made as to the potential loss of these green areas to nature?
13. What impact assessments have been made as to the potential loss of these green areas to the well being of society?
14. If no impact assessments have been undertaken, what was the decision making process behind not doing so?
15. Yet there is a huge “green” area in non agricultural use immediately adjacent to Cooden Beach railway station, which is located on an important railway route with frequent direct services to Ashford, Rye, Hastings, Eastbourne, Lewes, Brighton, Gatwick Airport and London.
16. The provision of a new railway line to Bexhill’s sprawling housing developments is not viable; the potential relocation of a “brownfield” golf course (whose attendees do not travel by rail) to enable a sustainable housing development has simply been ignored. Perhaps too many Council officials play golf.
17. What was the decision making process behind not including this potentially valuable development site in the Local Plan?
18. The Local Plan goes into much detail, claiming many “facts and figures” in an attempt to justify this urbanisation, including why sites identified in 2024 (HEDNA) are no longer “sufficient”.
19. However, the Local Plan does not address simple practicalities such as the traffic levels generated by these developments, either into Bexhill or to adjacent towns along a restricted road network.
20. Traffic entering Bexhill (perhaps to visit all the charity shops) will end up “fighting” for the limited parking spaces that exist—apart from the car park to the rear of Endwell Road (BX11), which is to be built upon.
21. The Local Plan includes many references to sustainable transport, including walking and cycling (all very laudable), yet Bexhill on Sea has a significantly higher than average elderly population compared to the rest of the UK. As of 2021/2022 data, it has one of the oldest median ages for a town of its size in the country.
22. However, the Plan includes very little to address the needs of this elderly population (the word “elderly” appears only twice within definitions).
23. For example, not all bus routes are serviced by accessible buses, and whilst some railway stations have ramped access, this does not meet modern accessibility standards. Yet housing development is proposed without improvements to such public transport infrastructure.
24. Why are these accessibility issues not included in the Local Plan?
25. What amount of housing is being included to enable elderly and disabled persons to enjoy independent living in an accessible house, on an accessible public transport route, with a private garden?
26. On a wider issue, beaches along the South Coast have suffered unacceptable levels of sewage discharge from water companies who cannot cope with existing demand. The Local Plan will only add to this demand without providing any solutions beyond “provide for an acceptable connection to the local sewerage system”.
27. Why has Rother’s Local Plan not addressed the current lack of sewerage capacity, nor the impact that its developments will have upon it?
28. Then there is the inadequate water supply to the area—indeed to most of East Sussex and Kent. The Local Plan remains silent on this issue despite all the pages of so called “facts and figures” on national housing needs.
29. The water companies operate to five year plans, yet the Local Plan runs to 2042. Has Rother DC considered the future disconnect between the two timescales, and if so, how will this be addressed?
30. Why is the Local Plan selective in addressing national issues such as housing needs, but not water supply and sewerage needs?
Finally, as a reasonable adjustment for disabilities (Section 20 of the Equality Act 2010), I request that Rother District Council provide confirmation of receipt of this letter by their Planning Policy Department.

