QUESTION 14: Do you agree with the policy approach to extensions, annexes, alterations and outbuildings and the wording of the respective policies? If not, what changes would you wish to see?

No comment

Extensions and alterations will in many cases lead to the loss of on site parking or existing garage/car port facility. Thus increasing pressure on on road/verge parking.
Policy should be amended to specifically safeguard from these negative effects.

Comments by Rye Town Council on the Rother DC Development and Site Allocations (DaSA) (Local Plan)


1.The 2014 Core Strategy recognised that it needed a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies. It would need to tackle two specific issues affecting dwellings: to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

2. It is noted that the DaSA Plan records the preferred sites across Rother District in two categories:

- sites where no Neighbourhood Plan (NP) is being made
- sites identified in Neighbourhood Plans; Rye is in this category.

4. Rye Town Council has considered the DaSA Plan in its three parts.

- It has NOTED Part A - the Context: (the Core Strategy), with its development requirements (not for review), and related policies. Where NPs are being prepared these are listed (Rye is listed).
- It COMMENTS on Part B - Development Policies as below. Many of these draft policies affect the RNP. Some have argued that it would have been useful to have had these as Rye was drafting its RNP, but we are where we are. We have been specifically encouraged to consider the definitive housing requirements for the Rye Neighbourhood Plan area (Rye targets have already been reconciled by Rother officers) and the policies for Development Boundaries and "Gaps".

- It has NOTED Part C - There are the Site Allocations for those parishes where no NP is being made. The only site allocations in this section relating to Rye are in Rye Harbour which we have considered in the RNP. Also there is discussion of traveller sites including one in Rye.

5. Whereas we had, at first sight, presumed that Part B might conflict with the emerging Rye NP, this is not the case. As agreed, here is the Rye TC comments in consolidated form on the three parts of DaSA.

The Rother District Development and Site Allocations Local Plan

Part A - Neighbourhood Plans (NP) - Rye NP is listed as being drafted. Version 8 emerging plan is on the website. www.ryeneighbourhoodplan.org.uk
Rother Officers have reconciled numbers in the RNP with the DaSA.

Part B Q1 - Water Efficiency -Support approach: adopt standard through Bldg Regs

Part B Q2-4 - Suggest Rye Harbour for turbines and biomass. Solar panels are not mentioned and could be fitted to large industrial and educational buildings in Rye. Support approach - should adopt national guidance standards.

Q5 - Retention of sites of social or economic value - Support approach and proposed criteria for retentions.

Q6 - Equestrian development - Support approach - as drafted

Q7 - Affordable Housing - Support Option B, in line with PPG (None under 10; 30% over 10 dwellings)

Q8 - Access to housing and space standards (Older people) - Support Option E

Q9 - 10 - Custom and self-build housing - 1% of target of 160 houses= 2 for Rye Rye could support 5 homes which is around 3%. Support Option D; a site is identified in Rye NP

Q11 - External residential areas - Support proposed policy

Q12 - Extensions to residential gardens - Support proposed policy

Q13 - Extensions and alterations, including annexes - Support proposed policy

Q14 - Boundary treatments and accesses -Support proposed policy

Q15 - Shopfronts and advertising - Strongly support proposed (more prescriptive) policy

Holiday Sites - Support proposed policy

Q16 - Existing Businesses and Sites - Support proposed policy

Q17 - Landscape and AONB - Support proposed policy

Q18 - Strategic Gaps - Rye-Rye Harbour to be extended Support the proposed definition of strategic gap, but given the unique nature and profile of Rye could be extended to gaps on the Eastern and Western approaches: New Road, Military Road and New Winchelsea Rd

Q19 - Bio diversity and Green Space - Support the policy approach

Q20 - Drainage - Support the policy approach

Q21 - Land Stability - There is a risk of (sandstone) rockfall around Rye. The rock structure is of similar composition to cliff structure of Fairlight / Pett . The risk locations include East, South and West Citadel; land above Military Rd and at Cadborough. Rye should be specifically identified and a similar policy applied to land at risk above and below where historical falls have occurred. Propose inclusion of Rye as for Fairlight and Pett Level

Q22 - Environmental Pollution - Support policy approach

Q23 - Comprehensive Development -Support policy approach

Q24 - Development Boundaries - The RNP proposes two changes to the development boundary of Rye. Policy approach should cater for this.

Part C - Targets
Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour), 10-20,000 sqm employment. Dwellings Number Breakdown has been agreed with Rother DC Officers:

Total Completions Large Site Small Site Windfall
355 198 22 6 22
Balance: 107

Rye Harbour - Allocation to Rye Harbour - 40 dwellings - Support policy approach; as directed by Rother DC, and for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish)
The 40 are included in the Rye target of 400 as above.

Traveller sites - Traveller Site - Rye Gritting Depot is listed but not a preferred option - Support policy approach

Support policy DHG6

Option C preferred

We support DHG6 to protect the AONB from damaging development

Support DHG6

I agree

It would help, particularly to parish councils looking at applications, to have the checklist/guidance suggested in Policy DHG5. We believe however that in (i) additional noise should be an additional consideration. This particularly relates to outbuildings used as workshops.

With regard to Policy DHG6, it is felt that 'close proximity' needs further definition.

NCS agrees to the policy approach for exyensions to residential gardens,Extensions, alterations and outbuildings, residential annexes, boundary treatments and accesses and drives

Extensions: Policy needs to incorporate measures against the 'serial extender' who will constantly add small extension to their property. The extensions individually may not require planning, and therefore a property may change considerably without the planning department having seen a single plan. A limit must be placed on the amount and size of extensions allowed.

Annexes: Policy need to cover what happens when the annex is no longer required for the purpose it was put up for. If the property changes hands, this will sell as a much larger property and be used as part of the main dwelling.

Rye Conservation Society agrees to the proposed policy and wording.

Agree with Option C and policy wording

We broadly support Policy DHG5 but are concerned that the wording may seem to argue against modern extensions or alterations. We believe that, since modern additions can be very effective and in sympathy with older buildings, and can be preferred to pastiche alterations, if you would change the policy wording accordingly, we would be in complete agreement.

Object to the policies as too restrictive. The following changes are suggested:

In the preamble at para 8.57 add the words "from the Local Planning Authority" after 'planning permission'.

Retain Policy HG8 of the 2006 Local Plan and issue design guidance. It is easier to update guidance than policies.

For annexes. Option B is the preferred choice. We are concerned that the policy gives no thought to the short term needs but seems to assume all annexes will be permanent. This need not necessarily be the case.

From first-hand experience, it is evident that the proposed policy approach has been 'de facto' in force since at least 2006, so it is welcome to finally see the design guidance spelt out. This may help achieve much needed consistency in approach by the planning authority, as it will assist not just applicants or their agents, but planning officers themselves. However, much of the terminology used is still highly subjective. It would be helpful to encourage more objective criteria so as to achieve a fair and consistent approach by officers.

Landscape

HOUSING Page 35

Yes

Ecology

HOUSING Page 35

Yes.