See attachments

See attachments

Rother Local Plan 2025 - 2042 (Regulation 18) – Representation on behalf of Jarvis Homes
(South-East) Limited
Site FW2A, Flimwell (formerly HELAA Site TIC0029 and TIC0095)

I write on behalf of Jarvis Homes (South-East) Limited in support of the allocation of Site FW2A within
the emerging Local Plan.

This representation is made in the context of a materially increased housing requirement, significant
environmental constraints across the district, and the clear need for the Council to identify robust and
deliverable sites. Against that background, the inclusion of Site FW2A is not only appropriate, but
necessary to ensure that the Plan is positively prepared, justified and capable of being found sound.

- Plan Context

In preparing this draft plan, the Council’s evidence clearly establishes a significant housing
requirement of c. 912 dwellings per annum, driven in part by the revised standard method.

In addition, the evidence base identifies a clear need to provide sufficient employment land and
floorspace to support economic growth over the plan period. National policy requires that this is
planned alongside housing delivery, ensuring that land of the right type is available in the right
locations to support a strong and responsive local economy.

At the same time, Rother faces exceptional constraints, with c. 83 per cent of the District falling within
the High Weald National Landscape, alongside extensive environmental and heritage constraints.

As acknowledged within the evidence base, this creates a clear structural tension between housing
and employment need and land availability. Contextually, it is necessary for settlements such as
Flimwell, despite their location within the National Landscape, to accommodate an appropriate
proportion of development where this can be achieved without unacceptable landscape,
environmental or heritage harm.

The Council’s evidence confirms a substantial uplift in housing and employment need, materially
exceeding historic delivery rates. At the same time, the Plan recognises that a very large proportion of
the district is subject to policy and environmental constraints, most notably the High Weald National
Landscape.

This combination of high need and constrained supply is fundamental. It requires a realistic and
balanced approach, identifying sites that are capable of delivering development without unacceptable
harm, rather than seeking idealised or unconstrained opportunities which do not exist in sufficient
quantity.

The strategy of directing growth to sustainable settlements, including Flimwell, is both logical and
necessary. Site FW2A is a key component of that strategy for both housing and employment
opportunities.

- HELAA Progression

The progression of the site from HELAA references TIC0029 (residential) and TIC0095 (employment)
to the proposed allocation FW2a is a material consideration which should be afforded full weight.

The separation of these uses at HELAA stage has been positively resolved through the draft
allocation, which brings forward a coordinated mixed-use scheme. This directly reflects the HELAA’s
conclusions that development in this location is most appropriately delivered on a comprehensive
basis, combining residential and employment uses to address sustainability and accessibility
considerations.

The HELAA methodology applies a staged filtering process, including:

• initial site identification and availability
• assessment against constraints (including landscape, heritage, access and flood risk)
• consideration of suitability and achievability
• identification of sites capable of contributing to suppl

The site has successfully progressed through each of these stages, which demonstrates that, when
assessed against the Council’s own criteria, the site is:

• not subject to overriding constraints
• capable of development in principle
• deliverable within the plan period

The subsequent site selection process has appropriately combined the residential and employment
components into a single allocation (FW2a), forming part of a wider coordinated development strategy
for Flimwell. This reflects a more effective and policy-aligned approach than considering the sites in
isolation.
This is directly relevant to the test of soundness. The Plan must demonstrate that it has selected the
most appropriate strategy and sites when considered against reasonable alternatives. In this case,
the evidence supports not only the suitability of the site, but also the appropriateness of its
comprehensive mixed-use allocation.
It is also relevant that a number of sites assessed through the HELAA process in and around Flimwell
were discounted due to greater landscape sensitivity, weaker settlement relationship, or technical
constraints. Against that context, the identification of FW2a, as part of a coordinated allocation, reflects a clear comparative advantage and reinforces that it is one of the most appropriate and
deliverable opportunities available within this part of the district.