1. This is a letter of response to Rother’s Local Plan 2025–2042; a plan which Rother District Council has been developing over several years, yet upon which residents have only a couple of months to digest and respond.
2. Why is this consultation period so short, and do not those affected by Rother District Council’s Local Plan deserve better in terms of timescale—particularly when Rother DC is permitted to wait up to 20 working days to respond to questions from the public (FoI)?
3. What considerations has Rother District Council given to these timescales, and what impact assessments have been made in terms of the public’s ability to respond?
4. For example, I only found out about the St Mark’s Church (Little Common) consultation after it had taken place, although it was suggested there was no level (wheelchair) access into the premises anyway.
5. Rother’s Local Plan 2025–2042 is a blueprint for the unsustainable urbanisation of Bexhill on Sea and Robertsbridge (etc.) to the detriment of local wildlife and nature, including protected species such as badgers.
6. The word badger appears only once in the Local Plan, yet there are potentially multiple sites that will adversely affect their habitat. Why?
7. Indeed, site BX16 would lead to the unacceptable decimation of a meadow containing protected species, yet this impact is not mentioned in the Local Plan. Why the omission?
8. The Local Plan should (as a matter of urgency) be designating sites such as BX16 as protected wildlife sanctuaries. Why does it not do so?
9. There are numerous sites that will unacceptably decimate green natural areas, whether it be a pocket of greenery at Cooden (BX19) or the extensive urbanisation of greenfield sites such as BX20, BX22, BX23, BX24, BX32 and BX33.
10. In destroying the character of Bexhill, has Rother DC no shame?
11. The existence of the radio antenna and its two supporting towers have enabled the Local Authority to euphemistically describe this BX16 meadow as a “brownfield” site ready for development. Presumably, having built a car park on part of the public open space at The Gorses (BX19) enables the Local Authority to also use the euphemism “brownfield” in order to support its urbanisation plans?
12. What impact assessments have been made as to the potential loss of these green areas to nature?
13. What impact assessments have been made as to the potential loss of these green areas to the well being of society?
14. If no impact assessments have been undertaken, what was the decision making process behind not doing so?
15. Yet there is a huge “green” area in non agricultural use immediately adjacent to Cooden Beach railway station, which is located on an important railway route with frequent direct services to Ashford, Rye, Hastings, Eastbourne, Lewes, Brighton, Gatwick Airport and London.
16. The provision of a new railway line to Bexhill’s sprawling housing developments is not viable; the potential relocation of a “brownfield” golf course (whose attendees do not travel by rail) to enable a sustainable housing development has simply been ignored. Perhaps too many Council officials play golf.
17. What was the decision making process behind not including this potentially valuable development site in the Local Plan?
18. The Local Plan goes into much detail, claiming many “facts and figures” in an attempt to justify this urbanisation, including why sites identified in 2024 (HEDNA) are no longer “sufficient”.
19. However, the Local Plan does not address simple practicalities such as the traffic levels generated by these developments, either into Bexhill or to adjacent towns along a restricted road network.
20. Traffic entering Bexhill (perhaps to visit all the charity shops) will end up “fighting” for the limited parking spaces that exist—apart from the car park to the rear of Endwell Road (BX11), which is to be built upon.
21. The Local Plan includes many references to sustainable transport, including walking and cycling (all very laudable), yet Bexhill on Sea has a significantly higher than average elderly population compared to the rest of the UK. As of 2021/2022 data, it has one of the oldest median ages for a town of its size in the country.
22. However, the Plan includes very little to address the needs of this elderly population (the word “elderly” appears only twice within definitions).
23. For example, not all bus routes are serviced by accessible buses, and whilst some railway stations have ramped access, this does not meet modern accessibility standards. Yet housing development is proposed without improvements to such public transport infrastructure.
24. Why are these accessibility issues not included in the Local Plan?
25. What amount of housing is being included to enable elderly and disabled persons to enjoy independent living in an accessible house, on an accessible public transport route, with a private garden?
26. On a wider issue, beaches along the South Coast have suffered unacceptable levels of sewage discharge from water companies who cannot cope with existing demand. The Local Plan will only add to this demand without providing any solutions beyond “provide for an acceptable connection to the local sewerage system”.
27. Why has Rother’s Local Plan not addressed the current lack of sewerage capacity, nor the impact that its developments will have upon it?
28. Then there is the inadequate water supply to the area—indeed to most of East Sussex and Kent. The Local Plan remains silent on this issue despite all the pages of so called “facts and figures” on national housing needs.
29. The water companies operate to five year plans, yet the Local Plan runs to 2042. Has Rother DC considered the future disconnect between the two timescales, and if so, how will this be addressed?
30. Why is the Local Plan selective in addressing national issues such as housing needs, but not water supply and sewerage needs?
Finally, as a reasonable adjustment for disabilities (Section 20 of the Equality Act 2010), I request that Rother District Council provide confirmation of receipt of this letter by their Planning Policy Department.

