8. 8 We are pleased to see that the overall development strategy does not draw a line under its development requirement of 7,881 dwellings to 2042 and states that this will be the ‘minimum’ number over the plan period. Therefore, the strategy should not limit itself to allocating sites just to meet that number. If a site is a suitable site for development in accordance with the development strategy, then it should be included as an allocation without any arbitrary limit to numbers.

The strategy looks to focus growth on broad locations or clusters and we welcome the inclusion of the Hastings Fringes as one of these to provide sensitive growth. Having settled on this strategy it is important to emphasise that the level of growth neds to be enough to support new and existing facilities and services for both new and existing residents as set out in the strategy. As noted above the development requirement is a minimum and allocations and growth should not be implemented on the basis of just meeting the numbers. The allocations and intended growth should follow the development strategy throughout and allocate enough to ensure broad growth locations can become more sustainable for both existing and new residents.

We welcome the approach proposed to development within the High Weald National Landscape. As 83% of the District is covered by the National Landscape it forms an important part of the character of Rother and its settlements. Therefore, rather than avoiding development it should be embraced and form an essential part of its future conservation. This inevitably means development allocations, but existing settlements help to define the special landscape that makes up the National Landscape and sensitive sustainable growth of settlements will help to retain that character into the future.

9. The overall growth strategy provides the road map for where the District will grow to 2042. As part of this strategy a ‘minimum’ of 7,881 dwellings will be needed. Unfortunately, the specific number of dwellings attributed to the sub areas seems to have been dictated by the minimum number not the growth strategy. The overall strategy is to grow these areas sustainably and so any site that is deemed to be suitable and meet that objective should be included regardless of the impact on the total number of dwellings. This is the reason the growth strategy specifies the 7,881 figure is a minimum number.

As it stands the sub areas have been allocated growth to solely meet the 7,881-dwelling figure. It is highly unlikely that if the overall growth strategy was followed that the total figure would match exactly the minimum number of dwellings that are required. We think that the Council should review how it has come up with the figures attributed to the sub areas and re-apply them in line with the principles of the growth strategy rather than engineering them to fit the minimum required dwelling figures.

Contrary to what the policy says it has done to attribute growth, there are a number of sites that are in the HELAA that are available and have seemingly been left out solely on the basis of the minimum figure of housing already having been met. These sites are similar to those currently allocated and can contribute to the overall sustainability of, in particular, urban fringe settlements for both existing and new residents. It would also support the soundness of the overall development strategy.
11. The policy states that “Where greater opportunities for development arise in larger, more sustainable villages, residential development will enable enhancement to public realm and community facilities. Growth will also help support existing facilities and services in the village, ensuring health and wellbeing and community cohesion is maintained and improved.” This seems to follow the overall growth strategy for Rother, but then the strategy states that “There is potential to deliver 382 dwellings.” This is a very specific amount and appears to be driven by meeting a minimum dwelling target for the district as a whole rather than follow the growth strategy.

Development should not be restricted to an arbitrary number. The strategy should instead state “There is potential to deliver a minimum of 382 dwellings.” Villages noted as having higher growth potential due to facilities such as primary schools should not be restricted to minimum numbers just because it fits with the target. The overall strategy and this Southern Rother and Hastings Fringe Strategy is clear that growth in these area should support sustainability and help to enhance existing and new facilities and services.

Icklesham is a good example, where there is an existing primary school, pub and bus service. New development will help to retain the school, support the pub and contribute to the local bus service as well as provide opportunities to provide new facilities and services into the future. There are some sites that are of similar availability and deliverability to the proposed allocated sites in the village. These should be allocated as well so that they can contribute to the growth strategies rather than restrict the village to an arbitrary minimum number.
32. Policy IK1
The proposed site allocation is adjacent to the built-up area on the southern side of the A259 road, is within the National Landscape but relatively well enclosed, is accessed directly off of the A259, and has the ability to provide onsite green infrastructure, and can provide approximately 26 dwellings.