- Site Characteristics and Settlement Integration

In spatial terms, the site forms part of a wider, coordinated extension to Flimwell, as identified through
allocation FW2. It is not a standalone parcel, but part of a comprehensive mixed-use allocation which
integrates residential, and employment uses alongside existing development. The site lies adjacent to
established built form and commercial activity, including the existing business area to the west of the
A21, and therefore represents a logical and planned expansion of the settlement rather than isolated
or sporadic encroachment into the countryside.

The presence of the A21 is an important defining feature. Whilst it currently acts as a physical barrier
within the settlement, the allocation responds positively to this through the requirement for improved
pedestrian and cycle connectivity. In this respect, the site does not rely solely on its immediate
relationship to the existing built form, but forms part of a wider strategy to better integrate the eastern
and western parts of Flimwell.

Equally important is the relative position of the site within the wider landscape context. The site does
not occupy the most sensitive or exposed parts of the surrounding countryside and is capable of
being contained within a defined edge through structural landscaping and appropriate layout. This
reflects the HELAA findings that, when considered comprehensively, the site is capable of
development without giving rise to unacceptable landscape harm.

The land itself is not subject to significant abnormal constraints and benefits from a form and
topography that lends itself to development. Access to utilities and the ability to deliver appropriate
infrastructure are implicit within the allocation framework. These are key factors identified through the
HELAA process in supporting the site’s suitability and achievability.

The draft allocation proposes a residential density of approximately 35 dwellings per hectare. In the
context of a mixed-use allocation and the need to optimise the use of land, this is considered
appropriate. It strikes a balance between efficient delivery of housing, responding to the Council’s
increased housing requirement, and maintaining a form of development that can be sensitively
integrated into the National Landscape through design, layout and landscaping.

In addition, the inclusion of employment provision within the wider FW2 allocation is a significant
benefit. The provision of employment floorspace alongside housing supports local economic growth,
reduces the need to travel, and contributes to a more sustainable pattern of development in
accordance with the strategic objectives of the emerging Local Plan.

- Landscape Considerations and National Landscape Context

The site lies within the High Weald National Landscape, and this is appropriately recognised as a key
consideration. National policy requires that great weight is given to conserving and enhancing
landscape character. However, this does not preclude development, particularly where it can be
accommodated without unacceptable harm and where it forms part of a planned and coordinated
strategy.

Paragraph 189 of the NPPF confirms that great weight should be given to conserving and enhancing
National Landscapes, and that development should be limited in scale. In this instance, the proposed
development forms part of a wider mixed-use allocation (FW2), incorporating both residential
development at approximately 35 dwellings per hectare and employment provision. When considered4
in this context, the scale and form of development are proportionate and reflect an efficient use of
land, whilst still enabling a landscape-led approach to design and layout.

Paragraph 190 of the NPPF addresses major development within National Landscapes. Whether
development constitutes “major development” is a matter of planning judgment, having regard to its
nature, scale and setting, and the extent of its impact on the purposes of the designation.

In this case, the allocation represents a coordinated extension to Flimwell rather than a standalone or
expansive incursion into the countryside. The development is contained within a defined parcel and
sits within a landscape context influenced by the A21 corridor and existing built form. On that basis, it
is not of a scale or character that would necessarily justify being treated as major development.

Without prejudice to that position, if the allocation were to be considered “major development”, the
requirements of paragraph 190(a) are met. There is a clear and significant need for both housing and
employment land, and a demonstrable constraint on land supply across the district, with a substantial
proportion of land falling within the National Landscape or subject to other environmental and heritage
designations. In these circumstances, the allocation of suitable and deliverable sites such as FW2a
forms part of a necessary and balanced response in the public interest.

The HELAA and site selection process has concluded that development in this location is achievable,
particularly when brought forward as part of a comprehensive scheme. That conclusion is supported
by the site’s characteristics and its ability to accommodate mitigation through design.

The site benefits from established boundary vegetation and the opportunity to introduce structural
landscaping as part of a coordinated scheme. The draft allocation also requires appropriate buffers,
including to areas of ancient woodland, together with a landscape-led approach to layout and design.
These measures are both necessary and capable of being delivered.

Whilst there are localised views, including from the A21 and surrounding areas, the site does not form
part of a wider open or highly sensitive landscape in longer-distance views. The influence of existing
infrastructure and development reduces its prominence and provides a context within which
development can be assimilated.

