Policy DHG2: Rural Exception Sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for 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.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. 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.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; 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 but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

Criterion (iv) is to be welcomed but experience elsewhere (see AiRS' work on this subject) would suggest that 'modest' may not be sufficient to get development off the ground in certain cases. AiRS spoke of examples of 70% market and 30% affordable. (Rother District Cllr Joy Hughes attended the Battle presentation by AiRS in October).

Exception sites are by their very nature rare. We therefore feel that where the land is coming forward at lower than market rates as is the case with exception sites, that there shouldn't be the need for market sales to provide further subsidy.

East Sussex County Council Representations on the Proposed Submission Rother Development and Site Allocations (DaSA) Local Plan

The County Council wish to make the following representations which seek modifications to make certain aspects of the Proposed Submission DaSA Local Plan sound. We also have some other comments and observations which relate to certain points that we raised at the draft consultation stage.

Minerals and Waste Planning

The comments below are made by East Sussex County Council in our role as the relevant Minerals and Waste Planning Authority for the plan area.

Soundness - Policy DEN3: Strategic Gaps

As identified in our previous comments on the Options and Preferred Options DaSA, Pebsham Household Waste Recycling Centre and Waste Transfer Station, which is a strategic safeguarded waste site, and the Pebsham Waste Water Treatment Works are located within the Bexhill and Hastings/St Leonards Strategic Gap (Policy DEN3), but are not within the Combe Valley Countryside park (Policy HAS1).

The East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP), adopted 2013, sets out the strategy for waste management within East Sussex, Brighton & Hove and the South Downs National Park. Policy WMP22 of the WMP supports proposals for increasing capacity within the boundaries of an existing waste management site and making the most efficient use of existing waste sites. This was a consideration in the identification of sites under the Waste and Minerals Sites Plan (2017).

The Council recognises the importance of retaining strategic gaps as set out in Policy DEN3. However, it is concerned that the stipulation that development may only occur within the strategic gap under exceptional circumstances undermines the ability of the WMP to make most efficient use of waste sites as supported by adopted Policy WMP22 of the WMP. This creates ambiguity between the two policies, and the Council therefore believes that Policy DEN3 is currently unsound on the grounds that it is not effective. 2

To resolve this soundness issue the County Council requests that the following text is inserted into the supporting text after paragraph 6.18:

"This Plan recognises that there are strategic waste facilities within the Gap. Proposals for the intensification of these facilities within their existing boundaries, as enabled by the Waste and Minerals Plan, are supported in principle and do not have to demonstrate exceptional circumstances, provided that the openness of the Gap is maintained."

Requested Minor Modifications

Reference is made to the Waste and Minerals Plan and the Waste and Minerals Sites Plan in section 1 which is appreciated. However, there is no mention of the safeguarding of minerals sites, wharves and railheads within the Rother Local Plan area, as identified in policies SP8 and SP9 of the Sites Plan and policies WMP14 and WMP15 of the Waste and Minerals Plan as previously suggested in the County Council's response to the Options and Preferred Options DaSA. It is requested that reference to these policies or to the safeguarding of mineral sites is made.

Presently, safeguarded waste and minerals sites do not appear to be referenced on the Rother Local Policies Map. It is requested that either the safeguarded minerals sites within the Rother Local Plan area are included in this Policies Map, or that reference to the Waste and Minerals Policies Map is made on the Rother Policies Map as required by article 9 of the Town and County Planning (Local Planning) (England) Regulations 2012 (as amended).

Paragraph 10.3 of the supporting text for policy HAS1 which concerns the Combe Valley Countryside Park refers to the continued use of land within the locality for waste collection, and states that such operations must be contained and should not conflict with the aims and objectives of the Combe Valley Countryside Park. This should refer to 'waste management' rather than waste collection.

Policy DEN3 states that development in a Strategic Gap will only be permitted in exceptional circumstances. Further clarity could be provided on what constitutes 'exceptional circumstances'.

