Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27443

Received: 22/07/2024

Respondent: Network Rail

Network Rail note the proposed development strategy for Battle and acknowledge the
issues around sensitivities of the landscape and other constraints towards the north of the
District. In terms of the railway, as previously noted Battle has funding towards the
implementation of the early stages of an Access for All scheme to bring step free access to
the station for passengers.
Capturing new development around Battle will ensure these facilities are utilised however
it’s also likely that passengers may travel from other parts of the District to use the step
free access. Therefore, a strategy to get users to and from the station regularly should be
developed with East Sussex CC to maximise the opportunity at Battle. Where possible,
Network Rail would advocate for development to be maximised near to Battle station
albeit considering the relevant constraints.
As part of this, development ear to the station should also contribute towards improving
accessibility to the station either through improved pedestrian and cycle links or through
financial contributions towards a regular bus service or improvements at the station itself.

Comment

Representation ID: 27444

Received: 22/07/2024

Respondent: Network Rail

As another urban area supported by a mainline station, there are opportunities to
maximise development potential in Rye. Insofar as direct relationships to the railway
exist, there are two level crossings near to Rye station which could present a risk to safety
with development coming forward. Where possible, Network Rail would seek to mitigate
the risk either by increasing safety provisions or closing the crossings. This is particularly
pressing with the level crossing located close to Ferry Road. Draft site allocations close to
this crossing will increase the use of the crossing meaning further risk to safety due to
cumulative impacts of development.

Network Rail would like to work with the Council so that these allocations include any
contributions towards mitigating the level crossing risk. This would especially be the case
for sites RYE0002, 0003, 0006 and 0015 as identified within the HELAA. Any of the
currently rejected sites close to the crossing in the HELAA that may become draft
allocations should also be considered within this context. As the ultimate arbiter and
experts in railway safety, Network Rail can advise the Council on the most appropriate
course of action and strategic approach to the level crossing issues.

Comment

Representation ID: 27445

Received: 22/07/2024

Respondent: Network Rail

Network Rail support the proposal to use the two rail stations as transport hubs around
which development can be brought forward. An approach which prioritises pedestrian and
cycling access to the stations should be maximised as should the quantum and density of
development of the sites.
Network Rail note the number of rejected sites in the HELAA around the Etchingham
station. The Council should review these if insufficient sites can be found elsewhere as
they are located in a highly sustainable location. Where sites are close to the station,
Network Rail can assist the Council in identifying of there are any impacts on the station
itself and how it functions. It is noted that the views from the station, especially
northwards, are highly sensitive.
Similarly, there are some possible sites close to Robertsbridge station. Network Rail
understand the reasoning for rejecting SAL00034 however it is located in a sustainable
location albeit within a sensitive context. SAL 00015 could contribute towards improving
access to the station and providing a better linkage through to the village centre.
The longer term vision involving the A21 bypasses does present the opportunity to unlock
additional land for development however it should be reviewed robustly to ensure that
introducing new roads is justified in the current environmental climate. From a railway
perspective, this could increase the accessibility of stations in northern Rother however its
unlikely to facilitate a modal shift away from the car to public transport.

Comment

Representation ID: 27446

Received: 22/07/2024

Respondent: Network Rail

Network Rail note the proposed Policy approach in relation to GTTS. Should any proposed
sites be close to the railway, Network Rail would like to work with the Council to mitigate
the impacts of rail movements close to the sites.

Comment

Representation ID: 27447

Received: 22/07/2024

Respondent: Network Rail

Network Rail has concerns over leaving a significant proportion of delivery until later in the
plan period. This potentially risks the Plan not meeting requirements through sites not
being built out. Additionally, lengthy delays in delivery can impact on infrastructure
funding and mean that improvements may not be secured.

Comment

Representation ID: 27448

Received: 22/07/2024

Respondent: Network Rail

Network Rail support the retention of PRoW where possible however in situations where
development leads to increased use of a PRoW that crossing the railway at-grade, then
safety risks have to be considered. Network Rail do not support new PRoW which interact
with the railway either through at-grade crossings or which could lead to trespass on the
railway.

Reference to considering the impacts of PRoW on railway safety in the context of new
development should be included within the draft Policy. Network Rail can advise the
Council on appropriate safety mitigation required and the circumstances around this.
Additional analysis can also be provided to help inform the Council in relation to level
crossing safety and its impacts.

Comment

Representation ID: 27449

Received: 22/07/2024

Respondent: Network Rail

As a provider of infrastructure, Network Rail supports the intention of the draft Policy. In
regard to timing and phasing of delivery, Network Rail would encourage the use of
Grampian conditions to ensure funding for the required infrastructure is provided to
mitigate the impact of development.
Network Rail support the need for early engagement over funding and delivery of required
infrastructure. It should be for the developer to demonstrate that certain infrastructure
improvements are not required as part of a planning application and to provide evidence
for this. Network Rail review infrastructure needs regularly to identify any gaps and
funding shortfalls, and this can be communicated to the Council and developers through
an annual update of the Infrastructure Delivery Plan. Network Rail supports a robust
infrastructure policy that requires developers to fund improvements needed for
development and to do so early to ensure delivery. Securing funding through relevant
planning obligations and the Community Infrastructure Levy is supported.

Comment

Representation ID: 27450

Received: 22/07/2024

Respondent: Network Rail

Rail network in Rother

Rother district is relatively well connected with East to West and North to South rail links
however the services can be slower and would benefit from improvements. The potential
however is significant, and Network Rail are reviewing opportunities to further enhance
the rail network.
The Bexhill to Rye rail link provides access to Eastbourne and Ashford International as the
main destinations with this route being operated by Southern Railway. The northern route
connects Battle with north Kent and south London stations with a terminus at Charing
Cross.
Step free access at Battle rail station is being pursued through the Access for All
programme, with initial funding secured to carry out feasibility of a scheme. Additional
funding may be required to further the scheme and developer contributions provide a
justified source to assist in this.
Similarly, step free access improvements at Bexhill station could be made and there are
on-going discussions around a new entrance at the station. Network Rail would encourage
the Council to also support an approach towards securing developer contributions to
improving Bexhill station to allow it to accommodate the anticipated growth around
Bexhill.

Where development interacts with the railway through its proximity, Network Rail should
be consulted to ensure no adverse impacts on the railway. Additionally, any new crossings
over the railway (not at grade) such as bridges or roads that connect development should
also be designed in conjunction with Network Rail.

Summary

The rail network within Rother provides a good basis to pursue development opportunities
and to promote sustainable transport as a genuine alternative to using the car.
Network Rail supports the identification of public transport and promotion of active and
sustainable travel within the Plan. The Plan should continue to be developed, with
appropriate policies and site allocations which promote the rail network in encouraging its
usage and pursuing development opportunities.
Network Rail are keen to continue to work with the Council and other stakeholders in
helping to deliver transport and infrastructure improvements for the benefit of residents
of Rother