A sensitively designed mixed-use scheme, incorporating native planting, structural landscaping and
green infrastructure, will mitigate potential effects and enable the development to integrate
appropriately with both the settlement and the wider landscape.

In practical terms, this is a site where landscape effects can be appropriately managed and mitigated
through policy requirements and design, and where development can be accommodated without
undermining the character or scenic quality of the National Landscape.

- Sustainability and Connectivity

The site forms part of a wider mixed-use allocation (FW2) and its sustainability must be considered in
that comprehensive context, rather than as a standalone proposal.

It is recognised that the site lies to the east of the A21, which currently acts as a physical barrier
within Flimwell and limits direct pedestrian connectivity to existing services and facilities located to the
west. This is an identified constraint. However, the draft allocation responds positively to this through
the requirement for enhanced pedestrian and cycle connections across the A21 and into the
established part of the settlement.

In this respect, the allocation does not simply rely on existing infrastructure but provides a clear
mechanism to improve connectivity and integrate the site with the wider settlement over time. This is
consistent with the HELAA conclusions that development in this location is most appropriate when
delivered comprehensively, including measures to address accessibility.

Importantly, the mixed-use nature of the allocation materially strengthens its sustainability credentials.
The inclusion of employment provision alongside residential development reduces the need to travel,
supports local job creation, and contributes to a more balanced and self-contained pattern of
development. This is a key distinction from a purely residential extension and aligns with the strategic
objectives of the emerging Local Plan.

Flimwell is identified within the draft Local Plan as a settlement where limited and carefully planned
growth can be accommodated. The allocation of FW2 reflects a deliberate strategy to direct
development to a location where it can be planned comprehensively, rather than allowing piecemeal
or less sustainable alternatives to come forward elsewhere.

The site’s relationship to the A21 corridor also provides a degree of accessibility to the wider area,
including connections to nearby settlements. Whilst this does not substitute for local accessibility, it
forms part of the overall connectivity profile of the site.

Overall, whilst there are existing constraints in terms of connectivity, these are recognised and
appropriately addressed through the allocation. The combination of improved pedestrian and cycle
links, alongside the provision of employment uses within the site, ensures that the development can
function as a sustainable and integrated extension to Flimwell over the plan period.

- Deliverability

Jarvis Homes confirms that the site is available, free from ownership constraints and capable of
delivery within the plan period. There are no known fundamental technical or viability barriers that
would prevent the site coming forward.

The allocation forms part of a wider coordinated development (FW2), and its delivery is appropriately
framed within that comprehensive approach. Whilst infrastructure requirements, including highways
improvements and connectivity enhancements, will need to be addressed, these are clearly identified
within the draft allocation policy and are typical of developments of this scale.

The site is capable of contributing to both housing and employment delivery within the plan period.
The mixed-use nature of the allocation provides flexibility in delivery and supports a phased approach,
allowing different elements of the scheme to come forward in a coordinated but viable manner.

In this context, the allocation represents a realistic and deliverable proposal of the overall
development strategy. It is not reliant on speculative or uncertain infrastructure provision but instead
is supported by clear policy requirements that can be addressed through the planning and design
process.

Given the scale of housing and economic need, and the limited number of suitable and deliverable
sites, allocations such as FW2a are not optional components of the supply. They are integral to the
delivery of both housing and employment objectives within the Plan.

The removal or downgrading of such allocations would materially undermine the Plan’s ability to
demonstrate a deliverable and balanced supply of development
land and would create a clear risk of the Plan failing the tests of effectiveness and soundness at
examination.

- Soundness

The allocation of Site FW2A is necessary to ensure that the Plan meets the tests of soundness:

• Positively prepared: The Plan must respond to a significantly increased housing requirement,
alongside identified economic needs. Given the extensive environmental constraints across
the district, these needs cannot be met without the inclusion of coordinated mixed-use
allocations such as FW2.

