Rother Local Plan 2020-2040 (Regulation 18)

9 Economy

(2) 9.1 This chapter of the Local Plan presents proposed policies related to economic development. Economic development comprises employment, retail and leisure use ns as well as visitor accommodation and agriculture and forestry and there are policies relating to all of these sectors in this chapter. The continued economic prosperity within the towns and rural communities of Rother is necessary to ensure the vitality and sustainability of settlements across the district. Residents require employment, services to meet their needs, and leisure opportunities to promote health and wellbeing. These requirements are essential to the overall priority to Live Well Locally.

9.2 The NPPF establishes that the planning system plays a major role in assisting the building of a strong and competitive economy. Planning policies are required to help create the conditions in which businesses can invest, expand and adapt. The Local Plan is required to set out a clear economic vision and strategy which proactively encourages sustainable economic growth.

9.3 To this end, the Council, together with HBC, has jointly commissioned the Housing and Economic Development Needs Assessment (HEDNA) (2024) as the Local Plan's primary evidence base underpinning its economic strategy. The joint commission recognises that Rother's economy and employment needs form part of a larger 'Functional Economic Market Area' (FEMA), which includes Hastings. While there are of course commuting links between Hastings, Rother and other neighbouring authorities, namely Eastbourne, Wealden and Tunbridge Wells, the commuting links within and between Hastings and Rother are significantly stronger; and equate to an overall self-containment rate of 79%.

9.4 The HEDNA's analysis includes assessment of the key issues inherent within the district and the identified FEMA. Although it sits within the prosperous southeast region, the geography of the area presents a number of challenges that significantly impact on its economy in contrast with the wider region. The majority of the area is within the countryside, while the countryside contains some 40% of Rother District's population. At the same time, the two major towns, Hastings and Bexhill, are both coastal communities which represent an economic typology that has long suffered economic challenges. Indeed, both towns have received funding as part of the Government's recent Levelling Up agenda.

9.5 Recent data shows that workforce qualification levels across the FEMA are lower than regional and national figures respectively, while the proportion of the workforce in Rother and Hastings with no qualifications is noticeably greater still. Skills availability is reported as constraining the local economy, and particularly at higher technical skill levels such as for manufacturing, general industry and construction. There are some areas within the district that feature relatively high levels of deprivation compared to national averages.

9.6 The national macroeconomic picture has also been factored into the HEDNA's analysis, and national forecasting models have been used to estimate future employment numbers in the district. In addition, the HEDNA specifically assesses the permanent recent shift towards hybrid working, as well as the long-term impacts of Brexit. It should be noted however, that while the recent trend towards hybrid working has been factored into the HEDNA's employment floorspace projections, evidence does not indicate that there is a specific demand for live-work units within the district. Working from home trends may result in an increased desire for dedicated homeworking space within residential units, which it is envisaged will be picked up through market demand for housing.

9.7 The HEDNA's forecasting models also include longer term factors that will have a significant impact on Rother's economy. The urgent need to decarbonise the economy, which is itself reflected in the Council's commitment to use its powers and influence to make the district climate-resilient, and reduce emissions to net zero, by 2030, will mean that certain economic sectors will emerge as significant to Rother's economy and will need to be prioritised through Local Plan policy. Ongoing technological advances, most notably including the recent application of Artificial Intelligence, have the potential to be highly innovative but also challenging economically. Ultimately, the long-term forecasts for the local economy in light of these broader economic impacts are uncertain. A transitory economic climate will be a hallmark of the plan period up to 2040, and the Local Plan will need to reflect this.

9.8 Overall, the HEDNA projects an increase of some 3,800 jobs across all sectors, between now and 2040. A higher level of jobs growth is projected in accommodation and food services, and financial/professional services. Higher levels of employment growth are also projected in construction industries.

9.9 Following these growth projections, the HEDNA forecasts that the district will need an additional 74,189sqm of employment space. This figure is discussed in the development strategy chapter.

(1) Proposed Policy ECO1: Supporting New Employment Development

Explanatory Text:

9.10 In order to encourage employment and economic growth, this policy establishes broad support for new employment development, subject to other policies within the Plan. Given the changing and somewhat unpredictable economic environment that we face, it is considered that alongside site allocations, the supportive function of this policy is an important component in the Plan's ability to deliver its employment objectives.

