Policy DHG4: Accessible and Adaptable Homes

Showing comments and forms 1 to 8 of 8

Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24007

Received: 20/11/2018

Respondent: Rye Town Council

Representation Summary:

Agree; complements RNP D1

Full text:

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 We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA.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

Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24156

Received: 06/12/2018

Respondent: Salehurst & Robertsbridge Parish Council

Representation Summary:

We applaud the adoption of the higher standard in para 2.

Full text:

We applaud the adoption of the higher standard in para 2.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24217

Received: 07/12/2018

Respondent: Burwash Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Burwash like many areas of the country has a growing elderly population. As part of our Neighbourhood Plan considerations we recently carried out a Housing Needs Survey which showed that there were two principal areas of housing need :

a. Social housing for young families (more on this in DHG1 above)

b. Small 1/2 bed bungalows for sale to existing residents to move to leaving behind larger unsuitable in accessible family homes

Full text:

Burwash like many areas of the country has a growing elderly population. As part of our Neighbourhood Plan considerations we recently carried out a Housing Needs Survey which showed that there were two principal areas of housing need :

a. Social housing for young families (more on this in DHG1 above)

b. Small 1/2 bed bungalows for sale to existing residents to move to leaving behind larger unsuitable in accessible family homes

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24340

Received: 06/12/2018

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The policy is unsound as it is not justified in line with planning guidance which requires local authorities to demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, different needs across tenure and the overall impact on viability. It is therefore incumbent on the Council to provide a local assessment evidencing the specific case for Rother which justifies the inclusion of optional higher standards for accessible / adaptable homes. Whilst the impact of the accessibility standard on viability has been tested, we could find no evidence, as required by PPG, with regard to, for example, the existing housing stock and needs within different tenures. It is not the case that all homes will need to be developed to the higher accessibility standard and that many older people will find the higher accessibility standard set out in part M4(1) will be sufficient to meet their needs both now and in future.

Without the required evidence to support this policy the Council should not require all new homes to be built to the higher accessibility standard.

Full text:

DHG4: Accessibility and Adaptability Standard

The policy is unsound as it is not justified in line with planning guidance
Paragraph 56-007 requires local authorities to demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. It is therefore incumbent on the Council to provide a local assessment evidencing the specific case for Rother which justifies the inclusion of optional higher standards for accessible / adaptable homes in policy DHG4. Whilst the impact of the accessibility standard on viability has been tested, we could find no evidence, as required by PPG, with regard to, for example, the existing housing stock and needs within different tenures. It is not the case that all homes will need to be developed to the higher accessibility standard and that many older people will find the higher accessibility standard set out in part M4(1) will be sufficient to meet their needs both now and in future.

Recommendation

Without the required evidence to support this policy the Council should not require all new homes to be built to the higher accessibility standard.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24342

Received: 06/12/2018

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The Planning Practice Guidance (Paragraph 56-007) requires local authorities to evidence and demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. Whilst Gladman understand the need for the delivery of accessible homes the Council must provide a local assessment evidencing the specific case for the scale of need proposed in Rother. This should justify the inclusion of optional higher standards for accessible / adaptable homes in policy DHG4. At present Gladman do not conclude that the evidence justifies the application of the standards to all new build homes.

Full text:

Dear Sirs,

Re: Proposed Submission Development and Site Allocations Local Plan

Gladman write to offer some brief comments on the Rother Site Allocations Local Plan. It is noted that the document follows on from the original Core Strategy adopted in 2014. Gladman make specific comments on Part A and Part B of the Site Allocations Local Plan below, but as an overarching point we consider that given the Site Allocations Local Plan has a very short life span, less than 10 years even before its submission for examination, both the Core Strategy and the Site Allocations Local Plan should be reviewed immediately post adoption of the Site Allocations Local Plan. Otherwise the Local Plan is in danger of being time expired prior to a new plan being put in place. This is especially important given that the government's standard methodology for housing need is likely to increase the housing requirement significantly. We do not consider that the plan can be found sound without commitment for an immediate review.

PART A

Policy DHG4 - Accessibility and Adaptability Standards

The Planning Practice Guidance (Paragraph 56-007) requires local authorities to evidence and demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. Whilst Gladman understand the need for the delivery of accessible homes the Council must provide a local assessment evidencing the specific case for the scale of need proposed in Rother. This should justify the inclusion of optional higher standards for accessible / adaptable homes in policy DHG4. At present Gladman do not conclude that the evidence justifies the application of the standards to all new build homes.