Other Comments

The reference to the National Planning Policy for Waste in paragraph 1.22 is welcomed.

In section 2, the inclusion of policy DHG7 External Residential Areas item (iii) Waste and Recycling is welcomed.

With regards to policy RHA2: Harbour Road Employment Area, Rye Harbour, the comments made by the County Council in response to the Options and Preferred Options DaSA have been taken into account. Paragraph 11.204 and policy RHA2 (vi) include text which requires proposals that could affect the wharf to demonstrate that capacity for landing, processing, handling and storage of minerals is safeguarded. This is strongly supported. Recognition of the waste management operation at Rye Oil is also appreciated.

Alterations to the Sustainability Appraisal are noted, and references to Commercial & Industrial Waste and Construction, Demolition and Excavation Waste are appreciated.

Alterations to the Sustainability Appraisal are noted, and references to Commercial & Industrial Waste and Construction, Demolition and Excavation Waste are appreciated.

Highway Authority

ESCC Cycling and Walking Strategy

Although the Cycling and Walking Strategy is briefly mentioned in the introduction section on page 13 we would request that a minor modification is made by adding the following text in the opening pages of the Bexhill site allocations chapter (pages 113-115) and the opening pages of the Hastings Fringes chapter (pages 175-178):

ESCC are in the process of developing a County wide Cycling & Walking Strategy, which will aim to deliver cycling and walking infrastructure on key corridors of movement between residential areas (including new developments) and key trip attractors, including education, employment, retail and leisure activities'.

Proposed site allocations

The County Council, in our role as the relevant Highway Authority for the plan area, have worked closely with Rother District Council in the production of the DaSA Local Plan and provided input at the Options and Preferred Options stage. For this reason, we do not wish to oppose the principle of the proposed allocations. However, we do seek some minor modifications to certain policies, and also wish to raise a soundness concern over one particular policy (BEX10). Despite this, we have set out below how we consider this soundness issue can be addressed by way of a modification to the policy in question.

It is recognised that a number of the proposed allocations have been, or are subject to planning applications that the Highway Authority has provided comment on (i.e. BEX1, BEX2, BEX7 and BEX9). In light of our involvement and our stated positions on the applications for these sites, alongside the evidence supporting the plan, we do not wish to object and raise concerns over the soundness of those particular proposed allocations.

BEX3: (Land at North Bexhill -Infrastructure) and sub-policies BEX3a, BEX3b, BEX3c

Policy BEX3c imposes a traffic calming requirement (criteria iii b) but Policy BEX3b doesn't. This does not suggest consistency across the three sites/sub-policies of BEX3 - as all traffic and most non-vehicular movement from the 3 sites reaches the proximity of Mayo Lane.

We therefore request that minor modifications are made to Policy BEX3 and BEX3c:
-that the policy criteria of Policy BEX3c (iii) (b) regarding traffic management is deleted from BEX3c and is instead written into the shared infrastructure policy (Policy BEX3).

BEX4: Land at Former High School Site and Drill Hall, Down Road, Bexhill
We agree with policy text in point (v) regarding the transport assessment.

We recommend that there should be a masterplan/design brief as the uses are specific and sustainable transport/connectivity should be a key feature.

The main impact of this development from a highways perspective will be on the trunk road.
BEX10: Land at Northeye (Former UAE Technical Training Project)

From a transport perspective, we do not consider that the proposed allocation is in a sustainable location and a development on this site could be reliant on access to and from to be primarily made by private car. This is primarily the case due to the sites detachment from the main settlement of Bexhill (as recognised in paragraph 9.107 of the plan) and that few amenities, community facilities and employment opportunities exist within a reasonable walking distance of the site. However, the County Council recognises the overarching development strategy set out in the Local Plan 'Core Strategy' 2014 and the fact that the site is partly brownfield. Given this we do not wish to object to the principal of the proposed allocation. Instead, we wish to ensure that any development in pursuant of this allocation is able to take full advantage of, as well as make improvements to sustainable transport measures in the locality, as well as seeking to implement measures that minimise the risk of travel by private car.