9.11 The policy contains requirements to ensure that neighbouring amenities are protected in cases where employment development could create adverse impacts. A further consideration of the policy is to ensure that developments that may create higher levels of traffic are suitably located, or their transport impacts otherwise mitigated.

9.12 The policy also incorporates the requirements of the development strategy, insofar as it gives specific consideration to the scale and suitability of employment development that may be supported outside of Development Boundaries. This aims to provide in principle support for suitable forms of employment development in the rural areas.

Regulation 18 commentary:

9.13 Given the transitory nature of the economy as we move through the plan period up to 2040, it is considered now more than ever, that Local Plan policy should be flexible in order to encourage and support new employment development. At the same time, it is intended that the policy sets out sufficient detail as to what may be permitted in order to provide a level of certainty for prospective development.

Proposed Policy ECO2: Protecting Existing Employment Sites and Premises

Explanatory Text:

9.14 Retaining land and premises currently in employment use is essential. However, it is a known feature of today's economic climate that there is commercial pressure for sites to change to alternative higher value uses, notably to housing, which can have an adverse impact on the long-term sustainability of existing and future communities. The above policy establishes the strategic approach that prioritises the retention of existing sites in their employment use unless it is demonstrated to be unviable, which is defined as there being no reasonable prospect of its continued use. The approach by which viability is determined is set out in Policy DEV4.

9.15 In cases where sites or premises are demonstrated not to be viable in their existing permitted use, the policy sets out a hierarchy of alternative uses that may be permitted. First, suitable enabling development may be permitted as part of a mixed-use scheme, in order to ensure the effective use of the site for employment purposes. Where this is not possible, community uses may be permitted, followed by 100% affordable housing, before finally regular market housing (in line with affordable housing policy).

9.16 In order to ensure the effective use of existing sites and premises, the policy also permits, in principle and subject to other policies in the Plan, the intensification and extension of existing sites, as well as their redevelopment or conversion. Where appropriate, the policy also permits access or environmental improvements to existing sites and premises.

Retail and Leisure Need

9.17 The growth in online shopping has diversified the retail market away from 'physical shopping'. This trend has also been driven by long term increases in business rates and the recent COVID-19 pandemic, resulting in widespread online shopping across the district. On top of this, the country is currently in the midst of a 'cost of living crisis', due to a sharp upturn in consumer inflation since the end of the pandemic and the subsequent decision of the Bank of England to increase the cost of borrowing. These factors have had major implications for retailers' space requirements and are changing the retail landscape of our towns and cities.

9.18 Rother's Retail and Town Centre Uses Study 2023, considers the district's retail and leisure needs for the whole plan period, however the Study recommends that Local Plan policy should place a greater emphasis on retail and leisure forecasts over the next 10 years. This recommendation reflects the Government's Planning Practice Guidance, which states that long-term retail trends and consumer behaviour are inherently difficult to forecast, and therefore recommends that while the whole lifetime of Local Plans needs to be taken into account, assessment of need and planning for this need may require a focus on a more limited period of time and be regularly reviewed. As a minimum, the NPPF requires the Local Plan to identify need and make sufficient provision for retail and town centre uses at least ten years ahead.

Retail

9.19 The below table (Figure 40) sets out forecasts for new convenience goods floorspace capacity, primarily relating to grocery shopping, throughout the plan period and across the district.

Figure 40: Forecast Capacity in Rother for New Convenience Retail Floorspace (sqm)

9.20 Given current trends, the Town Centre and Retail Study identifies a capacity for 597sqm of convenience floorspace within the whole district for the plan period up to 2039. However, the 2032 figure of 418sqm is a more important figure for the Council to plan for, bearing in mind the inherent unreliability of longer-term retail forecasts. At the same time, and given the local nature of retail needs, district-wide figures are less significant than more local figures as there is no location for a single allocation that would cover the needs for the whole district.

9.21 Overall, the level of capacity identified for the three town centres of Bexhill, Rye and Battle, could only support a small new convenience store in each, and would not particularly add to improving convenience offer in the town centres. Therefore, there is no need to identify additional future growth in any of the centres. It is considered that this limited need of 418sqm can be accommodated within the existing premises within these Centres, including currently vacant premises.

