QUESTION 22: Do you agree with the policy approach to land stability and the proposed policy wording?
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 21972
Received: 20/12/2016
Respondent: Vanessa Crouch
Agent: Stiles Harold Williams
No comment
No comment
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22169
Received: 31/01/2017
Respondent: Rye Town Council
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
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
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22262
Received: 14/02/2017
Respondent: Fairlight Parish Council
Fairlight Parish Concil comments:
We agree the policy generally.
In the Fairlight/Pett area we believe that following the precautionary principle soakaways should not be allowed within 100 metres of the cliff rather than the 50m proposed.
Reviews of the limit of development should take place every 3 years or following any significant cliff fall.
We would also like to see an Article 4 direction for the coastal zone in order that work which is currently permitted development is subject to the test of additional loading to the cliff.
We will seek to address this in the Fairlight Neighbourhood Plan.
Fairlight Parish Concil comments:
We agree the policy generally.
In the Fairlight/Pett area we believe that following the precautionary principle soakaways should not be allowed within 100 metres of the cliff rather than the 50m proposed.
Reviews of the limit of development should take place every 3 years or following any significant cliff fall.
We would also like to see an Article 4 direction for the coastal zone in order that work which is currently permitted development is subject to the test of additional loading to the cliff.
We will seek to address this in the Fairlight Neighbourhood Plan.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22381
Received: 16/02/2017
Respondent: linda parker
yes
yes
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22406
Received: 17/02/2017
Respondent: Ticehurst Parish Council
Agree with RDC proposal
Agree with RDC proposal
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22433
Received: 17/02/2017
Respondent: Northiam Conservation Society
NCS agree with policy approach and wording.
NCS agree with policy approach and wording.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22514
Received: 18/02/2017
Respondent: Rye Conservation Society
Rye Conservation Society agrees to the proposed policy and wording.
We would recommend that the cliffs above Military Road should be designated as Fairlight/Pett given the history of rock falls,
Rye Conservation Society agrees to the proposed policy and wording.
We would recommend that the cliffs above Military Road should be designated as Fairlight/Pett given the history of rock falls,
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22572
Received: 19/02/2017
Respondent: Mrs Sheena Carmichael
Agree with proposed policy and wording
Agree with proposed policy and wording
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22670
Received: 20/02/2017
Respondent: CPRE Sussex
We agree, but suggest the margin of protection at Fairlight Cove should be a minimum of 100m.
We agree, but suggest the margin of protection at Fairlight Cove should be a minimum of 100m.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 22690
Received: 20/02/2017
Respondent: Miss Judith Rogers
From this policy, I am unable to see how the 'unstable' or 'potentially unstable' land mentioned in the first line, is being assessed prior to a) taking place, or is a) to take place on all sites?
Is there any measure to ensure that development does not introduce instability i.e. from their ground works required to deliver the development, to ground which in its current form may be considered as stable?
From this policy, I am unable to see how the 'unstable' or 'potentially unstable' land mentioned in the first line, is being assessed prior to a) taking place, or is a) to take place on all sites?
Is there any measure to ensure that development does not introduce instability i.e. from their ground works required to deliver the development, to ground which in its current form may be considered as stable?
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 23239
Received: 18/02/2017
Respondent: Mr Dominic Manning
Agree in principle. However, with reference to policy item (ii), Figure 12 is confusing, as there is no legend, nor is the catchment clearly marked. It would also be useful to understand how 'greenfield rate' is technically defined.
Agree in principle. However, with reference to policy item (ii), Figure 12 is confusing, as there is no legend, nor is the catchment clearly marked. It would also be useful to understand how 'greenfield rate' is technically defined.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 23611
Received: 20/02/2017
Respondent: East Sussex County Council
Archaeology
ENVIRONMENT
-Land stability
It should be highlighted that the Fairlight coastal zone buffer and Pett Level catchment both contain archaeological sites that need to be considered.
-AMBER
Archaeology
Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.
ENVIRONMENT
-Land stability
It should be highlighted that the Fairlight coastal zone buffer and Pett Level catchment both contain archaeological sites that need to be considered.
-AMBER
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
Representation ID: 23705
Received: 20/02/2017
Respondent: East Sussex County Council
Ecology.
-Land stability
Yes
Ecology.
-Land stability
Yes