We therefore request that there is a modification to the policy that requires a Travel Plan to be submitted and approved by us for any planning application on the site. The Travel Plan will need to demonstrate how opportunities for walking and cycling can be fully utilised (there are existing cycle lanes either side of the A259), as well as other sustainable transport measures (e.g. possible car club, measures that encourage journeys to be made by bike and bus, etc).

We also request that an amendment is made to criteria vii) of the policy. It is not just the bus stops we would wish to see improved, we would also want to see improvements which aid the accessibility of the bus stops - i.e. widening of footways and an improved crossing point on the A259.

It is considered that such modifications are required to the policy in order for it to be effective and consistent with national policy (in reference to the tests of soundness).
FAC1: Land at Former Market Garden, Fairlight Cove

The supporting text for the policy notes that the access to the site will be on roads that are unadopted and privately maintained. It is highly unlikely that this road could be brought up to an adoptable standard. Although the County Council does not wish to oppose the proposed allocation, we would ask that reference is made within either the supporting text, or the policy itself, that consideration will need to be given to creating safe pedestrian routes to and from the site, which is particularly important given the lack of footway on the unadopted highway.

WES4: Land between Moor Lane and the A28, Westfield

The indicative parking area for the proposed allotments is located opposite a 4 way junction. Therefore it will be important to fully consider highway safety at planning application stage. It would be hazardous for vehicles to reverse out of the site into the main road and therefore the parking area should be designed in a way that removes the need to reverse out. It is suggested that reference is made to this requirement in paragraph 11.237 of the supporting text to the policy.

Ecology

Energy from biomass (Paragraph 2.17)
It should be noted that because Ancient woodland requires ongoing management it does have some potential as a source for biomass energy.

Policy DHG2: Rural Exception Sites

We request the following minor modification: That biodiversity is added to Point (vi) of the policy i.e. to state that 'the development does not significantly harm biodiversity'.
Locally designated sites (Paragraph 6.3.4)

We request the following minor modification:

Delete the reference to 'East Sussex County Council' in this paragraph. This is because the Sussex Biodiversity Record Centre is the main contact for information on locally designated sites (the Sussex Local Wildlife Site Initiative and the Sussex Geodiversity Partnership are both hosted by the Record Centre).

Biodiversity and Green Space (Page 60)

We request that a minor modification is made:

Mention should be made of Habitats and Species of Principal Importance, as listed under Section 41 of the Natural Environment and Rural Communities Act 2006. The S41 lists are used to guide decision-makers, including local authorities, in implementing their duty under Section 40 of the Act to have regard to the conservation of biodiversity in England, when carrying out their normal functions. S41 habitats within Rother include woodland, maritime cliff and slopes, hedgerows and lowland meadows, and s41 species include hedgehog, common toad, house sparrow, brown-banded carder bee and pennyroyal.

Biodiversity opportunities in development: Paragraph 6.43

We request that the following minor modifications are made (additional words in italics and underlined) to paragraph 6.43 on page 84:

Ecological surveys and reports will be required to be submitted with planning applications for major development or where the development may impact on any designated sites, priority habitat of protected or notable species.

Housing allocation policy detail maps:

Policy detail maps show indicative layouts, but these may need to be adapted depending on the ecological constraints and opportunities. Site masterplans for allocated sites should be informed by an Ecological Constraints and Opportunities Plan (in line with BS42020:2013).


Lead Local Flood Authority

The Lead Local Flood Authority (LLFA) recognises that the Local Plan 'Core Strategy' was supported by a Strategic Flood Risk Assessment (SFRA) and that the DaSA sets out non-strategic policies within the overarching development strategy for the district. Recognising the content of paragraph 156 of the NPPF, it is not a requirement for the DaSA to be supported by an up-to-date version of the SFRA. Nevertheless, the LLFA would wish to place on record that when Rother District Council review their Core Strategy, it will be required to be supported by an up-to-date version of the SFRA. This is particularly paramount given that since the 2008 version has been produced, a significant amount of evidence has been collated by the LLFA on local flood risk matters in the district.

