This representation has been prepared on behalf of Persimmon Homes South East in response to the Rother District Council (‘RDC’ or ‘the Council’) Development Strategy and Site Allocations (Regulation 18) consultation, which runs until 23 March 2026.
RDC is preparing a new Local Plan to set out a strategy for development across the District for the period to 2042. Once adopted, the new Local Plan will update and replace Rother’s Core Strategy (2014) and Development and Site Allocations (2019) Plans.
This Regulation 18 consultation now seeks views on the proposed site allocations which have been identified to deliver the updated spatial strategy and some area-specific policies related to the options for strategic growth.
The purpose of this representation is to support the growth identified for Bexhill and in particular the inclusion of ‘Land west of Fryatts Way’ (draft Policy BX14), ‘Land off Spindlewood Drive’ (draft Policy BX20) and ‘Land north of Barnhorn Manor Caravan Park’ (draft Policy BX21) which are being delivered by Persimmon Homes as set out below. It seeks to comment on the scope of the draft policies and on the proposed spatial strategy more generally.
Housing Land Supply
The number of homes identified as new and updated draft allocations has increased considerably since the April 2024 consultation, rising from 2,129 to 5,051 dwellings. This brings the total housing figure for the Plan period accounting for all sources of supply to 8,427 homes over the 17-year Plan period, equating to 495 dpa.
This is recognised to be a considerable increase in potential housing supply when compared to the adopted Core Strategy figure (355 dpa). However, at the time of writing, the Government’s standard method figure for Rother sets a minimum target of 912 homes per annum, equating to a Plan period need of 15,504 homes. The Framework is clear that the standard method figure should be used to determine the minimum number of homes
needed, along with any needs that cannot be met within neighbouring areas which should also be taken into account in establishing the amount of housing to be planned for.
Even without accounting for unmet needs from neighbouring authorities, at this stage the Local Plan would underdeliver annually by 417 homes, resulting in a shortfall of some 7,077 homes across the Plan period. This is even before a suggested minimum buffer of 5% for non-implementation is included, which would result in a shortfall of 775 dwellings.
Therefore, we urge the Council to take each and every opportunity to allocate suitable sites.
Spatial Strategy - Bexhill
The proposed spatial strategy is strongly supported, particularly in identifying West and North Bexhill as the main areas for growth. This approach strengthens the role of Bexhill-on-Sea as the district’s most sustainable settlement. As the largest town, it offers the broadest range of services and facilities, including employment opportunities, education and transport connections. Notably, it is the only settlement classified as “highly sustainable”, which supports its designation as the primary focus for significant housing and employment development.
Concentrating growth in this area is both logical and proportionate to the town’s size, capacity and access to existing and planned infrastructure. In contrast to other parts of the district, Bexhill is not constrained by nationally designated landscapes, making it the most suitable and deliverable location for growth.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX14 Land West of Fryatts Way
The site is located on the north-western edge of Bexhill, comprising three irregularly shaped fields previously in agricultural use, well related to the existing settlement and well-contained by physical features. Access to the site is located off Fryatts Way, which will be the main vehicular access to the site.
Outline Planning Permission was granted on 6 January 2023 (ref. RR/2021/1656/P) for the following:
“Erection of up to 210 residential dwellings (including up to 30% affordable housing), introduction of structural planting and landscaping, informal public open space and children's play area, surface water flood mitigation, vehicular access point and associated ancillary works. All matters to be reserved with the exception of the main site access.”
Subsequently, the Reserved Matters application was approved on 24 December 2025 (ref. RR/2024/2171/P) for the following:
“Reserved matters application for the erection of 210 dwellings, pursuant to outline permission RR/2021/1656/P (allowed on appeal).”
In light of Rother District Council’s substantial identified housing need, the residential allocation of land west of Fryatts Way presents a highly deliverable opportunity to support early plan period housing delivery. The site is particularly well placed to contribute meaningfully to the Council’s trajectory, given that both Outline Planning Permission and Reserved Matters consent have already been secured. This advanced planning status enables the scheme to proceed to delivery without the delays typically associated with larger or more complex strategic allocations.
The Fryatts Way scheme provides an opportunity to secure the early delivery of a substantial number of dwellings, with the intention of bringing forward housing delivery within the first five years of the plan period. In doing so, it will contribute positively towards the Council’s target of delivering at least 7,881 homes by 2042.
This representation is submitted in support of the proposed allocation of the Land West of Fryatts Way as set out within Policy BX14. It reinforces Persimmon Homes’ firm commitment to bringing the site forward for residential development at the earliest opportunity.
Policy BX14 allocates the Land West of Fryatts Way for residential development of up to 210 dwellings, including up to 30% affordable housing. The table below summarises the criteria set out within the draft allocation, alongside our response to each requirement.
POLICY BX14 CRITERIA RESPONSE
1. Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan;
Draft policy HOU2 states that the starting point for discussion on the affordable tenure mix is as follows: 25% First Homes, 58% social/affordable rent, and 17% affordable home ownership. It does, however, recognise that the exact tenure mix shall be identified through discussions with the local authority and informed by the latest Government guidance and any relevant local Housing Need Assessment.
