QUESTION 16a: Do you agree with the policy approach to holiday sites and the proposed policy wording?

Agree.

No comment

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 DEC2

I agree with the proposed approach.

Support DEC2

a) Something should be added in about access and infrastructure leading up to new sites. The impact of extra traffic(or larger caravan type traffic) on narrow country roads should be properly evaluated.
I agree with b,c,d.
e) As there are issues with affordable housing and the larger holiday camp sites generally have good amenities of offer, I think that a small proportion of accommodation should be made available for permanent residential use.It could help with, in particular, older people, as there is usually a small shop and health/leisure facilities readily available for use.

We feel that the occupancy conditions on Policy DEC2(e) should be spelt out definitively; anything greater that 48 weeks per annum occupancy should not be permitted.

there is wide spread abuse of the Shearbarn and Coghurst Hall and Beauport Park sites, If all holiday accommodation was required to close for 4 months a year and not just a couple of weeks, this would stop. there is already an excess of caravan/lodge accommodation, that is why the site owners are so keen to sell it to private occupiers.

Option B preferred
A more restrictive approach, with detailed criteria preventing the establishment of new large scale sites - ensuring against harm to the AONB

NCS agrees with policy approach and wording

Agree

Rye Conservation Society agrees to the proposed policy and wording.

Agree with Option B and new wording

We support DEC2.

Occupancy conditions have crept up in length of stay permitted, to such an extent that properties are being advertised locally as capable of being occupied for 51 weeks of the year. An occupancy condition must be realistic therefore and be 48 weeks or less. The condition also needs to be monitored properly by requiring of the developer positive evidence of its empty state.

POLICY DEC2: HOLIDAY SITES
Policy heading/description
Rename policy "Holiday Accommodation" not "Holiday Sites" as this does not
correctly describe the policy application.

Amend (a) (i) to:
Must safeguard the intrinsic and locally distinctive character of the countryside, with particular regard to the conservation of the High Weald AONB, and have an acceptable environmental impact, especially when viewed from public vantage points.
Reason: to align with other policies permitting development in the countryside, for
example the equestrian policy, and properly to reflect the stated policy objective
in the preceding text of promoting sensitive and small-scale tourism accommodation in the countryside whilst protecting and conserving the landscape.

Amend (a) (vi) to add "particularly":
Must not harm the rural character of the area, particularly where there is any increase in the site area or a new structure; and
Reason: no development in the countryside should be permitted to harm rural character.

Add new criteria to (a):
Must seek to re-use existing buildings before proposing new buildings or structures
Reason: re-use of buildings, for example farm buildings, is the established starting
point for accommodating new tourism accommodation in the countryside and there is no reference to this preferred approach in the policy.

Amend (b) (ii) to:
A proposal that comprises a limited amount of low key accommodation to enhance another existing countryside recreational use without accommodation and is wholly ancillary to that use.
Reason: to guard against misinterpretation and repeat applications producing
cumulative aggregate development over the plan period and to have some parity with (b) (i) in terms of the expected low-key nature of the accommodation.

Amend (c) (ii) to add "sensitive":
A proposal for the limited and sensitive extension of that site to a natural boundary and makes a significant improvement in the appearance and quality of accommodation.
Reason: to accord with paragraph 9. 17.

Add footnote to (c):
An "existing site" means the static caravan, chalet or lodge accommodation.
Reason: to ensure the interpretation of an existing site is definite and accords with
the policy intention and is incapable of misinterpretation. To ensure the term "existing site" is not taken to refer to the property/landholding/farm and is
understood specifically to refer to the existing static caravan, chalet or lodge
accommodation.

Amend (d) to:
In relation to a touring caravan or tented camping proposal, it is of a small scale appropriate to the area, is visually contained within the rural landscape and the siting of touring caravans and tents on the land is limited to April to October annually. Any ancillary facilities necessary to serve the site will only be permitted on a similar seasonal basis or, if they are of a permanent nature, are compatible with the local character of the area. Where the temporary use of land is permitted, any ancillary facilities necessary to serve the site will only be permitted on a similar
temporary basis.

Reason: the policy criteria does not match or reflect paragraph 9. 23 which sets out
what the policy intends to achieve. The wording is also unclear. The policy as
worded would appear potentially to permit year-round siting of touring caravans
on land, meaning open winter storage in the open countryside which would be
visually intrusive, harmful and unnecessary.

Note: This is a response to the printed question related to this policy DEC2,
Question 16 (a). There is no question 16 (b)... on DEC2. The following printed
question is Question 17 on the next policy DEC3.

a: Agree, tight control essential.

Transport Strategy & Economic Development

ECONOMY Page 65

Agree with Policy DEC2, but it is suggested that linkages are made to transport and accessibility to support sustainable tourism.

Landscape


ECONOMY Page 65

Yes: with the following suggested rewording:

P. 70 policy DEC2 holiday sites. Suggested rewording to reflect that impacts do not need to be seen to be significant. i) must have an acceptable environmental impact especially in relation to local landscape character and views.