QUESTION 104: Do you agree with the preferred sites for permanent Gypsy and Traveller pitches across the District? If not, which site(s) should be preferred?

Yes agreed

I do not object to the allocation of land at Loose Farm Lane and around Bexhill, but I do not agree with the preferred sites for permanent GT pitches for the following reasons-

1-fails to address existing need (which is clearly underestimated in the Core Strategy). The need is clearly far greater than 6 pitches. There are at least 4 households on existing sites with temporary consents. Policy fails to explain the approach to be taken for those who do not meet the definition of GT in PPTS but who are ethnically Gypsy Travellers and whose preference to live in caravans even if they no longer travel for work needs to be addressed under the Council's Equality Duty and Human Rights obligations.
2- fails to meet the immediate need from the two sites with temporary consent-they will not be accommodated on the single small family site as proposed.
3-fails to provide sufficient choice of site by location and choice. It is unclear what additional social provision will be made for those using the Robertsbridge site. Sites are concentrated in just 2 locations in the south of the district at Battle and Bexhill. No additional provision is made in the rest of the district yet housing is proposed in many rural settlements. The sites looked at may have been spread across the district but the choice made if too limited and does not reflect where GTs are living.
4-Inequitable approach to site provision. Exceptions are made to AONB for many housing schemes in villages in the AONB yet there is no provision for any GT sites for those families living in the AONB at present as part of these housing schemes or on site with temporary consents nearby. This approach breaches the Equality duty. Provision is made for housing but not caravans in the AONB..
5-Uncertainty when the Bexhill sites will be delivered . it will be v dependent on housing schemes being granted and implemented. Unclear what mechanism is in place to ensure the sites will be developed and when. Experience elsewhere suggests house builders will aim to develop sites for GTs last in the hope they will get out of doing so,

Site allocation Policy should be amended to include the two sites with temporary consents at

BL4 Coldharbour Farm estates, Dallington-because there is no good reason to reject this site. it is no more intrusive in the AONB that other housing schemes in the district. The visual harm relied on is v weak. The harm identified by Inspectors is overstated and they have not done the comparison with other sites granted eg Beeches Brook. This part of the AONB is not devoid of residential development. The fact a site can be seen from some v distant and v limited viewpoints does not necessarily man that it is causing harm to the landscape characteristics of the wider surroundings. This site is viewed in association with the adjoining commercial and residential buildings. This site can be delivered . The occupiers have access to buildings on adjoining land for the storage of goods/ equipment used as part of the need to travel for work. There is no suitable alternative site for the existing occupiers.

SP6/7-Brambles Farm Ewhurst because of the length of time this site has been occupied / consent renewed and the Council has still failed to make alternative provision for this site as part of housing schemes nearby in the same AONB. Officers recognise that this site is well screened behind existing farm buildings. Harm to the AONB is exceptionally limited due to other authorised development on this site. The location is good and the Council has permitted additional housing nearby. At p322 the Council agree that the village has a number of services and amenities. If Staplecross is acceptable for more housing (including affordable housing) there is no justification to take issue with this location for a GT site. This is not an unsustainable rural location. It has been established at appeal that the kids on this site walk into Staplecross to catch the bus. This site is deliverable and there is no suitable alternative site for the existing family-who now have need for their adult children. To dismiss this site for want of some more screening is pitiful. At the last appeal we had to stand on tip toe to see over the hedge to glimpse the top of the caravans on the site. The new houses in Staplecross encroach into the AONB requiring the development boundary to be amended. The schemes make no concession to the AONB setting. It is quite shocking that no provision was made for a Traveller site knowing that there is a need locally for this type of accommodation which is every bit as pressing as the need for affordable housing in the Ewhurst Parish. As the village of Staplecross is considered suitable for affordable housing there is no justification to doubt the suitability of Brambles Farm for a Traveller site. The occupants will be no further to services and no less reliant on a car than the occupiers of the new homes in Staplecross. No one would expect any one to live in Staplecross without access to a car as the local amenities, whilst good, area still limited. Given this site is part of a small holding with land and buildings which are used in connection with the wok undertaken by the occupants this is a very suitable site for Travellers who still travel for work.