Part B

Gladman do not wish to comment specifically on any of the individual allocations at this time, however we would comment on the overall level of housing supply within the plan. Paragraphs 8.1-8.18 set the context for the levels of development which have been achieved so far and the commitments that are made, a residual need of 1,574 dwellings to come forward through the Site Allocations DPD and Neighbourhood Plans is identified. The Site Allocations DPD confirms allocations for 1,562 dwellings in Figure 18, there is therefore a shortfall against the total requirement.

The plan is silent on the status of neighbourhood plans in Rother and whether or not it is realistic that the forthcoming neighbourhood plans will allocate the level of housing envisaged in Figure 18 and make up the difference in units aspired to hit the 5,700 unit total. What must also be remembered is that whilst the target may be 5,700 units to be delivered, there is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building any flexibility into the plan for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would in effect be a buffer to ensure overall plan levels of development are delivered is not sound.

Gladman consider it likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.

As a leading land promoter Gladman would welcome the opportunity to further discuss the content of this representation at the examination into the soundness of the Site Allocations DPD.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24433

Received: 07/12/2018

Respondent: Persimmon Homes Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy is objected to. The DaSA and its evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. Planning Practice Guidance sets out that the need for M4(2) and M4(3) must be demonstrated, as these are optional standards above the mandatory M4(1).

An "Accessible and Adaptable Housing" Background Paper has been prepared by the Council, providing evidence from a number of sources, including census, Local Authority Housing Statistics, and household projection figures. However, the conclusions drawn amount to nothing more than conjecture.

The evidence indicates an ageing population across the plan period. However, the implementation of the optional standards is excessive and does not account for the many older people who will find the higher accessibility standard in M4(1) to be sufficient.

It is recognised that an assessment on the viability of the proposals has been conducted. However, there is a lack of supporting evidence that supports the other criteria set out in the PPG.

Therefore the policy is insufficiently supported by the provided evidence. The Policy should be considered unsound and the requirement removed from policy.

Please see attached full representation for further information.

Full text:

Policy DHG4: Accessible and Adaptable Homes (Objection)

Policy DHG4 states that "the Council adopts the Optional Buildings Regulations for Accessible and Adaptable Homes" and that "All dwellings are required to meet M4(2): Category 2 - Accessible and Adaptable Dwellings." "Only in circumstances where it can be robustly demonstrated by the applicant that it is not practicable or financially viable to deliver the provisions above or where the requirements are clearly incompatible with conserving and enhancing historic character, will new development be exempt from either or both of these policy requirements."

This policy is objected to. The DaSA and its associated evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. Planning Practice Guidance Paragraph: 007 Reference ID: 56-007-20150327 sets out that the need for M4(2) and M4(3) must be demonstrated, as these are optional standards above the mandatory M4(1).

"There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:

the likely future need for housing for older and disabled people (including wheelchair user dwellings).

Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).

the accessibility and adaptability of existing housing stock.

how needs vary across different housing tenures.

the overall impact on viability.

An "Accessible and Adaptable Housing" Background Paper has been prepared by Rather District Council as part of the evidence base seeking to support the application of this policy. It provides evidence from a number of sources, including census data. Local Authority Housing Statistics, and household projection figures. However, the conclusions drawn from the supplied evidence amount to nothing more than conjecture.

The evidence provided shows an indication that the population across Rother will be an ageing one across the plan period, replicating the national trend. However, the implementation of the optional standards above and beyond the mandatory standard is an excessive step that does not account for the many older people who will find the higher accessibility standard that is detailed in M4(1) to be perfectly accommodative of their needs.

It is recognised that an assessment on the viability of the proposals has been conducted as part of the sustainability appraisal produced assessing the DaSA. However, there is a lack of supporting evidence, most notably a lack of evidence with regard to the existing housing stock and needs within different tenures that supports the other criteria set out in the PPG.

Therefore given the current supporting evidence base, policy requiring all new homes to be built to the requirements of M4(2) and 5% at M4(3) are insufficiently supported by the provided evidence. Therefore the Policy should be considered unsound and the requirement removed from policy.

Please see attached full representation for further information.

Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24465

Received: 07/12/2018

Respondent: Rye Conservation Society

Representation Summary:

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.

Full text:

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.

Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24495

Received: 07/12/2018

Respondent: Northiam Parish Council

Representation Summary:

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.

Full text:

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