The LLFA notes that the DaSA has been informed by site assessments and a number of background evidence studies. This has included surface water flooding information and flood zone mapping provided by the Environment Agency.

In light of the above, the LLFA does not wish to challenge the soundness of the DaSA and oppose the principle of the proposed allocations. However, we would request that the plan acknowledges that in avoiding areas of flood risk and ensuring that appropriate drainage proposals are delivered on the allocated sites (in the form of SuDS) that the quantums of growth set within each proposed policy allocation may need to be compromised in some instances. This is considered essential given that the LLFA has yet to see detailed masterplanning that identifies the potential land-take for whatever the appropriate drainage method will eventually be implemented. We would therefore suggest that the terms "approximately" or "circa" are used prior to the stated amount of residential development allocated to the site in question.

The County Council is aware that Rother District Council intends to formally submit the DaSA Local Plan to the Secretary of State in January 2019. The County Council supports this course of action as we consider that the matters raised in this representation can be suitably addressed and resolved during the Examination in Public into the DaSA Local Plan.

Should you require any further information on these points please do not hesitate to contact myself.

Rye Conservation Society
Comments on Rother Development & Site Allocation Policies
Cabinet Version

November 2018

Development Policies

Resource Management

Policy DRM1: Water Efficiency

Limits daily household water consumption to no more than 110litres/person per day.
RCS supports.

Policy DRM2: Renewable Energy Developments
General support for low energy schemes where they meet other Core strategy and D&SAP policies. No support for large scale wind farms.
RCS supports.

Policy DRM3: Energy Requirements
Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floor space should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement.
RCS supports.

Communities

Policy DCO1: Retention of Sites of Social or Economic Value
18 month period to show that use is no longer a prospect of continuing use.
RCS supports.

Policy DCO2: Equestrian Developments
RCS supports.

Housing

Policy DHG1: Affordable Housing
Sets requirement for affordable housing % (Rye 305 on sites with 10 or more/. 3 hectares)
Viability still a factor although 2018 NPPF sets standard for viability threshold.
RCS supports

Policy DHG2: Rural Exception Sites
RCS supports

Policy DHG3: Residential Internal Space Standards
To adopt government space standards.
RCS strongly supports.

Policy DHG4: Accessible and Adaptable Homes.
All dwellings are required to meet M4 (2): Category 2 - Accessible and Adaptable Dwellings. This does not provide for wheel chair access but where there is an identified need on the Housing Register, sites that provide affordable housing in line with Policy DHG1, are as part of the affordable housing requirement, expected to provide 5% of the total housing requirement to meet M4 (3): Category 3 - Wheelchair Accessible Dwellings.
RCS supports.

Policy DHG5: Specialist Housing for Older People.
Supports such schemes with 'walkability' an issue.
RCS strongly supports.

Policy DHG6: Self-build and Custom House building.
Supports concept. On sites of 20 or more dwellings, provision for 5-10% of the total number of dwellings to be provided should be made available as serviced plots for self and custom house builders.

Plots should be made available and marketed through relevant marketing agencies for a period of at least 12 months. If the plots are not sold within this time period, the dwellings may be released for conventional market housing in line with the terms set out in the relevant legal agreement.

RCS supports.

Policy DHG7: External Residential Areas.
For dwellings, private rear garden spaces of at least 10 metres in length will normally be required.
Provision for car parking and safe and secure cycle storage should be made in accordance with Core Strategy Policy TR4 and East Sussex County Council's 'Guidance for Parking at New Residential Development' and 'Guidance for Parking at Non Residential Development'.
Waste and Recycling: Sufficient bin storage and collection points must be provided on all new residential developments and changes of use. Their siting and design should be considered at the outset.
RCS strongly supports.