9.22 In terms of comparison goods retail, which relates to retail trade for goods that are usually more expensive than comparison goods, while being bought more infrequently, the Town Centre and Retail Study forecasts either nil or negative capacity.

Leisure

9.23 Leisure forms a diverse range of use categories, and forecasting for new leisure uses is more problematic than for retailing, being highly complex and dynamic. Consequently, no overall floorspace need is identified as it has been for convenience and comparison retail. That said, the Study identifies a number of sectors forming leisure uses that are identified as having potential for growth within the district.

(1) 9.24 In terms of theatre, music and the performing arts, improvements to the De La Warr Pavilion in Bexhill have the potential to claw back demand that is currently lost through trips to Central London and regional venues. This will in turn help to stimulate trade to other businesses within the leisure sector that would benefit from linked trade, such as food and beverage outlets and potentially increase demand for overnight visitor accommodation.

9.25 Market analysis in the Study identifies a demand for an improved active leisure and fitness provision within the district. This includes demand for facilities in different areas within the district, while there is potential for a new leisure centre that offers affordable access to both wet and dry-based facilities under one roof. It is noted that this could be supported by investment from the public sector and is one specific area where Local Plan policy could have a facilitating role.

9.26 Ultimately demand for leisure uses will change and will also face competition for advances in technologies that may draw potential customers to remain at home. Given the complexity of this sector, as well as the problematic nature of forecasting for future leisure capacity, it is proposed that applications for new retail and leisure development will be determined in accordance with Policies ECO3 and ECO4. The Local Plan will promote the district's leisure offer through supportive and flexible policy that allows for development to come forward according to market demand, where such development is considered acceptable.

Proposed Policy ECO3: Designated Town Centres

^{*Main Town Centre uses are defined in the NPPF as: retail development (including warehouse clubs and factory outlet centres); leisure, entertainment and more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, nightclubs, casinos, health and fitness centres, indoor bowling centres and bingo halls); offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).}

Proposed Policy ECO5: Tourism Activities, Facilities and Accommodation

9.42 This sets out the Plan's overarching strategy for tourism development, including visitor accommodation.

(1) 9.43 It is appreciated that Rother's tourism offer coincides with the preservation of its natural and built heritage, and a significant proportion the market will be focussed on the rural areas. Consequently, while the Plan is supportive of new tourism and accommodation development, the overall approach is selective, being focused on higher quality markets and those that are related to, and support, the area's high environmental qualities.

9.44 It is also recognised that there can be commercial pressures for tourism facilities, in particular visitor accommodation, to change to higher value uses. For this reason, the policy restricts the loss of tourism activities, attractions and visitor accommodation, unless it can be demonstrated that there is no reasonable prospect of its continued use subject to the requirements set out in Policy DEV4. Additionally, new visitor accommodation will also be subject to appropriate controls that restrict occupancy to that for holiday/leisure purposes.

Regulation 18 commentary:

9.45 Given its broad access to the coast, its beautiful and often remote landscapes, its unrivalled historic assets and settlements, and its relative proximity to London, it is no surprise that the visitor economy is a fundamental component of the district's economy. The Sussex Visitor Economy Baseline Report (July 2021) records Rother with the second highest number of tourist day visits amongst authorities in the County (after Brighton) and the highest proportion of tourism visits per resident (65).

9.46 A Study^[108] of the economic impacts of tourism within Rother recorded that in 2019, 6.3 million tourist trips to Rother were undertaken, with £287.3 million spent in the local area as a result of tourism (taking account of multiplier effects). The study estimated that 7,234 jobs were directly supported by tourism, while also supporting 1,219 non-tourism related jobs. Overall, 30.1% of Rother's population employed as a result of tourism within the district.

9.47 Tourism also forms an important component of rural economies. In addition to the district's three main town of Bexhill, Battle and Rye, Rother's villages are popular tourist destinations due to the presence of cultural activities and attractions such as Bodiam Castle, Batemans at Burwash, Great Dixter, the Kent and East Sussex Railway and the medieval town of Winchelsea. Tourism is an influential factor in the diversification of the rural economy, including the growing market for local produce and viticulture.