Neither of these two sites is any more intrusive than the development permitted at Beeches Brook, Telham lane, Battle. Indeed, having represented all these clients I am of the opinion Beeches Brook is visually the most sensitive site, especially in winter. It is clear from the appeal decisions at Beeches Brook that different Inspectors view things differently. What matters is that a comparative assessment is made of the most suitable sites. This is not undertaken at planning appeals. The Council has FAILED to undertake a proper, meaningful assessment of the merits of all these sites relying instead on appeal decisions where Inspectors were not invited to weigh up the benefits of individual sites.
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The occupants of these two sites do not want to / and should not be expected to have to relocate to Battle or Bexhill which are no where near where they have settled and lived for many years. If these sites are not considered acceptable provision should be made in nearby villages for these families-not some distance away in Bexhill or Battle.

For the above reasons policy as drafted fails to address need in an appropriate way and is contrary to PPTS/NPPF

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

We agree with the proposed allocation of sites for permanent gypsy and traveller pitches.

We agree with the proposed allocation of gypsy and traveller sites.

Support the preferred sites.

I agree with the prospective sites. Robertsbridge already has a substantial site.

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

OTHER POLICIES Page 337

Gypsies and Travellers

The sites would need to be assessed in relation to archaeological potential and areas of significant remains scoped out.
-AMBER

Traveller Liaison Team

OTHER POLICIES

We agree with the plans for both preferred sites and think that the location of these meets the needs of the community and does not have a detrimental effect on the landscape.

Our concerns regard proposals for development of land to the north of /Bexhill.

Firstly as a resident and land owner in Watermill lane.

As with anything concerning the new road in progress and proposed future development any information has been very quiet and very poorly publicised especially for those concerned.

No provisions for anyone not being computer literate have been made and yes there are many people out there who this affects.

So few people know what is going on. A properly well-advertised consultation should be given.

Three options, one preferred, all with a large number of housing (no schools, doctors).

The maps all very confusing, probably done on purpose

Although it was as I understood no development beyond the road a proposed business park on options two & three.

Option two has a road to housing estate and traveller park off the new road which then leads to cut through to Sidley!

All three options have a traveller park.

I most adamantly oppose this for these reasons:

In 2007 / 2008 we had a series of very unpleasant experiences with travellers living in that area.

We have a footpath that runs across the back of our caravan park this was used by the travellers for access for theft.

Bearing in mind the already many problems caused at the Acton Farm area just off the new link road where the public has access we fear that we will have no privacy for our customers or safety from such happening again.

Proposed access roads are marked on the plan PROPOSED !! the one for the travellers sight is already in.

We propose that the existing footpath be re routed along the new road and no longer on our property.

Already on the plans you have removed a footpath from Watermill lane to Ninfield road.

Also provision for horses has seemed to not be mentioned. We will not go away we need safe access.

Although a new country park has been provided we still have to get to it and crossing has to be safe.

Alternatively we will ride the distance from Watermill lane to Buckholt as I take it there will be no restriction by law for horses.

The potential pedestrian link between the two should include horses.

The caravan park has been in our family since 1980 in its third generation we have spent much money on improvements and drawn our customers from the people who like a peaceful time in the quiet rural countryside. This is all about to change. We have no control over it and will have to totally redevelop it to suit a completely different customer, ones that like Constant road noise, we are not sure that this will work so our future cannot rely on getting through the period when development takes place which we are presuming is over a period of several years we have no other means of revenue.

Can you provide compensation for this period. We are already experiencing noise pollution and road access difficulty, saying you are keeping access is not acceptable if a customer has a £20,000 caravan to squeeze through the space of a family car and cover it in mud !!

(Already being experienced with the removal of trees in Watermill Lane)
Also the document holiday sites, it is a great possibility that the whole very popular area of our caravan and mostly camping area will be unusable in the future due to the impact of noise therefore we may need to take steps to move and alter the whole of the caravan park using an area that at the moment is not within our licence.

We have very little suitable land left and the most obvious is that of which the previously mentioned footpath runs straight through.

We would then come under scrutiny from these proposals extra expense loss of revenue.

It will be interesting to see if any consideration is given to a long standing Bexhill business that has benefited many small businesses by its regular custom to the area.

We await your response.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28143