The approved scheme will deliver 10% Shared Ownership, 25% First Homes, and 65% affordable rent; as requested and agreed as part of the outline planning permission.
2. Deliver public open space, informal recreation areas, and a children’s play area;
Persimmon is supportive of this requirement, as demonstrated by the approved landscaping and open space scheme which wraps around the northern, southern and western edges of the site, as well as a central area of open space.
3. Retain and enhance existing hedgerows; provide additional planting, street trees and landscape management;
Persimmon is supportive of this criteria. The scheme will retain and strengthen the existing hedgerows and trees across the site and along its boundaries through targeted management and supplementary planting. This will include new areas of meadow grassland, hedgerows, street trees, and native scrub and woodland, thereby reinforcing and expanding the site’s green infrastructure.
4. Implement a Sustainable Drainage System (SuDS) with at least two stages of treatment, including
The Outline Surface Water Drainage Strategy is confirmed to demonstrate that surface water management can be delivered in a policy-compliant manner to include two stages of treatment to intercept and treat surface water run-off.
POLICY BX14 CRITERIA RESPONSE maintenance and management arrangements;
5. Provide biodiversity enhancements and a Landscape and Ecological Management Plan;
The requirement to provide biodiversity enhancements and a Landscape and Ecological Management Plan (LEMP) is fully supported. These matters are already secured through Condition 21 of the Outline Planning Permission; as such, the development will deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
6. Implement a Construction Environment Management Plan and Construction Management Plan addressing biodiversity, pollution prevention, air quality, noise mitigation, and contamination risks;
The requirement to provide a Construction Environment Management Plan is fully supported. These matters are already secured through Condition 12 of the Outline Planning Permission. As such, the development can deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
7. Undertake an archaeological investigation, including post-investigation assessment, and provide mitigation if necessary;
The requirement to provide an archaeological investigation, including post-investigation assessment, is fully supported. These matters are already secured through Condition 6 of the Outline Planning Permission. As such, the development is capable of delivering these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
8. Provide a sustainable transport package including contributions towards Digital Demand Responsive Transport (DDRT), pedestrian improvements, and reasonable endeavours to establish a car club for a minimum of three years;
The requirement to provide a sustainable transport package, including contributions towards Digital Demand Responsive Transport (DDRT), is supported. The planning obligation includes a contribution towards DDRT.
9. Implement highway works necessary to secure safe site access and protect the strategic highway network;
The requirement to secure safe site access and protect the strategic highway network is fully supported. These matters have already been addressed throughout the planning approval process.
10. Be designed to allow for a vehicular and pedestrian access through the southern boundary to link to adjoining land subject to allocation Policy BX15 of this Plan.
The approved scheme facilitates potential future pedestrian and active travel links to the adjacent land to the south via pedestrian.
The approved development proposals will be delivered in accordance with the policy’s intended strategic and movement objectives.
As demonstrated in the table above, the approved scheme is compliant with the draft allocation and therefore supports the allocation being carried forward into the new Local Plan.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX20 Land off Spindlewood Drive, Bexhill
The site is allocated for 160 dwellings including 30% affordable, through Policy BEX9 of the DaSA Local Plan. It is also subject to Outline Planning Permission for 160 dwellings (ref. RR/2017/1705/P). An application for approval of Reserved Matters for 146 dwellings is currently under consideration (ref. RR/2023/1202/P).
The site is therefore reallocated under Policy BX20 for residential development comprising approximately 146 new dwellings, reflecting the scheme now being progressed.
On behalf of Persimmon Homes, it is put forward that the site is suitable, available and achievable for development, with the intention of bringing forward housing delivery early within the plan period. As such, the site’s continued allocation and its inclusion within the emerging Local Plan is supported.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX21 Land north of Barnhorn Manor Caravan Park, Bexhill
The site lies immediately west of land identified under Policy BX20 and is being promoted by Persimmon Homes. This allocation proposes for residential development of approximately 20 dwellings at a density (indicative) of 40 dph. However, it is considered that the site has the capacity to accommodate at least 30 dwellings when assessed against the proposed density objectives and efficient land use principles.
The site is well related to the built confines of Bexhill and represents a logical and sustainable extension to the western edge of the settlement. It benefits from good access to a range of day-to-day services and facilities, supporting its suitability for residential development.
In the context of the significant housing need within Rother District, as set out above, it is essential that all suitable and available sites are brought forward and allocated to ensure a robust and deliverable development strategy.
The Council must seek to maximise delivery by making effective use of all appropriate sites. On this basis, Persimmon Homes support the proposed allocation of at Land north of Barnhorn Manor Caravan Park, including existing allocated land west of Spindlewood Drive.
Summary
This representation is submitted in continued support of the proposed allocation of the Land West of Fryatts Way (Policy BX14), Land off Spindlewood Drive (Policy BX20), and Land north of Barnhorn Manor Caravan Park (Policy BX21) reaffirming the landowner’s firm commitment to bringing these sites forward for residential development at the earliest opportunity.

