Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26287
Received: 17/07/2024
Respondent: Burwash Parish Council
Hard to see how the opportunities will be achieved or realised.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26725
Received: 23/07/2024
Respondent: Rother Environmental Group
Housing figures for communities – No village should have an absolute zero allocation for additional housing growth, otherwise that community will over time atrophy.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26995
Received: 22/07/2024
Respondent: Northiam Parish Council
NPC accepts that scope for development is limited due to factors such as flooding, the HWNL (AONB) and access issues.
See attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27027
Received: 22/07/2024
Respondent: Mr Richard & Rosie Philipps Jones
Number of people: 2
Our views of the draft about Iden (pages 46 to 52) are that Rother has completely overturned the current plan based upon years of cooperation with the outlying settlements which is reflected in existing Local Plan. We believe that this occurred as a consequence of the local elections in 2023.
Nonetheless we support the need for modest (affordable housing) but we cannot change the basic fact as stated in the current plan: "There is very limited scope for development in and around the village." and ..."development to the south would inappropriately extend growth along Main Street, encroaching into an area of rural character.
The 312 bus service is 2 hourly, the pub is closed indefinitely although there is a strong will within the community to take it over. Horse riding is abundant as is cycling with serious walkers and runners going on.
We refer to ROTHER DISTRICT COUNCIL DRAFT HOUSING AND ECONOMIC LAND AVAILABILITY ASSESSMENT (HELAA)
Part 2: Site Assessments
Chapter 4 - Rye and the Eastern Settlements Cluster
There are 2 general points we should like to make on the draft vision for Rye and the eastern network settlements.
Rye is a popular tourist destination despite an infrequent hourly train service from Ashford and from Eastbourne. Access by road is similarly awkward with no major highways
We believe that Rother's approach to the regional housing problem is cumbersome and limited in that the council seems to be attracted to potential sites merely because the land owner has approached the council to sell parcels of land without giving a lot of thought to the impact on existing residents and the country side. The net result is housing being built for tourism which of course enriches the few but not the many less wealthy people and others who just love their environment as it is.
Our views of the draft about Iden (pages 46 to 52) are that Rother has completely overturned the current plan based upon years of cooperation with the outlying settlements which is reflected in "Rother District Council Development and Site Allocations Local Plan dated 16 December 2019". We believe that this occurred as a consequence of the local elections in 2023. It would seem that something similar will occur after the 2024 general election.
Nonetheless we support the need for modest (affordable housing) but we cannot change the basic fact as stated in the current plan: "There is very limited scope for development in and around the village." and ..."development to the south would inappropriately extend growth along Main Street, encroaching into an area of rural character.
The 312 bus service is 2 hourly, the pub is closed indefinitely although there is a strong will within the community to take it over. Horse riding is abundant as is cycling with serious walkers and runners going on.
The current proposed development behind Conkers (IDE 0001 and IDE 0011) is beset with problems of access and proximity to listed buildings of which there are relatively many nearby. Main Street is increasingly dangerous with passing traffic having to navigate a curving narrow rural road, sadly made worse by frequent speeding well above the 30 mph limit
On the other hand, there is a brownfield site (IDE0014) which is home to a very few small businesses using old apple packing sheds This site has decent access to Wittersham Road would be more appropriate than IDE0010 which the draft suggests:
"The site could be suitable for a short terrace of small
houses fronting Main Street, which would continue the adjoining
ribbon development northwards" To describe a charming set of mid-19th century built affordable homes in such a way is incongruous if not dishonest.
It is quite odd that IDE 0021 is assessed in the draft as follows: "development into the remainder of the field would not be appropriate as this would be out of keeping with and harmful to the settlement pattern and the rural setting of the village within the countryside of the National Landscape, and could harm the setting of the adjacent listed buildings."
IDE0010 is an important part of the rural setting of Iden. It is what impacts visitors and residents alike. I believe a development here would be a serious error and should be refused.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27343
Received: 22/07/2024
Respondent: Oak Tree Homes Trust
Agent: Greenhayes Planning
See points 3 to 6 in the "Reps- Oak Tree Homes Trust final 2207" attachment.
See attached documents which comprise the submission:
- Reps- Oak Tree Homes Trust final 2207 (which includes appendices 1-3); and
- 4019_Technical Note_Pond Cottage Main Street Peasmarsh_May24 (Appendix 4).
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27600
Received: 23/07/2024
Respondent: Southern Housing
We support the approach in principle and welcome the fact new transport infrastructure is intended for Rye and the surrounding area. This should help deliver the identified growth for the area. RDC should work closely with ESCC and the adjoining authorities in Kent, including Kent County Council, to ensure suitable transport infrastructure is delivered. We also support the aim to improve cycling and pedestrian routes.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27771
Received: 23/07/2024
Respondent: Rye Neighbourhood Plan Steering Group
Development Target Comparison, please see below for reconciliation
See Table at page 10/11 of attached submission document.
Please see attachment
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28089
Received: 23/07/2024
Respondent: Kingacre Estates
Agent: Nexus Planning
Paragraph 5.8 of the Draft LP confirms that the most appropriate spatial development options to take forward as
Rother’s proposed development strategy is a combination of the following options:
a. Brownfield intensification and redevelopment within sustainable settlements (Option reference SDO6);
b. Bexhill greenfield growth on the northern and western edges of the built-up area of Bexhill to create new
compact, connected communities (SDO3A);
c. Hastings Fringes urban growth (SDO5);
d. Radial settlement network connected to Bexhill and Hastings (SDO2);
e. Village clusters centred around Rye and Battle (SDO1); and
f. Sustainable settlement growth (SDO4) with longer term, a focus on the A21 Corridor (SDO10).