• Justified: The HELAA and site selection process demonstrates that development in this
location is appropriate when delivered comprehensively. The consolidation of HELAA sites
TIC0029 and TIC0095 into a single mixed-use allocation reflects a more effective and policyaligned solution when considered against reasonable alternatives, many of which have been
discounted due to greater landscape sensitivity, weaker settlement relationship, or technical
constraints.

• Effective: The site is available and capable of delivery within the plan period as part of a
coordinated scheme. The allocation benefits from a clear policy framework, including
infrastructure and connectivity requirements, which supports a phased and deliverable
approach to both housing and employment provision.

• Consistent with national policy: The allocation supports sustainable development by
combining housing and employment uses, promoting a more balanced pattern of growth, and
making efficient use of land, in accordance with the NPPF.

In the absence of allocations such as FW2a, there is a clear risk that the Plan would fail to
demonstrate a deliverable and balanced supply of development land, undermining both its
effectiveness and overall soundness at examination.

Conclusion

Site FW2a has been identified through a robust evidence base, has progressed through the HELAA
and site selection process, and forms part of a coordinated mixed-use allocation at Flimwell.

It is capable of being delivered as part of a comprehensive scheme, accommodating development
without unacceptable landscape harm, and supported by a clear and credible delivery framework. It
will make an important contribution towards meeting both housing and employment needs within the
district.

The allocation is integral to a sound and deliverable strategy. Its removal or downgrading would
materially weaken the Plan and create a clear risk of it being found unsound at examination.

In these circumstances, Site FW2a should be retained and progressed to the Regulation 19 stage
without amendment.

Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Site at Cherry Tree Nursery, Hawkhurst Road, The Mount, Flimwell, TN5 7QL

I write on behalf of our clients, Cherry Tree Farm Investments Ltd. and Mr. David
John Harvey.

As you will be aware, we prepared representations on behalf of the above
landowners in 2024.

We have now had a chance to discuss the latest version of the Draft Local Plan and
Housing and Economic Land Availability Assessment (HELAA), and the comments
therein and the contents of the draft Local Plan (Development Strategy and Site
Allocations).

We are pleased to see that the sites are considered potentially suitable, available
and deliverable, subject to final assessment and that they have been included in the
draft local plan under policy reference FW2b (which for clarification also includes the
Weald Smokery site to the west of the Nursery; reference made here to FW2b does
not include the Smokery site as it is outside our clients’ ownership).

Our understanding is that the Local Authority’s preference is for the owners of the
various parcels of land that comprise TIC0095, TIC0029, and TIC 0097/FW2a and
FW2b to come forward together as a comprehensive development in order to
facilitate the following:

• Measures to improve the experience of walking alongside Hawkhurst Road
• Retention of the existing retail use at FW2b (The Weald Smokery) or its
replacement with a convenience store.
• Provision for a new community facility and LEAP within FW2b
• Improvements to wider pedestrian and cycle connectivity
Other requirements include a substantial area of Green Infrastructure.

FW2b is considered able to accommodate some 70 new dwellings.

On behalf of Cherry Tree Farm Investments Ltd. and Mr. Harvey, we confirm that
their land remains available and that both parties are willing to commence work with
the local authority and the neighbouring land owners.

Notwithstanding that the Authority’s preferred route is to develop FW2a alongside
FW2b, and our clients’ willingness to work with the other parties, it should be noted
that the land at Cherry Tree Nursery and the land to its rear owned by Mr Harvey
could be developed in its own right without relying on the development of FW2a. In
particular, its development is not hampered by access issues onto the A21.

A well designed scheme for the development of FW2b could quite easily incorporate
a future route through to FW2a if required.

FW2b lies a short walk from a bus stop (0.1mile to the west) and the site access off
the A268 Hawkhurst Road is established. A safe pedestrian and vehicular access
could be achieved as confirmed by the Highway Authority in response to application
reference RR/2020/174/P.

The site is not isolated as demonstrated in our earlier correspondence of July 2014
(Representations) which is attached to this letter for ease of reference.

The Authority’s published housing land supply is currently less than 3 years. It would
seem sensible to take a positive approach to developing the land at Cherry Tree
Nursery regardless of the position of other landowners.

Please see attached representations from 2024.

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.