This representation has been prepared on behalf of Persimmon Homes South East in response to the Rother District Council (‘RDC’ or ‘the Council’) Development Strategy and Site Allocations (Regulation 18) consultation, which runs until 23 March 2026.
RDC is preparing a new Local Plan to set out a strategy for development across the District for the period to 2042. Once adopted, the new Local Plan will update and replace Rother’s Core Strategy (2014) and Development and Site Allocations (2019) Plans.
This Regulation 18 consultation now seeks views on the proposed site allocations which have been identified to deliver the updated spatial strategy and some area-specific policies related to the options for strategic growth.
The purpose of this representation is to support the growth identified for Bexhill and in particular the inclusion of ‘Land west of Fryatts Way’ (draft Policy BX14), ‘Land off Spindlewood Drive’ (draft Policy BX20) and ‘Land north of Barnhorn Manor Caravan Park’ (draft Policy BX21) which are being delivered by Persimmon Homes as set out below. It seeks to comment on the scope of the draft policies and on the proposed spatial strategy more generally.
Housing Land Supply
The number of homes identified as new and updated draft allocations has increased considerably since the April 2024 consultation, rising from 2,129 to 5,051 dwellings. This brings the total housing figure for the Plan period accounting for all sources of supply to 8,427 homes over the 17-year Plan period, equating to 495 dpa.
This is recognised to be a considerable increase in potential housing supply when compared to the adopted Core Strategy figure (355 dpa). However, at the time of writing, the Government’s standard method figure for Rother sets a minimum target of 912 homes per annum, equating to a Plan period need of 15,504 homes. The Framework is clear that the standard method figure should be used to determine the minimum number of homes
needed, along with any needs that cannot be met within neighbouring areas which should also be taken into account in establishing the amount of housing to be planned for.
Even without accounting for unmet needs from neighbouring authorities, at this stage the Local Plan would underdeliver annually by 417 homes, resulting in a shortfall of some 7,077 homes across the Plan period. This is even before a suggested minimum buffer of 5% for non-implementation is included, which would result in a shortfall of 775 dwellings.
Therefore, we urge the Council to take each and every opportunity to allocate suitable sites.
Spatial Strategy - Bexhill
The proposed spatial strategy is strongly supported, particularly in identifying West and North Bexhill as the main areas for growth. This approach strengthens the role of Bexhill-on-Sea as the district’s most sustainable settlement. As the largest town, it offers the broadest range of services and facilities, including employment opportunities, education and transport connections. Notably, it is the only settlement classified as “highly sustainable”, which supports its designation as the primary focus for significant housing and employment development.
Concentrating growth in this area is both logical and proportionate to the town’s size, capacity and access to existing and planned infrastructure. In contrast to other parts of the district, Bexhill is not constrained by nationally designated landscapes, making it the most suitable and deliverable location for growth.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX14 Land West of Fryatts Way
The site is located on the north-western edge of Bexhill, comprising three irregularly shaped fields previously in agricultural use, well related to the existing settlement and well-contained by physical features. Access to the site is located off Fryatts Way, which will be the main vehicular access to the site.
Outline Planning Permission was granted on 6 January 2023 (ref. RR/2021/1656/P) for the following:
“Erection of up to 210 residential dwellings (including up to 30% affordable housing), introduction of structural planting and landscaping, informal public open space and children's play area, surface water flood mitigation, vehicular access point and associated ancillary works. All matters to be reserved with the exception of the main site access.”
Subsequently, the Reserved Matters application was approved on 24 December 2025 (ref. RR/2024/2171/P) for the following:
“Reserved matters application for the erection of 210 dwellings, pursuant to outline permission RR/2021/1656/P (allowed on appeal).”
In light of Rother District Council’s substantial identified housing need, the residential allocation of land west of Fryatts Way presents a highly deliverable opportunity to support early plan period housing delivery. The site is particularly well placed to contribute meaningfully to the Council’s trajectory, given that both Outline Planning Permission and Reserved Matters consent have already been secured. This advanced planning status enables the scheme to proceed to delivery without the delays typically associated with larger or more complex strategic allocations.
The Fryatts Way scheme provides an opportunity to secure the early delivery of a substantial number of dwellings, with the intention of bringing forward housing delivery within the first five years of the plan period. In doing so, it will contribute positively towards the Council’s target of delivering at least 7,881 homes by 2042.
This representation is submitted in support of the proposed allocation of the Land West of Fryatts Way as set out within Policy BX14. It reinforces Persimmon Homes’ firm commitment to bringing the site forward for residential development at the earliest opportunity.
Policy BX14 allocates the Land West of Fryatts Way for residential development of up to 210 dwellings, including up to 30% affordable housing. The table below summarises the criteria set out within the draft allocation, alongside our response to each requirement.
POLICY BX14 CRITERIA RESPONSE
1. Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan;
Draft policy HOU2 states that the starting point for discussion on the affordable tenure mix is as follows: 25% First Homes, 58% social/affordable rent, and 17% affordable home ownership. It does, however, recognise that the exact tenure mix shall be identified through discussions with the local authority and informed by the latest Government guidance and any relevant local Housing Need Assessment.
The approved scheme will deliver 10% Shared Ownership, 25% First Homes, and 65% affordable rent; as requested and agreed as part of the outline planning permission.
2. Deliver public open space, informal recreation areas, and a children’s play area;
Persimmon is supportive of this requirement, as demonstrated by the approved landscaping and open space scheme which wraps around the northern, southern and western edges of the site, as well as a central area of open space.
3. Retain and enhance existing hedgerows; provide additional planting, street trees and landscape management;
Persimmon is supportive of this criteria. The scheme will retain and strengthen the existing hedgerows and trees across the site and along its boundaries through targeted management and supplementary planting. This will include new areas of meadow grassland, hedgerows, street trees, and native scrub and woodland, thereby reinforcing and expanding the site’s green infrastructure.
4. Implement a Sustainable Drainage System (SuDS) with at least two stages of treatment, including
The Outline Surface Water Drainage Strategy is confirmed to demonstrate that surface water management can be delivered in a policy-compliant manner to include two stages of treatment to intercept and treat surface water run-off.
POLICY BX14 CRITERIA RESPONSE maintenance and management arrangements;
5. Provide biodiversity enhancements and a Landscape and Ecological Management Plan;
The requirement to provide biodiversity enhancements and a Landscape and Ecological Management Plan (LEMP) is fully supported. These matters are already secured through Condition 21 of the Outline Planning Permission; as such, the development will deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
6. Implement a Construction Environment Management Plan and Construction Management Plan addressing biodiversity, pollution prevention, air quality, noise mitigation, and contamination risks;
The requirement to provide a Construction Environment Management Plan is fully supported. These matters are already secured through Condition 12 of the Outline Planning Permission. As such, the development can deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
7. Undertake an archaeological investigation, including post-investigation assessment, and provide mitigation if necessary;
The requirement to provide an archaeological investigation, including post-investigation assessment, is fully supported. These matters are already secured through Condition 6 of the Outline Planning Permission. As such, the development is capable of delivering these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
8. Provide a sustainable transport package including contributions towards Digital Demand Responsive Transport (DDRT), pedestrian improvements, and reasonable endeavours to establish a car club for a minimum of three years;
The requirement to provide a sustainable transport package, including contributions towards Digital Demand Responsive Transport (DDRT), is supported. The planning obligation includes a contribution towards DDRT.
9. Implement highway works necessary to secure safe site access and protect the strategic highway network;
The requirement to secure safe site access and protect the strategic highway network is fully supported. These matters have already been addressed throughout the planning approval process.
10. Be designed to allow for a vehicular and pedestrian access through the southern boundary to link to adjoining land subject to allocation Policy BX15 of this Plan.
The approved scheme facilitates potential future pedestrian and active travel links to the adjacent land to the south via pedestrian.
The approved development proposals will be delivered in accordance with the policy’s intended strategic and movement objectives.
As demonstrated in the table above, the approved scheme is compliant with the draft allocation and therefore supports the allocation being carried forward into the new Local Plan.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX20 Land off Spindlewood Drive, Bexhill
The site is allocated for 160 dwellings including 30% affordable, through Policy BEX9 of the DaSA Local Plan. It is also subject to Outline Planning Permission for 160 dwellings (ref. RR/2017/1705/P). An application for approval of Reserved Matters for 146 dwellings is currently under consideration (ref. RR/2023/1202/P).
The site is therefore reallocated under Policy BX20 for residential development comprising approximately 146 new dwellings, reflecting the scheme now being progressed.
On behalf of Persimmon Homes, it is put forward that the site is suitable, available and achievable for development, with the intention of bringing forward housing delivery early within the plan period. As such, the site’s continued allocation and its inclusion within the emerging Local Plan is supported.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX21 Land north of Barnhorn Manor Caravan Park, Bexhill
The site lies immediately west of land identified under Policy BX20 and is being promoted by Persimmon Homes. This allocation proposes for residential development of approximately 20 dwellings at a density (indicative) of 40 dph. However, it is considered that the site has the capacity to accommodate at least 30 dwellings when assessed against the proposed density objectives and efficient land use principles.
The site is well related to the built confines of Bexhill and represents a logical and sustainable extension to the western edge of the settlement. It benefits from good access to a range of day-to-day services and facilities, supporting its suitability for residential development.
In the context of the significant housing need within Rother District, as set out above, it is essential that all suitable and available sites are brought forward and allocated to ensure a robust and deliverable development strategy.
The Council must seek to maximise delivery by making effective use of all appropriate sites. On this basis, Persimmon Homes support the proposed allocation of at Land north of Barnhorn Manor Caravan Park, including existing allocated land west of Spindlewood Drive.
Summary
This representation is submitted in continued support of the proposed allocation of the Land West of Fryatts Way (Policy BX14), Land off Spindlewood Drive (Policy BX20), and Land north of Barnhorn Manor Caravan Park (Policy BX21) reaffirming the landowner’s firm commitment to bringing these sites forward for residential development at the earliest opportunity.

