HG4 - Our first point, is that to find out by chance what is in effect 24 hours before, to respond to this planning consultation is disingenuous and undemocratic.

The village of Hurst Green is already reeling from the very recent arrogant implementation of a traffic light scheme at Station Road by the Highways Agency, despite a village vote to pause the scheme for re evaluation. This now only adds to our frustration.

The current facilities in the village will not support an additional 150 houses. There is no GP, no dentist, no pharmacy, no supermarket, no secondary school or safe walking route to Etchingham station.

That is aside from the ongoing problem with the volume and speed of traffic passing through the village and the dire need for a roundabout at Coopers Corner - a junction we use daily. With a minimum of an extra 150 cars in the village this can only further increase the volume of traffic. It can take 10-15 minutes to access the A21 at Coopers Corner in the summer as this is the only direct route from London to the coast.

We believe that Hurst Green is the only village in the UK to have a village school on a main 'A' road, which in itself causes traffic problems. If this scheme is allowed to proceed it will only further increase the dangers experienced daily by the village.

We were impressed by the work the Parish Council put into a Housing Needs Assessment in 2019 followed by a Parish survey. The needs assessment we understand has already been met by existing permissions and it directly contradicts Hurst Green's Neighbourhood Plan which was passed as recently as November 2025. We understand that if this development goes ahead it will mean a total of 239 new homes in Hurst Green. It appears the thoughts of the Parish Council and the inhabitants of a small village situated on a very busy 'A' road (with, it now appears, no funding available for its proposed bypass) have been ignored and Hurst Green has been included in a district-wide housing number which is not relevant to the location and sustainability of its infrastructure let alone proposing a development on greenfield countryside.

How long have discussions been going on between the owners of the land and the planning department and why did it only appear in the District Council's Local Plan in January 2026? Has there been any published evidence of a need for 150 new homes in Hurst Green, has there been a settlement-level study, has there been a local housing needs survey?

We do not agree with the proposed development strategy.
Either stop this proposed development, or put in a bypass.

As a mum of three at different school stages, I’m looking to put down roots in a place where every generation of our family can thrive. HG4 offers that opportunity for Hurst Green. It’s a well‑located, plan‑led site that can deliver mixed‑tenure family homes alongside accessible bungalows and adaptable plots — so grandparents can live nearby, and we can support each other. Its design can create safe, walkable routes to local schools, play spaces, and everyday services, reducing car dependence and helping older children become more independent. With timely, secured infrastructure — school places, primary care capacity, active‑travel links, and reliable bus services — HG4 is both deliverable and genuinely sustainable. Its scale can support real community assets, from green corridors to safe cycling that ties into village networks. For families like ours, stability matters. HG4 provides the right homes in the right place, strengthening Hurst Green’s community for the long term.

I'm a resident of Hurst Green. I'm not happy with the plans. I can see that HG1 and HG2 have been approved by the council to go ahead to start the build. There are already new houses built near HG3 - won't it be too close for comfort, safety and access for cars etc; spoils the landscape/ views etc. HG4 - 150 houses?? Too many houses for the village- spoil the character of the village in the countryside. This is not practical and not needed. This is not a town- It's a village. All of these houses are accessed via A21 which will cause more traffic especially with the traffic lights being installed on the junction. No amenities in the village- one shop that is not really a shop. No GP surgery. Primary school has got a waiting list to accept new pupils which is not ideal.

Land at The Lodge offers a realistic way to address one of the most damaging long‑term issues in Hurst Green: the dominance of through‑traffic over village life. The Community Housing Survey of 2019 summed this problem up bluntly when residents said they were “too afraid to walk anywhere” because of constant traffic, and that the village had slipped into feeling more like a “drive‑through than a community.” That statement still reflects daily experience for many people here. The situation has not improved with time; if anything, it has become more entrenched.

The Emerging Local Plan sets out a clear intention to create settlements that are sustainable, balanced, and not wholly dependent on car travel for every basic need. HG4 fits directly within that aspiration. It is not growth for its own sake. It is a chance to start rebuilding the conditions that allow normal village life to function again — places to walk to, reasons to stay in the village rather than drive straight out of it, and a local population base strong enough to support small services that residents have repeatedly said they want.

The location of HG4 helps make this possible. Positioned within the natural structure of the village, it brings new homes close to existing routes and central facilities rather than pushing development to the edges. More households living in this area would help create the activity, footfall, and sense of presence needed to counteract the hollowing effect that years of heavy through‑traffic have had on Hurst Green. This is how local shops, health‑related services, and community‑focused facilities start to become viable again — not by waiting for them to appear, but by creating the conditions that make their return sustainable.

