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

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.

2. Exeter College acknowledges the Council’s proposed housing target of 8,427 dwellings (495 dwellings annually). While we recognise the significant environmental constraints facing the district - with roughly 90% of the district designated as National Landscape or protected habitat-we believe the Council should strive to meet its objectively assessed housing needs in full.
The current target of 495 dpa is a significant shortfall from the standard method figure of 912 net new homes per year. To narrow this gap, the Council must prioritize sustainable locations like Grove Farm, Robertsbridge which benefit from existing rail infrastructure and local services.
5. The Infrastructure Delivery Plan (IDP) is a vital tool for coordinating investment and achieving the goal of "Live Well Locally," however we emphasize that it must facilitate, rather than hinder, the deliverability of sustainable development including proposed allocations in the emerging Local Plan. We therefore support the IDP in principle subject to technical clarification.
While not mentioned explicitly in the IDP, it is important to ensure that the updated surface water management policies of utility providers are implemented pragmatically in Local Plan preparation and decision making. We encourage the Council to ensure these policies do not create undue barriers to development through rigid restrictions related to the consideration of drainage hierarchies, particularly as measures for drainage of surface water through measures such as infiltration are often technically unfeasible in locations like Robertsbridge due to site-specific ground conditions, and not all sites identified for allocation in the emerging plan are proximate to watercourses. Such an approach should not be used to stymie schemes at the Development Management stage on sites that have already been tested at Examination through the Site Allocations Process.
A more pragmatic approach, allowing for low, strictly managed discharge rates where it has been demonstrated that other hierarchy options have been fully exhausted, is essential to maintaining the deliverability of sustainable housing. It would not be appropriate or legally sound in our view to propose a development management policy which seeks to apply a blanket restriction to state that any surface water discharge into the foul-only network should be refused. Where appropriate, emerging allocations can provide proportionate contributions to help to mitigate infrastructure quality / capacity issues.
6. Exeter College supports the Council’s assessment of Option SDO13 (A21 corridor growth focused within and around existing larger settlements). This option provides a positive strategy for directing growth to sustainable locations like Robertsbridge/Salehurst, which already possess a reasonable level of local services. Conversely, we agree with the rejection of Option SDO14 (Development within strategic gaps), as it would likely undermine the separate identity of settlements and have an adverse impact on the National Landscape.
7. We strongly support the "Higher Density" standard (Option B) as the preferred approach. This standard is essential for ensuring the optimal use of land, especially given the district's housing shortfall. Applying Option B allows for a step-change in housing delivery while remaining sensitive to rural character. The allocation of 70 dwellings at Grove Farm Phase 2 (approx. 35 dph) is a reasonable density assumption in our view and is compatible with this approach.
8. Exeter College supports the Proposed Overall Development Strategy, which combines several sustainable spatial options including SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations).
Further to the above, to ensure the soundness of the Plan we strongly encourage the Council to confirm through its evidence base that sites such as Grove Farm that are well located and do not give to significant impacts on landscape, do not constitute ‘major development’ (as per paragraphs 189 and 190 of the NPPF). NPPF 190 says that applications for major development in the National Landscape should be refused unless exceptions apply. Footnote 67 says “major” in this context is a matter for the decision maker.
9. The target of 729 proposed new dwellings for Northern Rother settlements is considered appropriate and sustainable; therefore, we support this strategy in principle. This level of growth reflects the presence of high-quality service centres like Robertsbridge, which benefit from mainline rail connections and a range of local facilities. By directing a reasonable proportion of the district’s growth to this sub-area, the Council is effectively implementing its "Live Well Locally" priority, ensuring new residents have access to sustainable transport and social opportunities.
The proposed allocation of Grove Farm Phase 2 under Policy RB3 (approximately 70 units) makes a significant and deliverable contribution to meeting housing needs - representing roughly 10% of the total new housing target for the entire Northern Rother sub-area. Our technical studies and pre-application engagement with both Rother District Council and ESCC Highways confirm that this site is a logical extension to Robertsbridge and is capable of supporting this sub-area’s growth objectives within the plan period.
14. Exeter College expresses support for the proposed Vision for Northern Rother. We particularly endorse the focus on directing growth toward the district’s most sustainable rural settlements, such as Robertsbridge, which benefit from existing provision of essential village services and the railway station.
Exeter College supports the indicative housing figures identified for Northern Rother. The target for new allocations in this sub-area reflects a balanced approach that recognizes the capacity of sustainable settlements to accommodate growth while fulfilling the statutory duty to conserve and enhance the High Weald National Landscape.
Our technical work on land within this sub-area confirms that Northern Rother settlements have the capacity to deliver high-quality, higher-density residential schemes that optimise the use of land without causing landscape harm.
57. Please see our full responses above under Section 3 of our accompanying written Submission. In summary, while we support the proposed residential site allocation of land at Grove Farm Phase 2, we object specifically to Site Requirement 3 in respect of the approach to site access.
The site requirements should not preclude the option of a dedicated primary access point off George Hill to ensure that the proposed allocation is deliverable without the need for third party land. Our engagement with statutory consultees including the highways authority confirm that this stipulation is not necessary and should therefore be removed from the list of site requirements.
66. Exeter College supports the principles of Policy LWL7 (Streets for All) where they facilitate safe, inclusive, and sustainable transport patterns. For Policy RB3 (Grove Farm Phase 2), the implementation of this policy involves providing high-quality pedestrian and cycle infrastructure to link effectively with George Hill and Fair Lane.
Exeter College maintains that its preferred strategy for a dedicated, standalone vehicular access point off George Hill is the most effective way to deliver the "Streets for All" objectives for this site. Technical engagement with ESCC Highways has confirmed that such a standalone access is feasible in principle.
68. We support the findings of the Interim Sustainability Appraisal (January 2026), specifically the preferred spatial development strategy. We strongly endorse the Council’s decision to pursue options which support development coming forward at Robertsbridge, such as SDO4 (Sustainable settlement extensions) and SDO11 (Growth in settlements with railway stations or sustainable transport alternatives).
Robertsbridge is a highly sustainable location, and Land at Grove Farm (Phase 2) is a logical extension that sits within easy walking distance of essential village services and the mainline railway station. This approach aligns with the Local Plan’s "Live Well Locally" priority by directing growth to areas where sustainable transport links and accessibility to social opportunities are already established.
In conclusion, Exeter College expresses overarching support for the proposed allocation of Land
at Grove Farm (Phase 2) under Policy RB3. The site is a deliverable and sustainable extension
to Robertsbridge, capable of providing approximately 70 new homes alongside generous open
space, enhanced walking and cycling links and biodiversity improvements.
This support is subject to the technical clarifications provided in Section 3, most notably the
request to amend the access strategy to allow for a dedicated primary access point off George
Hill to ensure the site's independent deliverability.
We look forward to engaging with the Council on the Proposed Submission version of the Local
Plan and participating in the 'Regulation 19' stage of consultation, which we understand is
expected to take place in Summer 2026.