This representation has been prepared on behalf of Persimmon Homes South East in response to the Rother District Council (‘RDC’ or ‘the Council’) Development Strategy and Site Allocations (Regulation 18) consultation, which runs until 23 March 2026.
RDC is preparing a new Local Plan to set out a strategy for development across the District for the period to 2042. Once adopted, the new Local Plan will update and replace Rother’s Core Strategy (2014) and Development and Site Allocations (2019) Plans.
This Regulation 18 consultation now seeks views on the proposed site allocations which have been identified to deliver the updated spatial strategy and some area-specific policies related to the options for strategic growth.
The purpose of this representation is to support the growth identified for Bexhill and in particular the inclusion of ‘Land west of Fryatts Way’ (draft Policy BX14), ‘Land off Spindlewood Drive’ (draft Policy BX20) and ‘Land north of Barnhorn Manor Caravan Park’ (draft Policy BX21) which are being delivered by Persimmon Homes as set out below. It seeks to comment on the scope of the draft policies and on the proposed spatial strategy more generally.
Housing Land Supply
The number of homes identified as new and updated draft allocations has increased considerably since the April 2024 consultation, rising from 2,129 to 5,051 dwellings. This brings the total housing figure for the Plan period accounting for all sources of supply to 8,427 homes over the 17-year Plan period, equating to 495 dpa.
This is recognised to be a considerable increase in potential housing supply when compared to the adopted Core Strategy figure (355 dpa). However, at the time of writing, the Government’s standard method figure for Rother sets a minimum target of 912 homes per annum, equating to a Plan period need of 15,504 homes. The Framework is clear that the standard method figure should be used to determine the minimum number of homes
needed, along with any needs that cannot be met within neighbouring areas which should also be taken into account in establishing the amount of housing to be planned for.
Even without accounting for unmet needs from neighbouring authorities, at this stage the Local Plan would underdeliver annually by 417 homes, resulting in a shortfall of some 7,077 homes across the Plan period. This is even before a suggested minimum buffer of 5% for non-implementation is included, which would result in a shortfall of 775 dwellings.
Therefore, we urge the Council to take each and every opportunity to allocate suitable sites.
Spatial Strategy - Bexhill
The proposed spatial strategy is strongly supported, particularly in identifying West and North Bexhill as the main areas for growth. This approach strengthens the role of Bexhill-on-Sea as the district’s most sustainable settlement. As the largest town, it offers the broadest range of services and facilities, including employment opportunities, education and transport connections. Notably, it is the only settlement classified as “highly sustainable”, which supports its designation as the primary focus for significant housing and employment development.
Concentrating growth in this area is both logical and proportionate to the town’s size, capacity and access to existing and planned infrastructure. In contrast to other parts of the district, Bexhill is not constrained by nationally designated landscapes, making it the most suitable and deliverable location for growth.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX14 Land West of Fryatts Way
The site is located on the north-western edge of Bexhill, comprising three irregularly shaped fields previously in agricultural use, well related to the existing settlement and well-contained by physical features. Access to the site is located off Fryatts Way, which will be the main vehicular access to the site.
Outline Planning Permission was granted on 6 January 2023 (ref. RR/2021/1656/P) for the following:
“Erection of up to 210 residential dwellings (including up to 30% affordable housing), introduction of structural planting and landscaping, informal public open space and children's play area, surface water flood mitigation, vehicular access point and associated ancillary works. All matters to be reserved with the exception of the main site access.”
Subsequently, the Reserved Matters application was approved on 24 December 2025 (ref. RR/2024/2171/P) for the following:
“Reserved matters application for the erection of 210 dwellings, pursuant to outline permission RR/2021/1656/P (allowed on appeal).”
In light of Rother District Council’s substantial identified housing need, the residential allocation of land west of Fryatts Way presents a highly deliverable opportunity to support early plan period housing delivery. The site is particularly well placed to contribute meaningfully to the Council’s trajectory, given that both Outline Planning Permission and Reserved Matters consent have already been secured. This advanced planning status enables the scheme to proceed to delivery without the delays typically associated with larger or more complex strategic allocations.
The Fryatts Way scheme provides an opportunity to secure the early delivery of a substantial number of dwellings, with the intention of bringing forward housing delivery within the first five years of the plan period. In doing so, it will contribute positively towards the Council’s target of delivering at least 7,881 homes by 2042.
This representation is submitted in support of the proposed allocation of the Land West of Fryatts Way as set out within Policy BX14. It reinforces Persimmon Homes’ firm commitment to bringing the site forward for residential development at the earliest opportunity.
Policy BX14 allocates the Land West of Fryatts Way for residential development of up to 210 dwellings, including up to 30% affordable housing. The table below summarises the criteria set out within the draft allocation, alongside our response to each requirement.
POLICY BX14 CRITERIA RESPONSE
1. Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan;
Draft policy HOU2 states that the starting point for discussion on the affordable tenure mix is as follows: 25% First Homes, 58% social/affordable rent, and 17% affordable home ownership. It does, however, recognise that the exact tenure mix shall be identified through discussions with the local authority and informed by the latest Government guidance and any relevant local Housing Need Assessment.
The approved scheme will deliver 10% Shared Ownership, 25% First Homes, and 65% affordable rent; as requested and agreed as part of the outline planning permission.
2. Deliver public open space, informal recreation areas, and a children’s play area;
Persimmon is supportive of this requirement, as demonstrated by the approved landscaping and open space scheme which wraps around the northern, southern and western edges of the site, as well as a central area of open space.
3. Retain and enhance existing hedgerows; provide additional planting, street trees and landscape management;
Persimmon is supportive of this criteria. The scheme will retain and strengthen the existing hedgerows and trees across the site and along its boundaries through targeted management and supplementary planting. This will include new areas of meadow grassland, hedgerows, street trees, and native scrub and woodland, thereby reinforcing and expanding the site’s green infrastructure.
4. Implement a Sustainable Drainage System (SuDS) with at least two stages of treatment, including
The Outline Surface Water Drainage Strategy is confirmed to demonstrate that surface water management can be delivered in a policy-compliant manner to include two stages of treatment to intercept and treat surface water run-off.
POLICY BX14 CRITERIA RESPONSE maintenance and management arrangements;
5. Provide biodiversity enhancements and a Landscape and Ecological Management Plan;
The requirement to provide biodiversity enhancements and a Landscape and Ecological Management Plan (LEMP) is fully supported. These matters are already secured through Condition 21 of the Outline Planning Permission; as such, the development will deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
6. Implement a Construction Environment Management Plan and Construction Management Plan addressing biodiversity, pollution prevention, air quality, noise mitigation, and contamination risks;
The requirement to provide a Construction Environment Management Plan is fully supported. These matters are already secured through Condition 12 of the Outline Planning Permission. As such, the development can deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
7. Undertake an archaeological investigation, including post-investigation assessment, and provide mitigation if necessary;
The requirement to provide an archaeological investigation, including post-investigation assessment, is fully supported. These matters are already secured through Condition 6 of the Outline Planning Permission. As such, the development is capable of delivering these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
8. Provide a sustainable transport package including contributions towards Digital Demand Responsive Transport (DDRT), pedestrian improvements, and reasonable endeavours to establish a car club for a minimum of three years;
The requirement to provide a sustainable transport package, including contributions towards Digital Demand Responsive Transport (DDRT), is supported. The planning obligation includes a contribution towards DDRT.
9. Implement highway works necessary to secure safe site access and protect the strategic highway network;
The requirement to secure safe site access and protect the strategic highway network is fully supported. These matters have already been addressed throughout the planning approval process.
10. Be designed to allow for a vehicular and pedestrian access through the southern boundary to link to adjoining land subject to allocation Policy BX15 of this Plan.
The approved scheme facilitates potential future pedestrian and active travel links to the adjacent land to the south via pedestrian.
The approved development proposals will be delivered in accordance with the policy’s intended strategic and movement objectives.
As demonstrated in the table above, the approved scheme is compliant with the draft allocation and therefore supports the allocation being carried forward into the new Local Plan.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX20 Land off Spindlewood Drive, Bexhill
The site is allocated for 160 dwellings including 30% affordable, through Policy BEX9 of the DaSA Local Plan. It is also subject to Outline Planning Permission for 160 dwellings (ref. RR/2017/1705/P). An application for approval of Reserved Matters for 146 dwellings is currently under consideration (ref. RR/2023/1202/P).
The site is therefore reallocated under Policy BX20 for residential development comprising approximately 146 new dwellings, reflecting the scheme now being progressed.
On behalf of Persimmon Homes, it is put forward that the site is suitable, available and achievable for development, with the intention of bringing forward housing delivery early within the plan period. As such, the site’s continued allocation and its inclusion within the emerging Local Plan is supported.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX21 Land north of Barnhorn Manor Caravan Park, Bexhill
The site lies immediately west of land identified under Policy BX20 and is being promoted by Persimmon Homes. This allocation proposes for residential development of approximately 20 dwellings at a density (indicative) of 40 dph. However, it is considered that the site has the capacity to accommodate at least 30 dwellings when assessed against the proposed density objectives and efficient land use principles.
The site is well related to the built confines of Bexhill and represents a logical and sustainable extension to the western edge of the settlement. It benefits from good access to a range of day-to-day services and facilities, supporting its suitability for residential development.
In the context of the significant housing need within Rother District, as set out above, it is essential that all suitable and available sites are brought forward and allocated to ensure a robust and deliverable development strategy.
The Council must seek to maximise delivery by making effective use of all appropriate sites. On this basis, Persimmon Homes support the proposed allocation of at Land north of Barnhorn Manor Caravan Park, including existing allocated land west of Spindlewood Drive.
Summary
This representation is submitted in continued support of the proposed allocation of the Land West of Fryatts Way (Policy BX14), Land off Spindlewood Drive (Policy BX20), and Land north of Barnhorn Manor Caravan Park (Policy BX21) reaffirming the landowner’s firm commitment to bringing these sites forward for residential development at the earliest opportunity.