HG4 also aligns with the recently approved Hurst Green Neighbourhood Plan, which was shaped directly by residents and reflects their expressed priorities. The HGNP is very clear about the type of development the village supports: modest, well‑placed housing that strengthens community life, improves walkability, and supports the return of essential services. HG4 is exactly the kind of careful provision envisioned in that plan. Allowing it to progress is, in effect, honouring the outcome of a democratic local process that residents took time and effort to participate in.

What stands out most to me is that HG4 responds to concerns residents have raised consistently since 2019. It helps reduce reliance on car travel by encouraging walking. It places growth where it actively supports village life rather than stretching it. It offers new homes for people who want to stay in Hurst Green and contributes to restoring the sense of a lived‑in, connected community. This is growth that reinforces local character instead of eroding it.

The scale of HG4 is measured and proportionate. It respects the surrounding landscape while acknowledging the reality that the village cannot revitalise itself without some level of planned, well‑considered development.

Hurst Green does not have the infrastructure to support a site of this scale, almost a 25% increase in dwellings in the village. The village has no GPS or dentists, one tiny shop and a school that is at or near capacity already. The one public car park in the village next to the village hall has room for 28 cars and is almost always full. The major trunk road going through the village creates major issues for existing residents without more vehicle movement adding to the burden. With little employment opportunities within the village and surrounding area there will be a large increase in commuting and although there is a main line station 2-3 miles away there is no public transport from Hurst Green to the station which will mean using private cars or risk walking on a road without pavements to access.
Note the village has had three major water pipe bursts recently which has left the village without water for days and not sure that South East water can reliably supply the proposed housing. Also concern on the mental wellbeing not only of existing residents but prospective new residents in an already fractured community that struggles with day to day living around the A21, as the current roadworks show, and lack of infrastructure to support daily life.
The site is outside the development boundary does not comply with Hurst Green Neighbourhood plan and apart from being in the High Weald National Landscape is rich in archaeological interest being part of the ancient manor of Iridge.

Sites HG4 and HG 1 are inappropriate in size and scope for Hurst Green. They should be removed from the Plan.
There is no data given as to why Hurst Green requires so many houses.
There is little regard for the local environment, especially trees, CO2 emissions and night time erosion by extra lighting. This latter in turn impacts the nocturnal fauna, further degrading the environment

As a dad with older children, someone who travels to work from just north of the river, and having spent many years working at Bedgebury, I want to express my strong support for the HG4 allocation in the Regulation 18 plan for Rother. My family didn’t grow up here, but we know the area well, rely on local services, and genuinely value the chance to put down long‑term roots in a community that needs thoughtful, sustainable growth.

HG4 uses the land responsibly and supports a balanced mix of homes for different ages and needs. It helps meet clear demand from working families and older children who want to stay connected to the area. Its proximity to essential services, public transport, and work opportunities also supports reduced car use — something that matters when commuting patterns already cross the river daily.

I support the allocation of HG4 because it reflects the clear national and local evidence that more housing is needed to ensure rural communities remain viable. Rother District’s own assessments, alongside responses to the 2019 Community Survey, show that younger households in particular are struggling to access suitable homes within the district. Without planned, well‑located development, this trend will continue, and villages like Hurst Green will lose the very residents who sustain their services and community life.

The Emerging Local Plan is explicit about locating new housing where it can be supported by existing infrastructure. Hurst Green is a strong example of this: it benefits from established road connections, proximity to rail services, and a layout that allows new development to integrate into the settlement pattern. HG4 fits this approach. It represents a site that can deliver homes at a meaningful scale, in a location capable of supporting day‑to‑day activity without encouraging isolated or car‑dependent growth.

HG4 also carries clear community benefit. The allocation provides scope for family housing, improved pedestrian links, safer movement through the village, and the delivery of accessible green space — all priorities raised through the Hurst Green Neighbourhood Plan consultations. Development of this scale is also one of the few mechanisms for securing the funding required to address long‑standing infrastructure concerns, including highway safety and access improvements. Smaller schemes have repeatedly struggled to deliver these outcomes.

This allocation is proportionate, deliverable, and aligned with both local and national planning objectives. It supports housing need, strengthens existing services, and ensures that Hurst Green remains a sustainable rural settlement capable of meeting the needs of current and future residents.

For these reasons, I strongly support the inclusion of HG4: Land at The Lodge in the Emerging Local Plan.

