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

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.