Policy DHG8: Extensions to Residential Gardens.
RCS supports.

Policy DHG9: Extensions, Alterations and Outbuildings.
RCS supports.

Policy DHG10: Annexe.
RCS supports.

Policy DHG11: Boundary Treatments.
RCS supports.

Policy DHG12: Accesses and Drives.
RCS supports but notes that no specific mention is made of the need to deal adequately with rainwater run off.

Economy

Policy DEC1: Shopfronts, Signage and Advertising.
RCS generally supports but is concerned that the extent of permitted development rights relating to advertising/sign is at odds with thrust of policy, as has been shown in Rye. Would like to see permitted advertising rights suspended in Conservation Areas.

Policy DEC2: Holiday Sites.
RCS supports.

Policy DEC3: Existing Employment Sites and Premises.
Where continued employment use of a site/premises is demonstrated not to be viable, permitting complementary enabling development as part of an overall scheme to make most effective use of the property for employment purposes; and if a mixed use scheme is not viable, prioritising alternative community uses, affordable housing (where affordable housing would be sought in line with Policy DHG1) and then market housing, subject to local needs.
RCS supports.

Environment

Policy DEN1: Maintaining Landscape Character.
RCS supports.

Policy DEN2: The High Weald Area of Outstanding Natural Beauty (AONB).
RCS supports.

Policy DEN3: Strategic Gaps.
Strategic gap between Rye and Rye Harbour identified. Within these Gaps, development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive and not detract from the openness of the area. Enhancement of the Gaps through effective landscape management which strengthens and reinforces their significance as protected landscape areas will be supported.
RCS supports.

Policy DEN4: Biodiversity and Green Space.
Development proposals should support the conservation of biodiversity and multi-functional green spaces in accordance with Core Strategy Policy EN5. Larger developments of more than 2 hectares or 50 dwellings (whichever is the smaller) should produce a Green Infrastructure masterplan as part of their proposals.
RCS supports.

Policy DEN5: Sustainable Drainage.

RCS supports but would like to see requirement for all new water courses to be open accept for access requirements and for 'daylighting' where appropriate of existing culverts stated in policy not just in supporting text.

Policy DEN6: Land Stability.

General policy which does not identify Point Hill area as potential problem area.
RCS supports.

Policy DEN7: Environmental Pollution.
RCS strongly supports.
Implementation

Policy DIM1: Comprehensive Development.
RCS still has concerns as to the exact circumstances which will require a 'comprehensive' approach. How will this apply to Rock Channel, where there are two co incident sites, Bourne's and Jempsons? Will Martello (Bourne's) have to produce a 'fictitious ' master plan for both sites even though Jempson's may not be developed in the near future or will it be sufficient to show that suitable access has been maintained.
Policy need to be clarified as to where and how it is applied.

Policy DIM2: Development Boundaries.
RCS supports.

Site Allocation Policies

Overview Policy OVE1: Housing supply and delivery pending plans.
RCS supports.

Figure 16 identifies an updated residual requirement for additional homes on new sites of 6+ dwellings in each of the towns as at 1st April 2018

Figure 16: (Residual requirements to meet Core Strategy targets as at 1 April 2016) included:

http://www.rother.gov.uk/CHttpHandler.ashx?id=31170


RCS supports and notes adoption of lower end of Core Strategy target for Rye which it believes to be prudent given the development difficulties in Rye.

Northiam Parish Council (NPC)
Comments on Rother Development & Site Allocation Policies
Cabinet Version
November 2018

1. Introduction

1.1 Legislation establishes a clear "plan-led" planning system and requires local planning authorities to produce a Local Plan for its area.

1.2 In September 2014, the Council adopted its Rother Local Plan 'Core Strategy', which sets out its vision, overarching development strategy and strategic policies for development and change, and conservation, for Rother District over the period up to 2028. The Core Strategy identified the need to prepare this further Plan to both set out more detailed 'development policies' for certain topics in order to assist in determining proposals and to identify specific 'site allocations' to deliver the agreed housing and other development targets.