Dear Sir/Madam
Re: Representation to the Regulation 18 Consultation on the Rother Local Plan 2025-2042
HURST GREEN SITE ALLOCATIONS: HG1–HG4
1. Introduction
This representation is submitted in response to the Regulation 18 consultation on the emerging
Rother Local Plan, speciGically in relation to the proposed site allocations for Hurst Green (HG1–
HG4).
It is submitted on behalf of the Chair of CPRE Sussex, the Sussex branch of the Campaign to
Protect Rural England.
This response should be read alongside CPRE Sussex’s wider representation on the Local Plan. It
focuses speciGically on the proposed allocations for Hurst Green, where particular concerns arise
regarding scale, sustainability, and impact on the High Weald National Landscape.
2. Status of the Hurst Green Neighbourhood Plan [HGNP]
The HGNP:
- establishes a deGined development boundary;
- provides a clear spatial strategy for growth;
- allocates sites to meet identiGied housing need;
- has been independently examined and democratically endorsed.
In accordance with national policy, the Local Plan must have regard to the Neighbourhood Plan
and should not undermine its strategy without clear and compelling justiGication.
The proposed allocations, particularly HG3 and HG4, represent a signiGicant departure from that
strategy.
3. HG1 and HG2 – Existing Commitments
The inclusion of HG1 and HG2 is supported, as these sites beneGit from extant planning
permission and are consistent with the established development strategy for Hurst Green.
4. HG3 – Land to Rear of The Olde Bakery
The proposed allocation of HG3 is not supported due to:
- ConGlict with the Neighbourhood Plan;
- Access constraints via Pringle Close and Foundry Close;
- Surface water Glood risk;
- Landscape impact within the High Weald National Landscape.
5. HG4 – Land at The Lodge
The proposed allocation of HG4 is strongly objected to, as it does not represent genuinely
sustainable development and fails to meet the requirements for major development within a
National Landscape.
Key concerns include:
- Scale signiGicantly exceeding HGNP strategy;
- Location within the High Weald National Landscape;
- Failure to meet the major development test;
- Infrastructure and highway constraints;
- SigniGicant environmental mitigation required.
The plan does not demonstrate that less harmful or previously developed alternatives have been
exhausted before proposing development at this scale within a protected landscape.
6. BrownQield and Previously Developed Land Opportunities
There are at least two brownGield sites within Hurst Green associated with Caravan Tech:
- A larger site with workshops, storage, and sales facilities;
- A smaller storage-based site within the village.
Both lie within the development boundary and have direct A21 access.
The Plan does not demonstrate that these sites have been properly assessed or prioritised.
National policy and CPRE Sussex’s established position both emphasise the need to prioritise
previously developed land before releasing greenGield sites, particularly within protected
landscapes.
7. Community Engagement
A public consultation held on 28 February 2026 demonstrated clear and widespread opposition
to HG3 and HG4.
8. Soundness
The proposed allocations for Hurst Green raise signiGicant concerns in relation to the tests of
soundness. The Plan is not:
- Positively prepared;
- JustiGied;
- Effective;
- Consistent with national policy.
9. Conclusion
While it is recognised that Rother District Council faces signiGicant challenges in meeting
national housing requirements, this does not justify the allocation of sites that are
unsustainable, poorly evidenced, or in conGlict with the development plan.
In particular:
- HG1 and HG2 are supported as existing commitments;
- HG3 is not supported due to access, Glooding, landscape impact, and conGlict with the HGNP;
- HG4 is strongly objected to as a major greenGield allocation within the High Weald National
Landscape that is not justiGied, not demonstrated to be necessary, and not supported by
evidence of deliverability or infrastructure capacity.
The Plan should instead:
- prioritise previously developed land;
- respect the strategy established through the recently made Neighbourhood Plan;
- ensure that development is genuinely sustainable and consistent with national policy.
Without signiGicant revision, the Plan risks being found unsound.

With respect to the proposed development of " The Lodge development" it is with considerable surprise that a development has been suggested north of end of Hurst Green , as there is No requirement for an additional 150 homes in the village of Hurst Green over and above those identified in the District councils own summer plan of 2024. The location is completely unsuitable with its proximity to the A21 and A229 and will add significantly to the congestion on the A21 gridlock regularly occurs as Hurst Green is the only Village on the A21 without a bypass. The land is predominantly agricultural and any development would be against both National and Local recomendations and policies , too numerous to record in 150 words . It would appear that No due diligence has been undertaken and that whatever review has taken place has been ill informed and deliberately misleading.