This representation has been prepared on behalf of Persimmon Homes South East in response to the Rother District Council (‘RDC’ or ‘the Council’) Development Strategy and Site Allocations (Regulation 18) consultation, which runs until 23 March 2026.
RDC is preparing a new Local Plan to set out a strategy for development across the District for the period to 2042. Once adopted, the new Local Plan will update and replace Rother’s Core Strategy (2014) and Development and Site Allocations (2019) Plans.
This Regulation 18 consultation now seeks views on the proposed site allocations which have been identified to deliver the updated spatial strategy and some area-specific policies related to the options for strategic growth.
The purpose of this representation is to support the growth identified for Bexhill and in particular the inclusion of ‘Land west of Fryatts Way’ (draft Policy BX14), ‘Land off Spindlewood Drive’ (draft Policy BX20) and ‘Land north of Barnhorn Manor Caravan Park’ (draft Policy BX21) which are being delivered by Persimmon Homes as set out below. It seeks to comment on the scope of the draft policies and on the proposed spatial strategy more generally.
Housing Land Supply
The number of homes identified as new and updated draft allocations has increased considerably since the April 2024 consultation, rising from 2,129 to 5,051 dwellings. This brings the total housing figure for the Plan period accounting for all sources of supply to 8,427 homes over the 17-year Plan period, equating to 495 dpa.
This is recognised to be a considerable increase in potential housing supply when compared to the adopted Core Strategy figure (355 dpa). However, at the time of writing, the Government’s standard method figure for Rother sets a minimum target of 912 homes per annum, equating to a Plan period need of 15,504 homes. The Framework is clear that the standard method figure should be used to determine the minimum number of homes
needed, along with any needs that cannot be met within neighbouring areas which should also be taken into account in establishing the amount of housing to be planned for.
Even without accounting for unmet needs from neighbouring authorities, at this stage the Local Plan would underdeliver annually by 417 homes, resulting in a shortfall of some 7,077 homes across the Plan period. This is even before a suggested minimum buffer of 5% for non-implementation is included, which would result in a shortfall of 775 dwellings.
Therefore, we urge the Council to take each and every opportunity to allocate suitable sites.
Spatial Strategy - Bexhill
The proposed spatial strategy is strongly supported, particularly in identifying West and North Bexhill as the main areas for growth. This approach strengthens the role of Bexhill-on-Sea as the district’s most sustainable settlement. As the largest town, it offers the broadest range of services and facilities, including employment opportunities, education and transport connections. Notably, it is the only settlement classified as “highly sustainable”, which supports its designation as the primary focus for significant housing and employment development.
Concentrating growth in this area is both logical and proportionate to the town’s size, capacity and access to existing and planned infrastructure. In contrast to other parts of the district, Bexhill is not constrained by nationally designated landscapes, making it the most suitable and deliverable location for growth.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX14 Land West of Fryatts Way
The site is located on the north-western edge of Bexhill, comprising three irregularly shaped fields previously in agricultural use, well related to the existing settlement and well-contained by physical features. Access to the site is located off Fryatts Way, which will be the main vehicular access to the site.
Outline Planning Permission was granted on 6 January 2023 (ref. RR/2021/1656/P) for the following:
“Erection of up to 210 residential dwellings (including up to 30% affordable housing), introduction of structural planting and landscaping, informal public open space and children's play area, surface water flood mitigation, vehicular access point and associated ancillary works. All matters to be reserved with the exception of the main site access.”
Subsequently, the Reserved Matters application was approved on 24 December 2025 (ref. RR/2024/2171/P) for the following:
“Reserved matters application for the erection of 210 dwellings, pursuant to outline permission RR/2021/1656/P (allowed on appeal).”
In light of Rother District Council’s substantial identified housing need, the residential allocation of land west of Fryatts Way presents a highly deliverable opportunity to support early plan period housing delivery. The site is particularly well placed to contribute meaningfully to the Council’s trajectory, given that both Outline Planning Permission and Reserved Matters consent have already been secured. This advanced planning status enables the scheme to proceed to delivery without the delays typically associated with larger or more complex strategic allocations.
The Fryatts Way scheme provides an opportunity to secure the early delivery of a substantial number of dwellings, with the intention of bringing forward housing delivery within the first five years of the plan period. In doing so, it will contribute positively towards the Council’s target of delivering at least 7,881 homes by 2042.
This representation is submitted in support of the proposed allocation of the Land West of Fryatts Way as set out within Policy BX14. It reinforces Persimmon Homes’ firm commitment to bringing the site forward for residential development at the earliest opportunity.
Policy BX14 allocates the Land West of Fryatts Way for residential development of up to 210 dwellings, including up to 30% affordable housing. The table below summarises the criteria set out within the draft allocation, alongside our response to each requirement.
POLICY BX14 CRITERIA RESPONSE
1. Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan;
Draft policy HOU2 states that the starting point for discussion on the affordable tenure mix is as follows: 25% First Homes, 58% social/affordable rent, and 17% affordable home ownership. It does, however, recognise that the exact tenure mix shall be identified through discussions with the local authority and informed by the latest Government guidance and any relevant local Housing Need Assessment.
The approved scheme will deliver 10% Shared Ownership, 25% First Homes, and 65% affordable rent; as requested and agreed as part of the outline planning permission.
2. Deliver public open space, informal recreation areas, and a children’s play area;
Persimmon is supportive of this requirement, as demonstrated by the approved landscaping and open space scheme which wraps around the northern, southern and western edges of the site, as well as a central area of open space.
3. Retain and enhance existing hedgerows; provide additional planting, street trees and landscape management;
Persimmon is supportive of this criteria. The scheme will retain and strengthen the existing hedgerows and trees across the site and along its boundaries through targeted management and supplementary planting. This will include new areas of meadow grassland, hedgerows, street trees, and native scrub and woodland, thereby reinforcing and expanding the site’s green infrastructure.
4. Implement a Sustainable Drainage System (SuDS) with at least two stages of treatment, including
The Outline Surface Water Drainage Strategy is confirmed to demonstrate that surface water management can be delivered in a policy-compliant manner to include two stages of treatment to intercept and treat surface water run-off.
POLICY BX14 CRITERIA RESPONSE maintenance and management arrangements;
5. Provide biodiversity enhancements and a Landscape and Ecological Management Plan;
The requirement to provide biodiversity enhancements and a Landscape and Ecological Management Plan (LEMP) is fully supported. These matters are already secured through Condition 21 of the Outline Planning Permission; as such, the development will deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
6. Implement a Construction Environment Management Plan and Construction Management Plan addressing biodiversity, pollution prevention, air quality, noise mitigation, and contamination risks;
The requirement to provide a Construction Environment Management Plan is fully supported. These matters are already secured through Condition 12 of the Outline Planning Permission. As such, the development can deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
7. Undertake an archaeological investigation, including post-investigation assessment, and provide mitigation if necessary;
The requirement to provide an archaeological investigation, including post-investigation assessment, is fully supported. These matters are already secured through Condition 6 of the Outline Planning Permission. As such, the development is capable of delivering these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
8. Provide a sustainable transport package including contributions towards Digital Demand Responsive Transport (DDRT), pedestrian improvements, and reasonable endeavours to establish a car club for a minimum of three years;
The requirement to provide a sustainable transport package, including contributions towards Digital Demand Responsive Transport (DDRT), is supported. The planning obligation includes a contribution towards DDRT.
9. Implement highway works necessary to secure safe site access and protect the strategic highway network;
The requirement to secure safe site access and protect the strategic highway network is fully supported. These matters have already been addressed throughout the planning approval process.
10. Be designed to allow for a vehicular and pedestrian access through the southern boundary to link to adjoining land subject to allocation Policy BX15 of this Plan.
The approved scheme facilitates potential future pedestrian and active travel links to the adjacent land to the south via pedestrian.
The approved development proposals will be delivered in accordance with the policy’s intended strategic and movement objectives.
As demonstrated in the table above, the approved scheme is compliant with the draft allocation and therefore supports the allocation being carried forward into the new Local Plan.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX20 Land off Spindlewood Drive, Bexhill
The site is allocated for 160 dwellings including 30% affordable, through Policy BEX9 of the DaSA Local Plan. It is also subject to Outline Planning Permission for 160 dwellings (ref. RR/2017/1705/P). An application for approval of Reserved Matters for 146 dwellings is currently under consideration (ref. RR/2023/1202/P).
The site is therefore reallocated under Policy BX20 for residential development comprising approximately 146 new dwellings, reflecting the scheme now being progressed.
On behalf of Persimmon Homes, it is put forward that the site is suitable, available and achievable for development, with the intention of bringing forward housing delivery early within the plan period. As such, the site’s continued allocation and its inclusion within the emerging Local Plan is supported.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX21 Land north of Barnhorn Manor Caravan Park, Bexhill
The site lies immediately west of land identified under Policy BX20 and is being promoted by Persimmon Homes. This allocation proposes for residential development of approximately 20 dwellings at a density (indicative) of 40 dph. However, it is considered that the site has the capacity to accommodate at least 30 dwellings when assessed against the proposed density objectives and efficient land use principles.
The site is well related to the built confines of Bexhill and represents a logical and sustainable extension to the western edge of the settlement. It benefits from good access to a range of day-to-day services and facilities, supporting its suitability for residential development.
In the context of the significant housing need within Rother District, as set out above, it is essential that all suitable and available sites are brought forward and allocated to ensure a robust and deliverable development strategy.
The Council must seek to maximise delivery by making effective use of all appropriate sites. On this basis, Persimmon Homes support the proposed allocation of at Land north of Barnhorn Manor Caravan Park, including existing allocated land west of Spindlewood Drive.
Summary
This representation is submitted in continued support of the proposed allocation of the Land West of Fryatts Way (Policy BX14), Land off Spindlewood Drive (Policy BX20), and Land north of Barnhorn Manor Caravan Park (Policy BX21) reaffirming the landowner’s firm commitment to bringing these sites forward for residential development at the earliest opportunity.