6. The Development Strategy Background Paper (April 2024) describes option SDO1 (Village Clusters) as a cluster of
villages that are connected with each other to form a sustainable community. One of the clusters identified is
centred around Rye and includes the village of Broad Oak.
7. The Vision for Rye and the Eastern Settlement Cluster sets out that:
“The eastern cluster of settlements will be better connected by sustainable transport infrastructure, with Rye
acting as a key transport hub, and local economies will continue to grow, respecting the historic development pattern of rural communities over time. The strengthened connections to Rye as a sustainable market town,
will allow for sensitive development in adjoining villages.”
8. Section 2 of the Framework considers achieving sustainable development. Paragraph 7 states that:
“The purpose of the planning system is to contribute to the achievement of sustainable development,
including the provision of homes, commercial development, and supporting infrastructure in a sustainable
manner.”
9. Paragraph 11 discusses the presumption in favour of sustainable development and states that:
“For plan-making this means that:
a. all plans should promote a sustainable pattern of development that seeks to: meet the development needs
of their area; align growth and infrastructure; improve the environment; mitigate climate change (including
by making effective use of land in urban areas) and adapt to its effects;
b. strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses.”
10. Kingacre Estates support the Council in seeking to address the sustainable longer term strategy for villages in
rural locations. It is key to address the need for housing within the rural areas in line with spatial objective 4 of
the Draft LP. However, this needs a strategic approach which directs residential development to those villages in
close proximity to nearby towns, such as Broad Oak, where sustainable transport options, including bus stops
(providing regular services to Robertsbridge, Westfield, Peasmarsh, Mountfield and Battle), and services and
facilities such as a primary school, convenience store, bakery and public house are all available. Broad Oak is
demonstrably a sustainable location for development.
11. It is clear that in its spatial strategy, the Council has had regard to encouraging development in locations with
strong access to key services and facilities and sustainable travel connections, which accords with paragraphs 7
and 11 of the Framework, as well as spatial objectives 1, 7 and 9 of the Draft LP.
12. The Housing and Economic Needs Assessment (February 2024) confirms that the Standard Method calculation
results in a minimum Local Housing Need (LHN) figure of 737 dwellings per annum (dpa), which equates to 7,370
dwellings over the Plan Period. As set out elsewhere in our representations, Kingacre Estates considers that for
the Draft LP to effectively achieve spatial objective 4, it should explore opportunities to exceed the minimum
LHN figure in setting its housing requirement, to more effectively address the issue of affordability within the
rural areas and ensure a reliable delivery of housing to meet local needs.
Rye and the Eastern Settlement Cluster – Distribution and Growth Opportunities
13. The Vision for Rye and the Eastern Settlements Cluster within the Draft LP states that the eastern cluster of
settlements will be better connected by sustainable transport infrastructure, with Rye acting as a key transport
hub, and local economies will continue to grow, respecting the historic development pattern of rural
communities over time. The strengthened connections to Rye as a sustainable market town, will allow for
sensitive development in adjoining villages.
14. Figure 25 of the Draft LP illustrates the potential development strategy for Rye and the eastern settlements
cluster. Specifically, relating to Broad Oak, this sets out the following:
a. identified level of housing growth – 52 dwellings;
b. potential additional level of housing growth – 11 dwellings; and
c. total potential housing growth – 63 dwellings
The Council’s Sustainability Appraisal (April 2024) presents an assessment of the available sites in the district for
development, and this has informed the Council’s overall spatial strategy. It is worth noting that the Site is
identified as an available site and scored highest, out of the seven sites located within Broad Oak, against the 20
Sustainability Appraisal Objectives.
16. Kingacre Estates supports the Council in directing strategic development towards sustainable locations within
the rural areas, particularly Broad Oak. To further support the Council’s Spatial Strategy and housing delivery,
and to more effectively achieve spatial objective 4, the Draft LP could explore opportunities to exceed the
minimum LHN figure in setting its housing requirement. This would more effectively address the issue of
affordability within rural areas and ensure a reliable delivery of housing to meet local needs. As identified above,
Broad Oak is a sustainable location within the rural area and Kingacre Estates would suggest that the Council
looks to deliver 63 dwellings as an absolute minimum over the Plan Period.
17. Of course, as an absolute minimum, the Council must roll forward existing, currently undeveloped allocations,
given that these have already been determined to be sustainable and appropriate through the examination
process for the DaSALP (confirmed again in the Sustainability Appraisal accompanying the current consultation).
This is essential in any event but will best support spatial objectives 1, 2, 3, 4, 7 and 9 of the Draft LP.
Conclusion
18. Kingacre Estates supports the approach taken by the Draft LP in seeking to deliver strategic development at
sustainable settlements in the rural areas. Land to the south of Broad Oak Public House aligns with this strategy
and the spatial objectives of the Draft LP as it would:
a. Deliver a residential development within a sustainable location within the rural area (in accordance with
Draft LP spatial objectives 1, 4 and 7);
b. Ensure development is accessible and located within close proximity to sustainable transport (in
accordance with spatial objectives 1, 7 and 9);
c. Provide housing to meet local needs and address affordability issues (in accordance with spatial objective
4);
d. Address the short-term housing needs of Broad Oak as it can come forward quickly and provide a
meaningful contribution towards delivering the housing needs of the district (in accordance with spatial
objectives 4); and
e. Provide an opportunity to deliver a high-quality attractive new development within Broad Oak, which
protects and enhances valued and high-quality landscapes (in accordance with spatial objectives 2 and 3).
19. However, Kingacre Estates consider that in order to support the Draft LP’s vision and objectives even further, the
Council should explore opportunities to exceed the minimum LHN figure.
20. To ensure that suitable and available sites are brought forward, the Council should roll forward unbuilt existing
allocations as a minimum, and then look to explore new appropriate allocations
Please see three separate attachments for the full representations