1.3 This Development and Site Allocations ("DaSA") Local Plan is effectively "part two" of the Council's Local Plan. It has been prepared to be in general conformity with the Core Strategy and has the same time horizon.

1.4 Together with the Core Strategy, this DaSA Local Plan provides the basis for determining planning applications in much of the district and supersedes all generic policies and relevant spatial policies from the earlier 2006 Rother District Local Plan.

1.5 The Core Strategy replaced the broader policies of the earlier 2006 Rother District Local Plan. This Local Plan now supersedes most of the remaining more detailed 2006 Local Plan polices, as listed at Appendix 2, exceptions being a few 2006 policies, mainly site allocations, not covered by this Local Plan but within a neighbourhood area where a Neighbourhood Plan is yet to be made.

1.6 National planning policies are contained in the 'National Planning Policy Framework' (NPPF). Local planning policies should be consistent with national planning policies, unless there are reasons justifying a local exception. The NPPF is also a material consideration in determining applications.

1.7 The NPPF defines the purpose of the planning system in terms of contributing to "sustainable development", with three interdependent economic, social and environmental objectives. It includes a 'presumption in favour of sustainable development', which is applied locally through Core Strategy Policy PC1.

1.8 The first NPPF, published in 2012, has recently been revised through the publication of a new NPPF in July 2018. While this Local Plan has been prepared to accord with the 2012 NPPF, notably in terms of housing provisions (which are set by the current Core Strategy), regard has also been had to the 2018 NPPF. Hence, it is believed that this Plan's policies, as set out in Part A and Part B, are also consistent with this latest statement of Government policy.

1.9 These development policies apply to all development applications including those relating to a site within a area with a Neighbourhood Plan which. When the D&SAP is formally adopted the policies within the D&SAP will have primacy over local neighbourhood plan policies unless there is a compelling case for the adoption of the NP policy.

Development Policies

Resource Management

Policy DRM1: Water Efficiency
Limits daily household water consumption to no more than 110litres/person per day.
NPC supports.

Policy DRM2: Renewable Energy Developments
General support for low energy schemes where they meet other Core strategy and D&SAP policies. No support for large scale wind farms.
NPC supports.

Policy DRM3: Energy Requirements
Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floor space should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement.
NPC supports.

Communities

Policy DCO1: Retention of Sites of Social or Economic Value
18 month period to show that use is no longer a prospect of continuing use.
NPC Strongly supports.

Policy DCO2: Equestrian Developments
NPC supports.

Housing

Policy DHG1: Affordable Housing
Sets requirement for affordable housing % (Rye 305 on sites with 10 or more/. 3 hectares)
Viability still a factor although 2018 NPPF sets standard for viability threshold.
NPC supports

Policy DHG2: Rural Exception Sites
NPC supports

Policy DHG3: Residential Internal Space Standards
To adopt government space standards.
NPC strongly supports.

Policy DHG4: Accessible and Adaptable Homes.
All dwellings are required to meet M4 (2): Category 2 - Accessible and Adaptable Dwellings. This does not provide for wheel chair access but where there is an identified need on the Housing Register, sites that provide affordable housing in line with Policy DHG1, are as part of the affordable housing requirement, expected to provide 5% of the total housing requirement to meet M4 (3): Category 3 - Wheelchair Accessible Dwellings.
NPC supports.

Policy DHG5: Specialist Housing for Older People.
Supports such schemes with 'walkability' an issue.
NPC strongly supports.

Policy DHG6: Self-build and Custom House building.
Supports concept. On sites of 20 or more dwellings, provision for 5-10% of the total number of dwellings to be provided should be made available as serviced plots for self and custom house builders. Plots should be made available and marketed through relevant marketing agencies for a period of at least 12 months. If the plots are not sold within this time period, the dwellings may be released for conventional market housing in line with the terms set out in the relevant legal agreement.
NPC supports.