This is no different to the adjacent site ICK0002 known as Land at Seven Acres. The Sustainability Appraisal provides a very similar assessment to both sites as shown below: (image)
If this site is deemed suitable for allocation then there is no reason why Seven Acres should be deemed unsuitable for development, particularly given that it has several advantages over this site including being closer to the school, no need for altering the existing bus stop, and there is more land available that can provide an opportunity to improve the existing footpath and formally enhance public access to the fields to the south. It also has enough land to meet BNG requirements on site, mitigating any landscape impact of new dwellings.
35. The site known as Seven Acres in the Council’s HELAA (ICK0002) is an ideal site to be included as an allocation. As noted earlier in our representations, apportionment of growth should not be restricted to the minimum dwelling numbers that are being proposed. This should be a minimum and good sites that will contribute to the overall growth strategy and sustainability of settlements should be included regardless of overarching dwelling numbers.

Seven Acres is located in a sustainable location adjoining the built-up area boundary of the settlement of Icklesham. It is approximately 5 km from Rye to the east and 8 km from Hasting to the south west. In terms of transport links the site is located directly onto the A259 main trunk road that links Rye with Hastings. There is a bus stop adjacent to the site that provides a regular hourly bus service to Hastings and Rye (Number 70 and Number 100). The site is also in relatively close proximity to both Winchelsea railway station (approx. 3.5km) and Doleman railway station (approx. 4km) that provides rail services across the south coast and connections to Hastings and London.
The site is located within the High Weald National Landscape, however there would be minimal impact on the wider landscape as it sits in the backdrop of the village and the A259 to the north which would be less sensitive to visual change, particularly the north and west of the site.

There is a footpath that runs across the site from the north eastern corner to the south western corner. It is proposed that this would be incorporated into any proposed development and enhanced.

The main part of the site is currently low-grade agricultural land, and taking in to account the location and the prevailing character of the site and surroundings, it is considered that there is an opportunity for the land to be used more efficiently and effectively, to meet Council’s objectives and the needs of the District in a sympathetic manner which is fully compliant with all levels of Planning Policy.

The site by virtue of its sustainable location adjacent to Icklesham village and the A259 with its excellent transport links provides very good opportunities for new residential development. The site lends itself to a sensitive residential scheme on the northern and western parts of the site with the density of development falling away to the south. The plan below shows the potentially developable area in purple stretching across the north and west of the site along the A259 replicating the development patterns to the north. The red arrow indicates the optimum location for a new access into the site from a highway visibility and safety point of view, with the blue arrow indicating an alternative or secondary potential access point.
Development would be in the least sensitive parts of the site within the backdrop of the existing built-up silhouette of the village to the north and the A259. It would provide the opportunity to increase the housing stock in the village, but it would also represent an opportunity to enhance the current footpath and accessible green space available to the village. The site has a footpath that runs through it and used by many of the local community. The development of this site would represent an opportunity to retain and enhance this footpath and formalise accessible green space for existing and new residents across the south of the site (coloured in green on the plan above). This would minimise impact of development on the National Landscape and footpath and also provide a new rural recreational area for the village.

We have assessed the site in relation to the draft regulation 19 policies and the overall growth strategy. It is large enough to accommodate up to approximately 25 dwellings at the ‘village area’ density of 35dph whilst also including a substantial area of land for informal open space and meeting all on site Biodiversity Net Gain requirements. It would provide the opportunity to improve the footpath and public access for existing residents and the new. It would also contribute to the overall sustainability of existing facilities and services such as the pub and the current bus services.

The site is in a single ownership and is available immediately.

The owner is working up a more detailed plan for the development of the site that will be landscape led, it is hopeful that a pre-application will be submitted to the Council in the coming months to discuss details.

The site is ready to be delivered and should be included as an allocation to meet the overall growth strategy for the District and Local area.

See attached.

See attached.

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.