I moved to Hurst Green from an area where pockets of development was rife; ill thought out; no consideration for infrastructure or additional services which resulted in fragmented communities; jammed roads and fed up residents who aren't listened to. I know HG1 and 2 are approved but I see the same thing happening if HG3&4 are agreed, too many houses built without future thought for a truly integrated village. Regardless of the lack of shops; dentists; doctors; minimal transport links and local employment opportunities, unless consideration is given to re-routing the A21, Hurst Green will remain a village of two halves - East and West A21. Coopers Corner is a poor choice for an additional 150 homes on a poor stretch of the A21

ROTHER LOCAL PLAN REGULATION 18 CONSULTATION
Your Ref: HG4
Our Ref: Land at the lodge, Hurst Green

We write to submit representations to the Regulation 18 consultation of the Rother District
Council’s “Rother Local Plan 2025-2042 – Development Strategy and Site Allocations” (hereafter
referred to as the ‘emerging Local Plan’).
These representations are submitted in relation to the site at Land at the Lodge, London Road, Hurst
Green (‘the Site’) under reference HG4.

Greymoor Homes supports the allocation of this site and has submitted a detailed representation directly to Rother District Council.

The evidence base correctly identifies that the Site is located within the High Weald National
Landscape. It goes on to confirm that whilst the site would represent a northwards extension to the village, it is generally enclosed from the wider High Weald Landscape.

We acknowledge that this would be a large allocation for development within the National
Landscape and securing appropriate mitigation and public benefit would be fundamental but we are in agreement that any proposal can be informed by a landscape sensitivity assessment to determine an appropriate layout, form and detailed design to ensure the conservation and
enhancement of the landscape and character of the High Weald National Landscape.

The High Weald AONB Management Plan expressly recognises the role that development has in the character of the National Landscape. If it correctly identifies that any adverse impacts of
development on the character and conservation purpose of the National Landscape can be
reasonably addressed by technical assessments, including Landscape and Visual Assessment (LVIA) and Design and Access Statements, alongside early consideration of the High Weald Housing Design Guide.

The evidence base distinguishes between the hierarchy of designated sites and identifies the extent of the local development needs. It seeks to take a strategic approach to the allocation of land according to its environmental and amenity value and proposes allocations that seek to address the context and extent of the need it. In this regard, the proposed allocation of the Site in the emerging Local Plan will significantly contribute to the Council’s strategy.

Greymoor Homes supports the decision to bring forward a new Local Plan in principle as the importance of creating an up-to-date Plan-led approach to planning for development cannot be understated. The Council’s Core Strategy Local Plan was adopted in 2014 and whilst it is becoming increasingly out-of-date. Many other significant planning legislative changes have occurred since its adoption.

It is notable that the revised NPPF, published in February 2025, has clearly set out the Government’s pro-growth commitment to delivering 1.5m new homes along with the critical infrastructure that underpins economic growth. This ambition is set to be one of the milestones to achieve by the end of this Parliament within the Government’s Plan for Changes.

In addition to the provision of much needed housing, the Site has the capacity to deliver publicly accessible open space for recreational opportunities for existing and future residents, further strengthening the public interest case for its allocation. Opportunities for biodiversity enhancement, alongside improved opportunities for recreational enjoyment to the wider National Landscape, would represent additional positive outcomes arising from the development.

These factors together can allow the judgement to be made that even were the development consider 'major', the necessary exceptional circumstances and public interest can be demonstrated to justify an allocation of the site within the emerging Local Plan.

In the context of the Site, its scale, location and single ownership of the Site, together with
Greymoor’s delivery capacity as a nationally established developer with a strong track record in
residential schemes, enable the Site to be immediately available and avoid the delays often
associated with large complex sites arising urban extension and new settlements. This will allow the Site to make a meaningful contribution to addressing the Council’s housing shortfall in an immediate period.

I object to the proposed plans of development in Hurst Green, particularly HG4 site. This development will simply be too large and with no provision of upgrading the local infrastructure. There are not enough school places, the local doctors are stretched to their limits and the number of dentists is dwindling.