This representation has been prepared on behalf of Persimmon Homes South East in response to the Rother District Council (‘RDC’ or ‘the Council’) Development Strategy and Site Allocations (Regulation 18) consultation, which runs until 23 March 2026.
RDC is preparing a new Local Plan to set out a strategy for development across the District for the period to 2042. Once adopted, the new Local Plan will update and replace Rother’s Core Strategy (2014) and Development and Site Allocations (2019) Plans.
This Regulation 18 consultation now seeks views on the proposed site allocations which have been identified to deliver the updated spatial strategy and some area-specific policies related to the options for strategic growth.
The purpose of this representation is to support the growth identified for Bexhill and in particular the inclusion of ‘Land west of Fryatts Way’ (draft Policy BX14), ‘Land off Spindlewood Drive’ (draft Policy BX20) and ‘Land north of Barnhorn Manor Caravan Park’ (draft Policy BX21) which are being delivered by Persimmon Homes as set out below. It seeks to comment on the scope of the draft policies and on the proposed spatial strategy more generally.
Housing Land Supply
The number of homes identified as new and updated draft allocations has increased considerably since the April 2024 consultation, rising from 2,129 to 5,051 dwellings. This brings the total housing figure for the Plan period accounting for all sources of supply to 8,427 homes over the 17-year Plan period, equating to 495 dpa.
This is recognised to be a considerable increase in potential housing supply when compared to the adopted Core Strategy figure (355 dpa). However, at the time of writing, the Government’s standard method figure for Rother sets a minimum target of 912 homes per annum, equating to a Plan period need of 15,504 homes. The Framework is clear that the standard method figure should be used to determine the minimum number of homes
needed, along with any needs that cannot be met within neighbouring areas which should also be taken into account in establishing the amount of housing to be planned for.
Even without accounting for unmet needs from neighbouring authorities, at this stage the Local Plan would underdeliver annually by 417 homes, resulting in a shortfall of some 7,077 homes across the Plan period. This is even before a suggested minimum buffer of 5% for non-implementation is included, which would result in a shortfall of 775 dwellings.
Therefore, we urge the Council to take each and every opportunity to allocate suitable sites.
Spatial Strategy - Bexhill
The proposed spatial strategy is strongly supported, particularly in identifying West and North Bexhill as the main areas for growth. This approach strengthens the role of Bexhill-on-Sea as the district’s most sustainable settlement. As the largest town, it offers the broadest range of services and facilities, including employment opportunities, education and transport connections. Notably, it is the only settlement classified as “highly sustainable”, which supports its designation as the primary focus for significant housing and employment development.
Concentrating growth in this area is both logical and proportionate to the town’s size, capacity and access to existing and planned infrastructure. In contrast to other parts of the district, Bexhill is not constrained by nationally designated landscapes, making it the most suitable and deliverable location for growth.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX14 Land West of Fryatts Way
The site is located on the north-western edge of Bexhill, comprising three irregularly shaped fields previously in agricultural use, well related to the existing settlement and well-contained by physical features. Access to the site is located off Fryatts Way, which will be the main vehicular access to the site.
Outline Planning Permission was granted on 6 January 2023 (ref. RR/2021/1656/P) for the following:
“Erection of up to 210 residential dwellings (including up to 30% affordable housing), introduction of structural planting and landscaping, informal public open space and children's play area, surface water flood mitigation, vehicular access point and associated ancillary works. All matters to be reserved with the exception of the main site access.”
Subsequently, the Reserved Matters application was approved on 24 December 2025 (ref. RR/2024/2171/P) for the following:
“Reserved matters application for the erection of 210 dwellings, pursuant to outline permission RR/2021/1656/P (allowed on appeal).”
In light of Rother District Council’s substantial identified housing need, the residential allocation of land west of Fryatts Way presents a highly deliverable opportunity to support early plan period housing delivery. The site is particularly well placed to contribute meaningfully to the Council’s trajectory, given that both Outline Planning Permission and Reserved Matters consent have already been secured. This advanced planning status enables the scheme to proceed to delivery without the delays typically associated with larger or more complex strategic allocations.
The Fryatts Way scheme provides an opportunity to secure the early delivery of a substantial number of dwellings, with the intention of bringing forward housing delivery within the first five years of the plan period. In doing so, it will contribute positively towards the Council’s target of delivering at least 7,881 homes by 2042.
This representation is submitted in support of the proposed allocation of the Land West of Fryatts Way as set out within Policy BX14. It reinforces Persimmon Homes’ firm commitment to bringing the site forward for residential development at the earliest opportunity.
Policy BX14 allocates the Land West of Fryatts Way for residential development of up to 210 dwellings, including up to 30% affordable housing. The table below summarises the criteria set out within the draft allocation, alongside our response to each requirement.
POLICY BX14 CRITERIA RESPONSE
1. Provide a policy-compliant amount of on-site affordable housing in line with policy HOU2 of the Rother Local Plan;
Draft policy HOU2 states that the starting point for discussion on the affordable tenure mix is as follows: 25% First Homes, 58% social/affordable rent, and 17% affordable home ownership. It does, however, recognise that the exact tenure mix shall be identified through discussions with the local authority and informed by the latest Government guidance and any relevant local Housing Need Assessment.