I write as a ward member in the High Weald. Like many of those seeking to answer the questionnaire it forces onto object where one might offer qualified support and does not always allow one to raise issues that do not quite fit the frame. I hope therefore that you will accept this memorandum as a response. I note also that I am a member of Etchingham Parish Council and am supportive of their answers to the questionnaire.
Rother has been asked (by algorithm) to find sites for 911 a year and even if all the sites in the draft Local Plan were agreed would fall well short of the figure. In large part that is because 83% of our Land area is protected as an historic Landscape and 90% in all is protected by that and other designations. Bewl Bridge reservoir may well be an SPA before the Local Plan is considered by the Inspector.
It follows that Rother will have to make a strong case for a lower annual number and in that regard it would seem helpful to set out in some detail what as a planning authority we see as entailed by the duty to conserve and enhance the Historic Landscape. This is all the more important as the way the new NPPF is structured could (without any apparent intention to do so) suggest that a case can be made for circumventing those protections.
It is essential therefore that there should be a section or full Chapter in the Local Plan detailing what features/characteristics of the High Weald should be preserved and identifying specific policies to achieve that end. While many of the policies relevant to development in the countryside apply, more is required. That is because we are dealing with the best surviving late mediaeval landscape in Europe. Were it a listed building it would be graded One. In effect we need to translate the High Weald Management Plan into specific policies.
Of particular importance to Etchingham is its position just to the west oft the confluence of three rivers, the Limden, Eastern Rother and Dudwell. All three are largely unspoilt and rich in biodiversity. They have much to contribute to the new nature conservation strategy. In addition both the Limden and Rother valleys include important features of the once prevalent iron working industry, not least the Hammer Ditch which provided barge access to the Etchingham site.
I note in passing that the potentially important fortification at Burgh Hill seems to have escaped attention hitherto.
Specific policies are required to preserve the unspoilt character of these valleys, together with others like the Brede Valley.
It is possible that the flood plains themselves are of some historic importance.
The second important consideration that Etchingham and other parishes wish to advance is the need to deal with a major problem with our infrastructure before any further development takes place. The current drainage system is inadequate and will not support the development proposed. This is particularly true of Shrub Lane in Burwash and of Etchingham more generally. For example at several points in Etchingham this leads to a regular n overspill of raw sewage, not only unpleasant but a potential public health problem.
Further infrastructure investment is required to reduce speeds on the Straight Mile and increase GP services in the area and these should be addressed in Rother’s infrastructure plan and submitted to the Sussex Mayor when s/he comes into office. The Parish Council also has an interest in seeing the Hurst Green bypass built.
Commenting specifically on five potential development sites, two of which are not currently included in the draft Local Plan, I am taking it that design, dark skies and other issues will be subject to specific policies for the High Weald.
EC1 Land off Oxenbridge Lane. 10 dwellings. Although this is bound to have some adverse effect on existing properties, one of them to the west of the site listed, the site has long been identified for development, and is in the draft Neighbourhood Plan, The Parish Council has no objection therefor, but would note that the access designated for the site has been known to flood.
EC2 Land at Church Lane. 5 dwellings. Again this is in the draft Neighbourhood Plan, but in this case consent should be subject to an agreed layout that minimises the effect on the cottages on the other side of the lane, which is substantially lower. Hence the number should be restricted to five and be in two groups, one at the NW end of the site and the other at south corner. This will mean that they do not overtop the existing houses. An architect’s plan was prepared for the draft Neighbourhood plan and the Council suggest that that Local Plan should indicate that approval will not be given to an outline plan. No objection in principle.
EC3 Croft Field. This is a major development in terms of paragraph 190 of the NPPF and this on its own indicates that it should be rejected. This is a field traceable to the mediaeval period, valuable pasture in agricultural terms, visually open and relatively high. Development here would have a visual impact on the Rother valley in particular. When consenting to the development of Parsonage croft, the Parish Council looked to ensure that it would end block the village and to that end, the Jubilee Wood was created in 2012 The new development would eat significantly into the green wedge between settlements and in a form that is wholly out of keeping with settlement edges in the High Weald. An estate of small houses at a high density is an unnatural extension of Etchingham and to be resisted for the harm it will do the High Weald. Even within the Parish there are small settlements that could be somewhat extended and do less harm to the historical character of the landscape. It should be noted that while the landowners support some development here, they were aghast at the suggestion that it should amount 55 houses.
However, the claims of two further sites for inclusion should not be overlooked :
1. The Lambing Shed. At least 6 starter homes. Already in the draft Neighbourhood Plan. This is a brownfield site and the Council fails to understand why it has been ruled out. It is possible that there has been some misinformation about the location of ancient woodland. The track accessing the site is already in use as an access and while the architect’s suggestion of ten may be excessive, at least half a dozen small properties would help meet one of the village’s principal needs. Sight lines at the access would need attention.
2. land behind Ladyfield. Six houses. Included in the draft Neighbourhood plan. This is not a site that is visually intrusive on the AONB, more particularly the Rother Valley and the furthest property would be no further from the High Street than those in Oaks Close. While the access is closer to Oxenbridge Lane on the south side of the High Street than is really desirable, the traffic is already slowing radically and access for a relatively small number of vehicular movements would seem achievable. Further assessment of the site is warranted.

Please see attached:
- Development Strategy and Site Allocations EA response (Part 1)
- Interim SA and IDP EA response (Part 2)
- Rother Draft Local Plan IDP Part B - EA amendments (Part2)

Part 1 - Development Strategy and Site Allocations

Consultation on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

We have provided advice and guidance
to strengthen policies and evidence to ensure the new Local plan aligns with
national, regional and local requirements.