9.48 Of particular significance is the coastal resort of Camber. With its golden sands, it has long been a popular tourist destination for people from across the wider region and its summer population swells considerably. The eastern end has become increasingly popular for extreme sports, particularly kite surfing. Camber has the potential to enhance its tourism offer and expand its role as a modern all year-round leisure and tourist destination.

9.49 Most visits to the district are day trips (with 5.8 million being recorded in 2019), although there is a considerable level of staying trips as well, with demand for both serviced and self-catered accommodation. It is envisaged that climate change related issues, including the growing unsustainability of overseas transit, will equate to a steady trend towards domestic 'staycation' holidaying. This represents a growing opportunity for Rother to diversify its tourism offer, extending beyond traditional day trips towards an increasing emphasis on multi-day visits. It is therefore essential for its tourism sector that Local Plan policy promotes a broad range of visitor accommodation, including higher-quality, sustainable accommodation, both in urban and rural areas.

9.50 The development of new online platforms, most notably Airbnb, has led to a rise in the number of short-term holidays lets in some areas of the country, particularly coastal towns. This is conspicuously the case in certain areas of Rother including Rye and Camber. There is a growing awareness that higher concentrations of short-term lets can adversely impact on the availability and affordability of homes for local people, as well as the overall sustainability of communities.

9.51 While Policy ECO5 has no specific approach to short-term holiday lets, the Government has recently consulted on proposals that would create a new use class for short-term holiday lets. It is proposed that a change of use from residential to a short-term holiday let would be Permitted Development, however, the use of Article 4 Directions would allow Local Authorities to remove this right of Permitted Development in areas where short-term holiday lets are concentrated and having an adverse impact on the availability of housing. Until such time as these changes are in place, Local Planning Authorities are generally unable to intervene.

(3) Proposed Policy ECO6: Holiday Sites

Explanatory Text:

9.52 The overarching policy approach set through Policy ECO6, is to support tourism activities and facilities, including by increasing the supply of quality serviced and self-contained accommodation, while ensuring compatibility with other policies, especially those that protect environmental character and amenities.

9.53 This additional policy for holiday accommodation is necessary because it makes up a significant and dynamic part of the tourism sector, being historically concentrated on static caravan sites situated near the coast but now taking more varied forms and being more dispersed.

9.54 Care must be taken in the siting, scale and form of holiday sites, as they can impact adversely on the special character of the countryside, particularly on an otherwise undeveloped coastline, much of which is designated as being of ecological importance, or in the High Weald National Landscape, which are the very assets that makes the district attractive to visitors. In addition, coastal areas are also most often vulnerable to flood risk.

9.55 Given these environmental constraints, the provision of new holiday centres or large static caravan/chalet sites would be most unlikely to be satisfactorily accommodated locally.

(1) 9.56 The upgrading of existing holiday sites, for example replacing static caravans with chalet or lodge-style units, can be positive in terms of better meeting customer needs so long as the impact on the wider landscape is unaffected. This may, exceptionally, involve a sensitive, limited expansion.

9.57 Changing leisure patterns bring other demands, including for short stay breaks in low key, high quality, self-catering accommodation. Such accommodation may take the form of small lodges or more unusual structures such as shepherd huts or tree houses. Where a scheme involves limited ancillary facilities and generates minimal traffic, as well as not detracting from its setting, these may also be accommodated.

9.58 In addition, visitor accommodation serving other countryside uses, for example existing fishing lakes or equestrian facilities, may also be considered where any new buildings can be assimilated into the landscape and the accommodation is wholly ancillary to and an integral part of the principal leisure use.

9.59 Relative to static holiday accommodation, there is more scope for further seasonal touring caravan and camping pitches for holiday use on temporary small-scale sites in the summer months, including new forms of camping, as seen in the rise of 'glamping' and the use of yurts for example.

9.60 The siting of such developments should be visually contained within the rural landscape, not adversely impact on the particular characteristics of the High Weald NL or sensitive ecological areas and have no unacceptable impacts in terms of traffic, access and other environmental impacts.