The approved scheme will deliver 10% Shared Ownership, 25% First Homes, and 65% affordable rent; as requested and agreed as part of the outline planning permission.
2. Deliver public open space, informal recreation areas, and a children’s play area;
Persimmon is supportive of this requirement, as demonstrated by the approved landscaping and open space scheme which wraps around the northern, southern and western edges of the site, as well as a central area of open space.
3. Retain and enhance existing hedgerows; provide additional planting, street trees and landscape management;
Persimmon is supportive of this criteria. The scheme will retain and strengthen the existing hedgerows and trees across the site and along its boundaries through targeted management and supplementary planting. This will include new areas of meadow grassland, hedgerows, street trees, and native scrub and woodland, thereby reinforcing and expanding the site’s green infrastructure.
4. Implement a Sustainable Drainage System (SuDS) with at least two stages of treatment, including
The Outline Surface Water Drainage Strategy is confirmed to demonstrate that surface water management can be delivered in a policy-compliant manner to include two stages of treatment to intercept and treat surface water run-off.
POLICY BX14 CRITERIA RESPONSE maintenance and management arrangements;
5. Provide biodiversity enhancements and a Landscape and Ecological Management Plan;
The requirement to provide biodiversity enhancements and a Landscape and Ecological Management Plan (LEMP) is fully supported. These matters are already secured through Condition 21 of the Outline Planning Permission; as such, the development will deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
6. Implement a Construction Environment Management Plan and Construction Management Plan addressing biodiversity, pollution prevention, air quality, noise mitigation, and contamination risks;
The requirement to provide a Construction Environment Management Plan is fully supported. These matters are already secured through Condition 12 of the Outline Planning Permission. As such, the development can deliver these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
7. Undertake an archaeological investigation, including post-investigation assessment, and provide mitigation if necessary;
The requirement to provide an archaeological investigation, including post-investigation assessment, is fully supported. These matters are already secured through Condition 6 of the Outline Planning Permission. As such, the development is capable of delivering these outcomes in accordance with both the condition and the emerging Local Plan policy framework.
8. Provide a sustainable transport package including contributions towards Digital Demand Responsive Transport (DDRT), pedestrian improvements, and reasonable endeavours to establish a car club for a minimum of three years;
The requirement to provide a sustainable transport package, including contributions towards Digital Demand Responsive Transport (DDRT), is supported. The planning obligation includes a contribution towards DDRT.
9. Implement highway works necessary to secure safe site access and protect the strategic highway network;
The requirement to secure safe site access and protect the strategic highway network is fully supported. These matters have already been addressed throughout the planning approval process.
10. Be designed to allow for a vehicular and pedestrian access through the southern boundary to link to adjoining land subject to allocation Policy BX15 of this Plan.
The approved scheme facilitates potential future pedestrian and active travel links to the adjacent land to the south via pedestrian.
The approved development proposals will be delivered in accordance with the policy’s intended strategic and movement objectives.
As demonstrated in the table above, the approved scheme is compliant with the draft allocation and therefore supports the allocation being carried forward into the new Local Plan.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX20 Land off Spindlewood Drive, Bexhill
The site is allocated for 160 dwellings including 30% affordable, through Policy BEX9 of the DaSA Local Plan. It is also subject to Outline Planning Permission for 160 dwellings (ref. RR/2017/1705/P). An application for approval of Reserved Matters for 146 dwellings is currently under consideration (ref. RR/2023/1202/P).
The site is therefore reallocated under Policy BX20 for residential development comprising approximately 146 new dwellings, reflecting the scheme now being progressed.
On behalf of Persimmon Homes, it is put forward that the site is suitable, available and achievable for development, with the intention of bringing forward housing delivery early within the plan period. As such, the site’s continued allocation and its inclusion within the emerging Local Plan is supported.
Part 3, Chapter 7 – Site Allocations, Question 17 – Policy BX21 Land north of Barnhorn Manor Caravan Park, Bexhill
The site lies immediately west of land identified under Policy BX20 and is being promoted by Persimmon Homes. This allocation proposes for residential development of approximately 20 dwellings at a density (indicative) of 40 dph. However, it is considered that the site has the capacity to accommodate at least 30 dwellings when assessed against the proposed density objectives and efficient land use principles.
The site is well related to the built confines of Bexhill and represents a logical and sustainable extension to the western edge of the settlement. It benefits from good access to a range of day-to-day services and facilities, supporting its suitability for residential development.
In the context of the significant housing need within Rother District, as set out above, it is essential that all suitable and available sites are brought forward and allocated to ensure a robust and deliverable development strategy.
The Council must seek to maximise delivery by making effective use of all appropriate sites. On this basis, Persimmon Homes support the proposed allocation of at Land north of Barnhorn Manor Caravan Park, including existing allocated land west of Spindlewood Drive.
Summary
This representation is submitted in continued support of the proposed allocation of the Land West of Fryatts Way (Policy BX14), Land off Spindlewood Drive (Policy BX20), and Land north of Barnhorn Manor Caravan Park (Policy BX21) reaffirming the landowner’s firm commitment to bringing these sites forward for residential development at the earliest opportunity.