Policy DHG7: External Residential Areas.
For dwellings, private rear garden spaces of at least 10 metres in length will normally be required.
Provision for car parking and safe and secure cycle storage should be made in accordance with Core Strategy Policy TR4 and East Sussex County Council's 'Guidance for Parking at New Residential Development' and 'Guidance for Parking at Non Residential Development'.
Waste and Recycling: Sufficient bin storage and collection points must be provided on all new residential developments and changes of use. Their siting and design should be considered at the outset.
NPC supports.

Policy DHG8: Extensions to Residential Gardens.
NPC supports.

Policy DHG9: Extensions, Alterations and Outbuildings.
NPC supports.

Policy DHG10: Annexe.
NPC supports.

Policy DHG11: Boundary Treatments.
NPC supports.

Policy DHG12: Accesses and Drives.
RCS supports

Economy

Policy DEC1: Shopfronts, Signage and Advertising.
NCP supports.

Policy DEC2: Holiday Sites.
NCP supports.

Policy DEC3: Existing Employment Sites and Premises.
Where continued employment use of a site/premises is demonstrated not to be viable, permitting complementary enabling development as part of an overall scheme to make most effective use of the property for employment purposes; and if a mixed use scheme is not viable, prioritising alternative community uses, affordable housing (where affordable housing would be sought in line with Policy DHG1) and then market housing, subject to local needs.
NPC supports.

Environment

Policy DEN1: Maintaining Landscape Character.
NCP strongly supports.

Policy DEN2: The High Weald Area of Outstanding Natural Beauty (AONB).
NCP strongly supports.

Policy DEN3: Strategic Gaps.
Not applicable to Northiam

Policy DEN4: Biodiversity and Green Space.
Development proposals should support the conservation of biodiversity and multi-functional green spaces in accordance with Core Strategy Policy EN5. Larger developments of more than 2 hectares or 50 dwellings (whichever is the smaller) should produce a Green Infrastructure masterplan as part of their proposals.
NCP supports.

Policy DEN5: Sustainable Drainage.
NCP supports but would like to see requirement for all new water courses to be open accept for access requirements and for 'daylighting' where appropriate of existing culverts stated in policy not just in supporting text.

Policy DEN6: Land Stability.
NCP supports.

Policy DEN7: Environmental Pollution.
NCP strongly supports.

Implementation

Policy DIM1: Comprehensive Development.
Policy needs to be clarified as to where and how it is applied

Policy DIM2: Development Boundaries.
NCP supports.

Site Allocation Policies
Overview Policy OVE1: Housing supply and delivery pending plans.

NOR 1
Policy NOR1: Land south of Northiam Church of England Primary School.
Northiam

Land south of Northiam Church of England Primary School, as shown on the Policies Map, is allocated for housing. Proposals will be permitted where:

(i) Some 6 dwellings are provided, of which 40% are affordable;

(ii) vehicle access is to the A28 to the satisfaction of the Highway
Authority;

(iii) existing trees on the eastern and western boundaries, protected by Tree Preservation Orders, are retained; and the hedgerow on the eastern boundary is retained and enhanced with native species; and

(iv) an assessment and evaluation of the she's archaeological potential has been carried out and mitigation measures are implemented.

NPC supports.

NOR 2
Policy NOR2:Land south of The Paddock/Goddens Gill Northiam

Land south of The Paddock Goddens Gill, as shown on the Policies Map, is allocated for residential development. Proposals will be permitted where:

(i) either:

(a) some 52 age-restricted dwellings for older people are provided;
or

(b) some 36 dwellings are provided. In both cases, 40% of the dwelling units shall be affordable.

(ii) vehicle access b via The Paddock to the satisfaction of the Highway
Authority;
(iii) tree belts and hedgerows on (he site boundaries are maintained and reinforced with planting of native species, and provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), on the eastern boundary, between the edge of development and the ancient woodland.

We have concerns as to the proposed density of dwellings on this site

Appendix B: D&SAP Policies attached:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31180