Q2 Target unrealistic given protected High Weald National Landscape; no evidence of local housing need on the scale suggested; inadequate infrastructure for current population.
Q3 Much stronger emphasis and specific localised plans for employment opportunities needed – particularly, for example, regarding tourism, green energy development and retrofitting, sustainable farming, rural skills and crafts etc.
Q5 Before housing numbers can be determined, revised Infrastructure Delivery Plan needs to specify detailed commitments rather than targets from agencies regarding: water supply, drainage and sewerage capacity; road, rail and bus capacity; energy supplies; health infrastructure; SEN provision, community parking provision etc – to ensure whatever housing target is finally agreed can be sustained.
Hurst Green requires a bypass/relief road in order to thrive as a community economically, socially, etc.
Q7 Housing densities of 35 per hectare is too high – much higher than any other area within Hurst Green.
Q56 HG1 and HG2 already granted planning permission – 54 houses.
HG3 – as this is a relatively sustainable location close to the village centre some reduced density (35 per hectare is too high) housing could be accommodated but community parking provision should be a condition.
HG4 – this development should be rejected: 150 houses is a major development completely out of keeping with a High Weald village; it would be a prominent visual intrusion on the landscape; there is no evidence of housing need on this scale in the village; and there is insufficient infrastructure existing or committed to accommodate such a large increase in population.
The eastern boundary of the above site outlines and existing village development should be considered as a potential relief road route for Hurst Green.

The following documents are attached:
1. Response to the High Weald AONB Unit
– setting out how HG4 can be a carefully moderated, design coded, landscape led allocation with meaningful mitigation and enhancement.
2. Coopers Corner Enabling Statement
– confirming our willingness to safeguard land required for a long awaited A21/A229 safety solution, including noting multiple National Highways survey access requests to our land relating to the A21 Safety Package.
3. HG4 Retention Summary
– demonstrating HG4’s role in supporting district wide housing need, rural affordable housing, service vitality, utilities deliverability, and Local Plan soundness.
4. ESCC Transport Technical Annex
– evidencing full alignment with the County Council’s Regulation 18 transport position (active travel, bus contributions, EV readiness, construction logistics and Monitor & Manage).
Collectively, these documents set out a coherent, proportional and Reg 18 appropriate case for retaining HG4. They demonstrate:
• how HG4 can be sensitively designed within the High Weald using a site specific design code;
• why HG4 uniquely enables the Coopers Corner safety improvement, a long recognised public interest need;
• how HG4 aligns with ESCC’s sustainable transport priorities;
• and how HG4 contributes meaningfully to the Local Plan’s housing, infrastructure and soundness requirements.

[Sent by separate emails]

I do hope you are taking pride in ruining a village of outstanding natural beauty with ugly buildings on our fields without even looking at infrastructure of the village in reality to schools, traffic exhaust, gp surgeries, shopping facilities. Well done for ruining another village

Planning on A21 and Station Road Tn19 Hurst Green

Please could you explain why you are trying to decimate our village without any thought of how the residents feel
It seems you are riding roughshod over the Village without any infrastructure being put in place, not enough Primary or Secondary School places, no Doctors Surgery, no proper shopping facilities to take on board the hugely expanded population. I hope you can answer with some positive thoughts please.

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

Please see attached representation objecting to proposed site allocation HG4: Land at The Lodge, London Road, Hurst Green.

SITE HG4: LAND AT THE LODGE, HURST GREEN

Rurban Estates writes in support of allocations in Northern Rother including the proposed allocation of Site HG4.

The emerging Local Plan is being prepared in the context of a significant uplift in housing need. The standard method identifies a requirement of circa 15,500 dwellings over the plan period (c.912 per annum), compared with a current identified supply of approximately 8,400 homes. This substantial shortfall highlights the need to allocate deliverable and sustainable sites across the district, including within the villages of Northern Rother.

In this context, Site HG4 represents an important and appropriate allocation. The site:

• Forms a logical and well-related extension to Hurst Green, closely associated with the existing built form along the A21 corridor;
• Is well contained by strong, defensible boundaries, including established hedgerows, mature trees, adjoining woodland and the A21/A229, which provide a clear and durable edge to development; and
• Benefits from a parkland character which provides a robust framework for a landscape-led scheme.

The draft policy’s requirement for a landscape-led approach is supported. The site’s containment and existing landscape structure mean that development can be accommodated in a manner that conserves and enhances the character of the High Weald
National Landscape, particularly through the delivery of substantial green infrastructure and retention of key features.

The proposed residential-led mixed-use approach is also strongly supported. The inclusion of community, employment, leisure or retail uses alongside new housing will:

• Enhance the sustainability of the development;
• Support local services and facilities; and
• Contribute positively to the vitality and resilience of Hurst Green as a rural settlement.

Overall, HG4 is a sustainable, well-contained and deliverable site that can make a meaningful contribution towards addressing the district’s housing needs, while also delivering wider community benefits. The allocation should therefore be retained as part of the emerging Local Plan for Regulation 19 and subsequent submission for EiP.

See attached representations in support of site HG4.

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.