9.61 There is a need to give careful consideration to tourism accommodation proposals, including ones to upgrade or extend existing permanent and seasonal sites, as well as new sites, where this is likely to generate increased recreational pressure on the Dungeness Complex^[109] of Habitats Sites. This will be most relevant to proposals in the Camber, Rye Harbour and Winchelsea Beach areas, where otherwise suitable proposals must also maintain the integrity of the ecological interest of the Complex; this may involve restricting the scale, length of season, the provision/retention of recreational space and provision of guidance about the sensitivity of sites.^[110]

9.62 Some significant areas of the district are at risk from coastal and/or fluvial flooding. For both permanent and seasonal accommodation, the provision/extension of sites, or extension of occupancy periods, is will not be agreed in undefended areas of high flood risk unless a Flood Risk Assessment has satisfactorily demonstrated that the appropriate standard of flood defence will be provided and the development would not impede flood flows or otherwise prejudice floodplain storage.

9.63 Fluvial flooding from rivers can occur at any time of the year and therefore highly vulnerable uses such as touring and static caravans and tents should normally be located outside the floodplain or be adequately defended, with any residual flood risk mitigated for on the site. Flood Risk Assessments will also be required for applications in flood risk areas, included those with flood defences, to assess any residual flood risk to the site. These should have regard to the impact of hard-standings and other impermeable surface treatments. To safeguard people, restrictions on occupation will be imposed where there is a high risk of flooding.

9.64 While there has been a trend to move away from seasonal controls on permanent sites to allow all-year-round use, it is essential that holiday sites remain available as tourist accommodation and do not develop, or become seen, as low-cost homes to be purchased or occupied by persons without a permanent residence elsewhere. As well as the loss to the tourism economy, permanent residential occupation has infrastructure impacts, notably on highways and local services, including schools.

9.65 On sites with static units established practice is to impose conditions on any new permissions to the effect that any unit is only occupied for holiday purposes and not as any person's sole or main place of residence; also, that the owners/operators of the site should maintain an up-to-date register of the names and main home addresses of all occupiers of the units and make this available to the Council.

(1) 9.66 Seasonal sites will be limited to holiday use and the occupation period will be restricted to prevent use all year round (normally to between April and October).

9.67 The Living Well Locally Overall Priority requires proposals, including holiday site development to demonstrate that they have had sufficient regard to matters of sustainability, including sustainable and active transport where possible.

Regulation 18 commentary:

9.68 This policy takes forward DaSA Policy DEC2 into the new Local Plan, subject to several minor updates. Holiday sites development remains a significant part of the district's tourism offer, and this policy goes into some detail to ensure that such development does not adversely impact on Rother's landscape and environment.

9.69 Updates to the policy include specific updated references to align with the NPPF and the other policies in this Plan.

(1) Proposed Policy ECO7: Agriculture Development and Forestry

Explanatory Text:

9.70 Rother is a predominantly rural district, and the primary economic function of the countryside is agriculture and the production of food; with some 70% of the area of Rother district being classed as farmed land by DEFRA. Rother's agricultural land is of mixed quality; mostly grade 3, but with significant areas of higher quality grade 2 towards the east of the district along the Brede Valley and East Guldeford Level.

9.71 It is important to recognise that with 83% of the district being within the High Weald NL that the form of agriculture within the district is generally less intensive in nature compared to other rural areas. This is reflected in the High Weald's medieval field pattern consisting of small, irregularly shaped fields bounded by hedgerows and woodlands. According to the High Weald AONB Management Plan, there is no Grade 1 agricultural land within the High Weald, with only 2.5% being of Grade 2, while the average farm size in the High Weald is less than half the national average.

(1) 9.72 The Management Plan emphasises that certain forms of agriculture are nonetheless an integral part of the maintenance of the High Weald's medieval landscape, especially where the production of food is intended for local markets. Changes in agricultural practices during the 20th century saw a decline in traditional land and woodland management, with a consequent decline in skills in environmentally sensitive land management. Maintaining and developing such skills, and practices, offers opportunities for local employment and has a vital part to play in maintaining the district's distinct landscape character, especially in the High Weald. Key threats to the High Weald's fieldscape identified by the Management Plan include the fragmentation of farm holdings due to an increase in non-farming land ownership, the loss of agricultural skills and knowledge, and a reduction in livestock grazing and the associated loss of farm infrastructure and the degradation of pasture and soils.

9.73 New agricultural buildings are often permitted development and do not require planning permission, subject to requirements that the farm holding is over a certain size, with limitations for building size also relevant. In Rother, where farm sizes are smaller than national averages, new agricultural buildings may therefore be more likely to require planning permission.