Please see attached:

- Catesby Strategic Land and Rurban Estates - BX36 - Representation
- Appendices Part 1
- Appendices Part 2

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

- Representation Document
- Appendices Part 1
- Appendices Part 2

LOCAL PLAN REPRESENTATIONS IN RELATION TO LAND SOUTH OF BARNHORN ROAD,
BEXHILL – DRAFT ALLOCATION BX22

These representations are submitted by Bidwells LLP on behalf of Richborough, the promoter of Land
South of Barnhorn Road, Bexhill (the site). Richborough is promoting the site through the emerging Rother
Local Plan process.

Richborough’s objective is to bring forward a comprehensively planned, residential-led development that
responds positively to the site’s opportunities and constraints. This submission is accompanied by a Vision
Document showing how the site could be developed (enclosed). This explains how a high-quality urban
extension to West Bexhill can be delivered, supported by strong walking, cycling and public transport
connections, landscape and ecological enhancement, and the infrastructure necessary to support a
sustainable new community. The Vision Document also demonstrates that development can be structured
in a way that retains and enhances important landscape features, respects the setting of nearby heritage
assets, and responds appropriately to the relationship with the Pevensey Levels.

The purpose of these representations is therefore to respond to the draft allocation and associated policy
framework, and to explain how Richborough propose to deliver development on the site in a manner
consistent with the emerging Local Plan objectives. In doing so, the representations are intended to assist
the Council in refining the allocation, confirming its deliverability, and ensuring that the site can make an
effective contribution towards meeting housing and wider development needs in Bexhill and across the
district.

Please see attached representations and site Vision Document.

Re: Concerns regarding the Rother District Council Local Plan Consultation

I am writing to submit my response to the draft Rother Local Plan and share some of the concerns raised with me by constituents, many of which I share. Far too often existing residents are asked to support more housing locally when they are not provided with the infrastructure that should come with it. Their access to public services like GP appointments is already challenging – they reasonably ask why they should welcome developments that will make it worse?

Given that the majority of constituents will have submitted their comments directly to Rother, I will not comment on each and every site which has been brought to my attention. As mentioned, the common concern is that current infrastructure – roads/transport, schools, access to primary healthcare and utilities – is already stretched across the district and cannot accommodate the scale and location of proposed development. Constituents are also concerned about the impact on the environment, flood risks and protection of the High Weald AONB and Pevensey from further development.

Infrastructure must be the starting point of any sustainable planning strategy. At present, residents feel that the proposed allocations are being driven by the Government’s housing targets, rather than a realistic assessment of what the area can safely and responsibly support. On that basis, I have written to the Housing Minister to highlight the challenges for Rother to deliver an unrealistic housing target within the tight constraints of available land given well over 80% is protected by AONB or SSSI status. I am also aware that as our housing targets are raised, the Government is lowering the targets for house building in London because they say they aren’t realistic. They aren’t realistic for our area either. There are specific concerns about the impact on the A259 of proposed housing development in West Bexhill. I share those concerns and I am supportive of any plans for a new road which would alleviate the volume of traffic in Little Common which is already a heavily used route and will be more so if further housing is delivered in this part of the town.

In Sidley, I share the community’s concerns about site BEX50 – Sidley Car Park, which has been identified for a possible 10 homes. Whilst I fully understand the need for quality housing in Sidley, I consider that losing parking spaces in this free car park would be bad for local businesses and would impact the hard work which has been done in recent years by East Sussex ounty Council and All Saints School to create
a road safety scheme. Parents are no longer permitted to drive into Saints Lane at school drop off and pick up times so use Sidley car park. The school also runs ‘walking bus’ from the car park to the school gates.

In addition to concerns raised about infrastructure, the following have also been noted:

1. Sites in Battle – proposed BT7 off North Trade Road would sit on flood zones. General concerns about further development in Battle include worsening of congestion on already heavily-used roads, consideration of ancient and historic woodland, Battle cannot support additional population pressure and traffic – its high street being regularly congested and heavy vehicles causing damage to ancient buildings.

2. North Bexhill (BA3) – overdevelopment of green space without supporting infrastructure.

3. Netherfield (GYP4) temporary sites being granted permanent status sets a precedent that people can purchase plots and commence development without planning permission I look forward to your response to the above concerns and how these will be taken forward in future versions of the Local Plan.

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.

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.

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.

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.

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

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

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

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.