Dear Sirs,

Re: Proposed Submission Development and Site Allocations Local Plan

Gladman write to offer some brief comments on the Rother Site Allocations Local Plan. It is noted that the document follows on from the original Core Strategy adopted in 2014. Gladman make specific comments on Part A and Part B of the Site Allocations Local Plan below, but as an overarching point we consider that given the Site Allocations Local Plan has a very short life span, less than 10 years even before its submission for examination, both the Core Strategy and the Site Allocations Local Plan should be reviewed immediately post adoption of the Site Allocations Local Plan. Otherwise the Local Plan is in danger of being time expired prior to a new plan being put in place. This is especially important given that the government's standard methodology for housing need is likely to increase the housing requirement significantly. We do not consider that the plan can be found sound without commitment for an immediate review.

PART A

Policy DHG4 - Accessibility and Adaptability Standards

The Planning Practice Guidance (Paragraph 56-007) requires local authorities to evidence and demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. Whilst Gladman understand the need for the delivery of accessible homes the Council must provide a local assessment evidencing the specific case for the scale of need proposed in Rother. This should justify the inclusion of optional higher standards for accessible / adaptable homes in policy DHG4. At present Gladman do not conclude that the evidence justifies the application of the standards to all new build homes.

Part B

Gladman do not wish to comment specifically on any of the individual allocations at this time, however we would comment on the overall level of housing supply within the plan. Paragraphs 8.1-8.18 set the context for the levels of development which have been achieved so far and the commitments that are made, a residual need of 1,574 dwellings to come forward through the Site Allocations DPD and Neighbourhood Plans is identified. The Site Allocations DPD confirms allocations for 1,562 dwellings in Figure 18, there is therefore a shortfall against the total requirement.

The plan is silent on the status of neighbourhood plans in Rother and whether or not it is realistic that the forthcoming neighbourhood plans will allocate the level of housing envisaged in Figure 18 and make up the difference in units aspired to hit the 5,700 unit total. What must also be remembered is that whilst the target may be 5,700 units to be delivered, there is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building any flexibility into the plan for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would in effect be a buffer to ensure overall plan levels of development are delivered is not sound.

Gladman consider it likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.

As a leading land promoter Gladman would welcome the opportunity to further discuss the content of this representation at the examination into the soundness of the Site Allocations DPD.