9.74 In addition, modern farming practices often require new agricultural buildings to meet specific needs. It is also recognised that new forms of agriculture, including viticulture and beer production, are becoming increasingly important within the rural economy, with local beer production in particular being marketed in local urban areas.

9.75 It is therefore considered that a separate policy is required for new buildings for agriculture and forestry, in order to establish flexibility to account for the specific requirements of agriculture within Rother that does constitute Permitted Development. To ensure viable farming industries, these will be supported in principle, though whilst the size and mass of such buildings is inevitably dictated by their function, care is still needed in their siting, design and materials, to minimise the visual impact on the landscape character of the countryside.

(1) Proposed Policy ECO8: Agricultural Diversification

Explanatory text:

9.76 The above policy offers in principle support for schemes to diversify agricultural businesses, both through the reuse of existing redundant buildings and in some circumstances through new buildings. Such diversification schemes can include workshops, farm shops or tourist facilities, and other employment uses such as offices. To be considered a diversification scheme, development is not required to have a direct connection to the established farm, however there is often high interdependency and mutual benefit between developing markets for local food production and other business activities.

Regulation 18 commentary:

9.77 The diversification of traditional rural businesses has by now become an established means of supporting the agricultural activities that are integral to the vitality of rural areas. At the same time, adding new farming activities to changing farming needs and development economics have meant that many former farm buildings, historic and modern, have become available for conversion and re-use.

9.78 What is essential to diversification schemes, in contrast with other businesses in the rural areas, is that they add value to the established agricultural business while remaining ancillary in function. By supporting the vitality of agriculture, it is considered that a policy for diversification schemes may permit increased flexibility for new economic development over proposals for new development in the countryside that are not connected to agriculture.

Proposed Policy ECO9: Local Employment & Skills

Explanatory Text:

9.79 Unemployment within a geographic area is a key indicator of deprivation, while qualification levels significant factor in the development of a high skill economy. It is a long-standing statistic that, low employment and qualification levels compared to regional and national averages, are a continued detriment to local living standards and Rother's overall level of economic development. This is also true of the wider Functional Market Area, which includes Hastings. The Housing and Economic Development Needs Assessment also states that the lack of local skills, particularly in the construction sector, has a role in restricting the development of much needed housing in the district, as well as the delivery of planned for employment floorspace. It consequently recommends that the upskilling of local residents should be an objective of the Local Plan.

9.80 The Council has an established practice of using planning obligations to secure Local Employment and Skills Plans (LESP) from larger developments. LESPs will set out opportunities for, and enable access to, employment and the upskilling of local people through the construction phase, and where possible the operational phase, of the development. Opportunities are to be made available to qualifying residents from the local area as far as possible.

9.81 The responsibility for drawing up the LESP is the responsibility of the developer. In doing so, the developer will be expected to liaise with the Council's Regeneration Team in combination with local employment and skills agencies, from which opportunities for upskilling and employment will be identified. The target outcomes of the LESP will be commensurate with, and assessed against, construction industry standard benchmarks of the employment / skills outcomes expected from the particular size and type of construction proposed^[111].

9.82 LESPs will be required from all developments over the thresholds of 10+ dwellings and 1,000+sqm of floorspace. Qualifying developments are required to make a financial contribution to the Council for its role in liaising with the developer in drawing up the LESP, as well as for its role in monitoring the delivery of the LESP. Financial contribution requirements are set out in the policy, and they are to be index linked for inflation based on the adoption date of the Local Plan.

Regulation 18 commentary:

9.83 Though it is now an established practice to require LESPs from larger developments within the district, this policy aims to formalise the process so that LESPs can be considered as early in the planning of new development so that opportunities are not missed. The policy also strengthens the Council's ability to require LESPs from larger developments.

9.84 The thresholds of 10+ dwellings for residential development, and 1,000+ sqm for commercial development have been derived through the Council's experience in its use of LESPs from new development.

9.85 The Council's experience of using LESPs indicates that the financial contribution requirements of £200 per dwelling, or £1 per sqm of non-residential floorspace, are minimal in respect to the overall value of a development. It is therefore not expected that these requirements would have any significant adverse impact on the viability of a development.

