Planning Committee



15th June 2022


Report by:

Director of Communities, Economy and Transport


Title of Report

Traffic Regulation Order – A2100 London Road, Battle


Purpose of Report

To consider the objections received in response to the formal consultation on the draft Traffic Regulation Order associated with the development of Lillybank Farm, London Road, Battle.



Contact Officer:   


Mark Weston – 01273 482242


Local Member:


Councillor Kathryn Field





The Planning Committee is recommended to:


1.    Not uphold the objections to the draft Order as summarised in paragraph 2.2 of this report


2.    Recommend to the Director of Communities, Economy and Transport that the draft Traffic Regulation Order be made as advertised.





1.            Introduction


1.1       Planning permission for a residential development of 50 dwellings at Land to the West of Lillybank Farm, Wattles Wish, Battle was granted by Rother District Council in May 2017 (Planning application reference RR/2016/725/P). A Section 106 Legal Agreement was attached to the permission that secured the requirement for an extension to the 40mph speed limit on the A2100 London Road. This needs to be implemented through a Traffic Regulation Order (TRO), the cost of which is funded by the developer. The proposed lowered speed limit is intended to reduce vehicle speeds on the approach to the new junction (the development access).


1.2       To encourage compliance with the extended 40mph speed limit a gateway feature with a speed limit sign is proposed at the beginning of the new limit.  


1.3       This Traffic Regulation Order is identical to the proposal originally advertised and approved by the County Council’s Planning Committee in 2018. The reason this matter is now back before this Committee is that the developer did not implement the speed limit reduction within the statutory two-year time period, as commencement on site was delayed, and therefore the TRO needed to be readvertised.


1.4       An initial consultation was carried out between 27 October 2021 and 17 November 2021 with the local District and County Councillors, and statutory consultees including the emergency services.


1.5       On the 18 February 2022, the County Council gave notice under the relevant section of the Road Traffic Regulation Act 1984, (as amended), that it was proposing to amend the existing Traffic Regulation Order. A copy of the draft Traffic Regulation Order is included in Appendix 1. Copies of the advertised Notice of proposals were placed on posts in London Road.  Copies of the proposals were also placed on deposit in County Hall reception for viewing by members of the public. In addition, the Public Notice was advertised in the local newspaper (The Rye and Battle Observer on 18 February 2022). The formal period for representations ended on the 11 March 2022.


1.6 The proposals are as follows: -


·         To extend the 40mph speed limit in the following length of road: A2100 London Road – from a point 26.5 metres north of its junction with Virgins Lane, for a distance of 177 metres to the north of this point.

·         The existing 40mph speed limit will remain in force as specified in the Order.


1.7 The proposed speed limit will reduce vehicle speeds on the approach to the new junction that accesses the approved residential development. This allows for compliance with visibility guidance, increases pedestrian safety and minimises potential for collisions at the proposed site entrance.


2.            Comments and Appraisal


2.1       During the formal consultation period, seven items of correspondence were received objecting to the proposals.


2.2       The grounds for the objections were that:-


·         The proposal does not extend far enough to the north to include other properties on London Road. The reasons cited for this;

o   The footway alongside the western side of London Road, to the north of the proposed speed limit, is narrow and is often narrowed further by overhanging vegetation and fallen soil from banks and can feel unsafe when cars pass at higher speeds.

o   Residents accessing their properties on London Road to the north of the proposed speed limit are overtaken when indicating to leave the highway.

o   Exiting properties to the north of the proposed speed limit can be difficult when there is a high volume of traffic using London Road.

o   A large number of the properties north of the speed limit extension access single width tracks. If a vehicle is waiting to exit one of these tracks another vehicle cannot enter which is not clear to other traffic using the A2100.  

o   Drivers on the A2100 are unaware that there are vehicle accesses north of the proposed speed limit extension.

o   Rights of Way meet the A2100 north of Canadia Road where there is no footway at the side of the road.

o   A lower speed limit would help encourage walking and cycling.

o   There have been a number of accidents on this stretch of road.


2.3       No objections were received that were objecting to the proposed extension of the 40mph speed limit itself.  Instead, the objectors were requesting that the proposed extension goes further.


2.4       It is not considered that these objections provide sufficient grounds to warrant the modification or withdrawal of the proposals. This TRO relates solely to the Lillybank Farm development and is a mitigation measure for it as required by their planning permission for the site. This Traffic Regulation Order will implement a speed limit extension, not to address any existing road safety concerns, and its implementation is paid for by the developer. Given that the County Council has previously made a decision for an identical Traffic Regulation Order on London Road, and that there has not considered to have been a change in circumstances in the subsequent years, the Traffic Regulation Order advertised is simply for an extension of the 40mph speed limit that replicates the previous lapsed Traffic Regulation Order.


2.5       The extension of the existing 40mph speed limit is proposed to achieve a full Design Manual Road & Bridges (DMRB (TD 9/93)) 60mph stopping sight distance (215m) prior to the proposed development junction. This has been designed to accommodate vehicles decelerating from 60mph at the 60mph/40mph interface providing an acceptable forward visibility to the proposed junction.


2.6       It is not considered appropriate to introduce a further extended 40mph speed limit as part of this proposal, as it is not required to make the development access acceptable in planning terms or to be in accordance with visibility guidance. Concerns were raised at the time of the planning application with regard to highway safety at the proposed access point, by ESCC officers and members of the public. The proposed extension to the 40mph speed limit will mitigate those concerns, lead to improved highway safety and ensure that the development site access is policy compliant.


2.7       A petition requesting an extension to this speed limit has been submitted to the County Council, which is due for consideration by the Lead Member for Transport and Environment once this TRO has been considered by Planning Committee.  


3.            Conclusion and reasons for recommendation


3.1       This proposal seeks to address road safety concerns associated with the proposed development at Lillybank Farm whilst being mindful of the need to ensure the flow of traffic on London Road (A2100). It is considered that the concerns raised by the objectors should not be upheld and the proposals should proceed as per the advertised TRO.


3.2       In turn, it is recommended that the Planning Committee recommends to the Director of Communities Economy and Transport that the draft Order be made as advertised.




Director of Communities, Economy and Transport

31 May 2022







Appendix 1: Draft TRO