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

Support

Representation ID: 31183

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

TWBC strongly agrees with the Objectives for the Local Plan which all include the underlying thread of sustainability in line with the requirements of the NPPF. TWBC particularly supports the improved focus on climate change mitigation and adaption in objective 1, the inclusion on ‘timely delivery of strategic and other supporting infrastructure’ in objective 7, and the inclusion of ‘including to support active travel’ in objective 8. TWBC also supports the inclusion of the new objective 11 relating to making the optimal use of land, including brownfield land, and achieving appropriate densities on sites.

Object

Representation ID: 31184

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

TWBC notes that RDCs housing need is 15,504 dwellings (921 dpa) over the plan period (using the standard method). TWBC objects to RDCs development strategy because RDC should plan to meet its full need. RDC should continue investigate all potential opportunities to increase housing provision within its plan area. Any shortfall/unmet need should be robustly justified and backed up by appropriate evidence.

TWBC notes that it has provided comments on the Vision for Northern Rother and regarding site allocations in Northern Rother in its response to question 14.

TWBC acknowledges that RDC wrote to TWBC by letter dated 4 March 2026 to request assistance in accommodating unmet housing need. TWBC is preparing its response at the time of writing.

Support

Representation ID: 31185

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

TWBC notes that the Rother Retail and Town Centre Uses Study (2023) concludes that there is no need at the district-level for new retail floorspace over 10 years, and that as a result RDC is not seeking to allocate land for new retail floorspace to meet identified need other than as part of mixed-use developments.

TWBC acknowledges that RDC has commissioned a Housing and Economic Development Needs Assessment with Hastings Borough Council which will become available later in 2026. TWBC may wish to comment further on this policy at Regulation 19 when the updated HEDNA is available.

Support

Representation ID: 31186

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

TWBC notes RDCs Gyspy and Traveller requirement is for 28 pitches and no Travelling Showpeople plots within the plan period, based on the East Sussex GTAA (2022). RDC currently has an outstanding requirement of 18 pitches across the plan period and intends to meet its own need, which TWBC supports.

RDC uses the PPTS compliant definition (as defined in December 2023). TWBC uses the broader, ethnic definition. TWBC is seeking to meet the ‘ethnic’ need to ensure that the needs of all households who ethnically identify as Gypsies and Travellers are accounted for, regardless of whether they have ceased to travel. TWBC would recommend that RDC also takes this approach in applying the ‘ethnic’ need rather.

TWBC acknowledges that the East Sussex GTAA is due to be updated during 2026 and may wish to comment further on this policy at Regulation 19.

Object

Representation ID: 31187

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

TWBC notes the updated draft IDP 2026 Parts A and B.

TWBC considers that there is a lack of reference to cross-boundary infrastructure working.

The IDP acknowledges that the A21 and A259 corridors will require capacity management and selective enhancements to accommodate forecast growth. TWBC supports the proposed A21 road safety improvement schemes but notes there is no proposed scheme to improve congestion at Flimwell junction.

TWBC requests that more information is provided on plans to support growth at Etchingham, Robertsbridge and Stonegate railway stations.

TWBC also questions the suitability of Hurst Green.

TWBC notes a lack of detail regarding how increasing secondary school place requirements will be met.

The IDP acknowledges that more than half of Rother’s population live in rural or fringe areas, where access to GP services can be more difficult. Reference should be made to cross-boundary provision of health services.

Support

Representation ID: 31188

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

TWBC notes RDC proposes to take forward new spatial development option SDO13 based on the updated HELAA findings and following its assessment in the updated Interim Sustainability Appraisal (2026). TWBC expects detail and discussion on the longterm proposals for the A21 corridor, to provide a clear understanding of what this would entail.

It would be helpful to understand more about how the A21 related options have evolved. TWBC notes that the initial preferred approach set out in the previous Regulation 18 included option ‘A21 corridor growth with a new sustainable transport corridor’. This option has been carried forward, along with the new option for development along the A21 road corridor, focussed within and around existing settlements. TWBC recognises that due to uncertainty around funding of works to support an A21 sustainable transport corridor, that RDC wishes to explore other options relating to the A21.

Support

Representation ID: 31189

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

TWBC notes the increased higher density options for different area types, which are based on the outcomes of the Density Study (2026). TWBC is supportive in principle of achieving optimal density on sites as a means of meeting local housing needs. However, RDC should continue to investigate all opportunities for increasing housing provision within the plan area with the aim of meeting the housing needs of the district.

Support

Representation ID: 31190

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

TWBC notes that the given housing target of 8,427 dwellings is less than the district’s housing requirement based on the standard method. TWBC recognises that Rother is a highly constrained district but asserts that RDC should plan to meet its full housing need. RDC should continue to apply the ‘no stone left unturned’ approach to identifying and allocating development sites.

TWBC considers that further transport and flood risk modelling are required, as the Shared Transport Evidence Base and SFRA documents are not up to date. Updates to these, and where necessary, any other supporting evidence base documents should be available for the Regulation 19 consultation.

TWBC would welcome discussion on the identified A21 growth corridor and further details of what the aspirations are for this area over the longer term. This should include ongoing engagement with Kent County Council Highways and National Highways.

Object

Representation ID: 31191

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

TWBC notes the proposed site allocations in the Northern Rother sub-area and further comments are made on this.

In general, TWBC questions whether the proposed level of growth in the Northern Rother sub-area is suitable given its existing infrastructure. The proposed level of growth in the sub-area has significantly increased above the range provided in the previous Regulation 18 consultation. This sub-area is proposed to support the second highest level of growth in the district. TWBC considers that Northern Rother is unlikely to present the same opportunities for sustainable development than Battle, and that residents will be required to utilise infrastructure outside of the district.

TWBC asserts that exceptional circumstances for allocating sites within the High Weald National Landscape should be clearly demonstrated and justified. TWBC also expects that the cumulative impact of the potential development sites are fully considered in the supporting documents.

Object

Representation ID: 31192

Received: 23/03/2026

Respondent: Tunbridge Wells Borough Council

See attached for full representation.

The Vision recognises that the residents within the sub-area are likely to use services outside of the sub-area. TWBC would therefore expect that the infrastructure requirements must be fully investigated.

Paragraph 6.84 refers to the network of village primary schools but does not mention secondary school capacity. Reference should be made to working with KCC and ESCC.

TWBC questions the vision statement that ‘local environmental impacts are lessened due to an increase in the uptake of electric vehicles and a corresponding increase in available EV charge points.’

TWBC asks that the Vision make greater reference to how RDC proposes to work with neighbouring authorities.

TWBC would welcome further discussion with RDC on the proposals for the Northern Rother sub-area.

Consideration should be given to how RDC will support sustainable travel in the case funding does not come forward for the A21 sustainable travel corridor.