Environment Agency Position

Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.

Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.

Further details are provided in:
• Section 1 – General recommendations
• Section 2 – Specific comments on proposed policies and sites

Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.

Our planning advice service

As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.

We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our
cost recoverable planning advice service.

Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally sensitive development.

We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

Part 2 - Interim SA and IDP

Consultation on the Draft Rother Local Plan 2025–2042 – Interim Sustainability
Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and Part B (the
Schedule)
Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Interim
Sustainability Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and
Part B (the Schedule). We have provided advice and guidance to strengthen policies
and evidence to ensure the new Local plan aligns with national, regional and local
requirements.
Environment Agency Position
Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.
Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.
Further details are provided in:
•
Section 1 – Infrastructure Delivery Plan (IDP) comments
•
Section 2 – Interim Sustainability Appraisals (SA) comments
We also attach the following document to our response:
•
Rother Draft Local Plan IDP Part B - EA amendments
Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.
Our planning advice service
As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.
We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our cost recoverable planning advice service.
Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally
sensitive development.
We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

This representation was received after the Regulation 18 consultation had completed but is published in the public interest.

Please see attached Consultation Response from South East Water.

Q5: The sewage system cannot cope with the current level of housing at Peasmarsh without adding yet more !
So far this year there have been 27 dumps/283 hours by Southern Water pouring raw sewage into the River Rother. Southern Water have admitted that the pumping station is currently working at it’s limit in times of heavy rainfall.
. Any further development will only exacerbate the problems.
These problems were highlighted in the PNDP and accepted by RDC in April 2024. There should be NO further developments in Peasmarsh until the sewage infrastructure is vastly improved.
Very poor Local bus service ( 1 every 2 hours ), with poor connections for onward travel.
ESCC are withdrawing the 313 Evening weekdays and Sunday service due to lack of funding.
Poor road surface , when raining heavy flooding of roads due to blocked drains not only on main roads but surrounding lanes as well ( some have been blocked for years ). This leads to many potholes being formed throughout winter.
Q47: PE 3 TANYARD FIELD.
This site was scrutinised and investigated during the PNDP 2024 by not only the local residents group but also by the independent inspectorate and endorsed by the village referendum as being totally unsuitable for development. This decision was accepted by RDC in 2024. The whole site is riddled with natural springs which even now causes problems with surface water running off to the properties bordering the site.
Q47: PE 4 ORCHARD WAY
Flooding occurs when there is very heavy rain. A drainage ditch drains into the small pond on the site which then flows into a small drainage pipe. In times of heavy rain this cannot cope with draining the water away and flooding occurs.
The site is also abutted on one side by a row of very old Poplar trees and oaks. One would assume that these would have to be cut down to ensure the safety of any houses built nearby. This would be sacrilege as the trees form part of the landscape of our village and are inhabited and visited by many birds and animals.
There is only narrow limited access to site via privately owned road.
There is no mains drainage available on this site.
Q47: PE 5 Malthouse Business Park
Used by small local firms employing local people. Removal of these premises would be detrimental to the establishment of small businesses within the village which also give employment to local people. The car parking area is utilised by users of the playing field, the loss of which would create further parking issues in nearby streets.

Please see attached representations responding to questions 1, 2, 3, 4, 5, 6, 7, 9, 10, 17, 18 & 24

- Covering Letter March 2026 regarding Rother Local Plan 2025–2042 Development Strategy and Site Allocations regarding Sea Change Sussex’s representations
- Representations of Sea Change Sussex answering questions in the Rother Local Plan 2025–2042 Development Strategy and Site Allocations

Key issues raised in representations:
1. The Retail Study and underestimation of need
2. Countryside Park use of retail park car park
3. Development densities on existing allocation sites
4. Development contributions
5. Pressures from unmet housing needs
6. Strategic Gap options
7. Blanket buffer approaches to habitat on BX47
8. Additional sites suggested

Please also see Call for Sites site submission of BEPNX- Bexhill Enterprise Park North Expansion Land, as set out in attached documents below:

- Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- DaSA excerpt of the Strategic Gap at Bexhill, Crowhurst and Battle
- Responses to questions 5a, 6c, 7b and 8a in the Call for Sites site submission form regarding submission of site: BEPNX- Bexhill Enterprise Park North Expansion Land
- Site outline plan of Bexhill Enterprise Park North Expansion Land
- Accurate Visual Representations for Bexhill Enterprise Park North Feb 2020
- Accurate Visual Representations for Bexhill Enterprise Park North Aug 2019