(1) Proposed Policy ECO10: Equestrian Developments

Explanatory text:

9.86 While there is a limited number of larger commercial centres in the district, it is small-scale facilities for individual and private pursuit that predominantly come forward as planning applications. Typically, proposals for stables will include a tack room as well as external hard-standing and manure bays, but may also include a sand school, fencing and jumps, as well as new access from the highway.

9.87 A balance needs to be struck between meeting the desires of the equestrian community and at the same time safeguarding the intrinsic value and locally distinctive rural character and landscape features of the countryside. This is especially the case in the High Weald NL, the conservation and enhancement of which is afforded great weight.

9.88 The High Weald landscape is particularly vulnerable to development, including on the fringes of settlements. New buildings and hard surfaces – access roads or sand schools – are not always easily accommodated without some impact on the fields, small woodlands and farmstead meadows which make up the essential character of the High Weald NL.

9.89 Much of the rural area beyond the High Weald NL is also sensitive for other reasons; notably, the lower and open Levels extending eastwards towards the Romney Marsh are ecologically sensitive and subject to national and international protection. More generally, equestrian developments can have ecological impacts, for example, through habitat or species loss, nutrient enrichment, or the use of lighting. Sites should also have regard to avoiding the loss of higher quality agricultural land.

9.90 Other than the possibility of utilising former farm or other commercial buildings for new uses, there is limited scope within the countryside to accommodate further commercial equestrian enterprises. However, there is scope for equestrian development in the countryside that is limited in scale, although there is a need to manage the increasing pressures from proposals for new isolated stables and, at the other extreme, from a cumulative impact of stabling and equestrian facilities in a concentrated area.

(2) 9.91 Ideally, new development should be sited close to existing built development and close to the bridleway system. Mobile field shelters can often be an appropriate way of catering for equestrian uses, although this is not always practicable.

(1) 9.92 Where applications come forward in more remote locations and permanent buildings are required, new development will be expected to meet a number of criteria aimed at protecting the character of the countryside and the amenities of both local residents and users of the countryside.

(1) 9.93 Particular control is necessary over the location of any new equestrian development and the size, siting and design of all new buildings and associated facilities. Floodlighting will rarely be acceptable for private/ domestic stables in the countryside, particularly in the High Weald NL and in those areas identified as having "dark skies". Any lighting necessary for commercial uses will need to be carefully designed in accordance with Policy LAN3. Extensive access roads or excavations other than of a minor nature to enable the formation of a sand school (or manège) are not appropriate in the countryside.

(1) 9.94 In assessing applications, adequate provision should be made for the safety and comfort of horses in terms of land for grazing and exercising. Such provision will help to address the issue of the excessive sub-division of fields and over grazing/loss of soil structure. While there is not a common standard applicable throughout the plan area, depending on how the horses are kept and the nature of the land, a desirable guideline would suggest stocking at a density of one hectare per horse.^[112]

Regulation 18 commentary:

9.95 The Rother area continues to be a popular area for equestrian activities. Its countryside provides an attractive environment for horse riders and there is a good network of bridleways throughout the district. Equestrianism is recognised as a countryside pursuit and has a role in supporting the rural economy.

9.96 This policy takes forward Policy DCO2 from the DaSA. It aims to accommodate equestrian developments whilst setting out the key considerations, notably in terms of the potential harm to the character of the countryside and particularly the High Weald NL so they are sensitive to their context.

9.97 The policy now includes further detail regarding the hierarchy of agricultural land, as well as designated sites of ecologically significant and sensitive.

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^[108] The Economic Impact of Tourism on Rother District 2019, Tourism South East Research Unit.

^[109] This comprises the Dungeness, Romney Marsh and Rye Bay Special Protection Area (SPA) and Ramsar site, and the Dungeness Special Area of Conservation (SAC).

^[110] For further information see Dungeness Complex – Sustainable Access and Recreation Management Strategy (SARMS) (Oct 2017)

^[111] Industry standard benchmarks are currently set out in the National Skills Academy for Construction Client Based Approach from 2017. While this is the latest available version, developers would be expected to comply with the latest version as and when these benchmarks are updated.

^[112] Managing Land for Horses, Kent Downs AONB Unit (2011)