Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25265
Received: 12/07/2024
Respondent: Richard Bailey
Agent: DHA Planning
Please see attached representation, existing and proposed sites plans.
Please see attached representation, existing and proposed sites plans.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25419
Received: 16/07/2024
Respondent: Denbigh Properties Ltd
Agent: DHA Planning
Please see attached:
- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan
Please see attached:
- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25919
Received: 23/07/2024
Respondent: Miss Judith Rogers
Why have you shown Northbridge Street as a separate place to Robertsbridge when it is part of Robertsbridge? This should be only one circled place. Has this been done deliberately to mask the actual population of Robertsbridge? This is mis-information. Any person not familiar with the area, including the inspector looking at this plan, would take your map on face value and may make wrong assumptions based on the incorrect information you have provided. This needs to be addressed before this plan can proceed further.
Why have you shown Northbridge Street as a separate place to Robertsbridge when it is part of Robertsbridge? This should be only one circled place. Has this been done deliberately to mask the actual population of Robertsbridge? This is mis-information. Any person not familiar with the area, including the inspector looking at this plan, would take your map on face value and may make wrong assumptions based on the incorrect information you have provided. This needs to be addressed before this plan can proceed further.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25998
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
Generally, our clients agree that sensitive and sustainable housing developments will help deliver the aims of the plan, however the proposed vision overarchingly suggests that no new development sites are required other than those already identified in the Ticehurst Neighbourhood Plan. This is considered unacceptable given the significant levels of lack of delivery of housing. They identify the clients two sites. TIC0043- Land at Cherry Tree Field, Lower Platts, Ticehurst and TIC0044- Land at Steellands Farm, Ticehurst, as potential additional growth. We believe that they are sustainably located and can be designed in a manner to minimise any impact on the National Landscape through sensitive design.
Generally, our clients agree that sensitive and sustainable housing developments will help deliver the aims of the plan, however the proposed vision overarchingly suggests that no new development sites are required other than those already identified in the Ticehurst Neighbourhood Plan. This is considered unacceptable given the significant levels of lack of delivery of housing. They identify the clients two sites. TIC0043- Land at Cherry Tree Field, Lower Platts, Ticehurst and TIC0044- Land at Steellands Farm, Ticehurst, as potential additional growth. We believe that they are sustainably located and can be designed in a manner to minimise any impact on the National Landscape through sensitive design.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26289
Received: 17/07/2024
Respondent: Burwash Parish Council
Overall aspirational as a vision. Employment opportunities in rural parish is overstated. Provision for 21st century working reality. The vision should include
protection of the unique river valleys along the Rother and Dudwell and the 'droveways' from the valleys and the green spaces between settlements.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26525
Received: 22/07/2024
Respondent: Tunbridge Wells Borough Council
See also response to Q51. TWBC
considers that in order to achieve the
proposed vision and deliver the potential
number of new dwellings and
employment floorspace over the plan
period, the Plan will require the
completion of the following evidence
base studies:
• Appropriate Landscape Impact
Assessment(s)/Setting Study
• Transport Modelling – both for the
strategic and local road networks
and a full assessment of the impacts
on Flimwell Junction.
• Flood risk modelling/assessments
The draft Rother Local Plan also
recognises that the residents within the
Northern Rother sub-area are likely to
use services and facilities outside of the
sub-area, including in Tunbridge Wells
Borough. TWBC would expect,
therefore, that the infrastructure
requirements to support the potential level of growth are fully investigated
through engagement with the relevant
infrastructure and other service providers
(as well as both East Sussex County
Council and Kent County Council) and
for this to be clearly evidenced in the
Infrastructure Delivery Plan and, as
appropriate, in Statements of Common
Ground. Appropriate mitigation should
be provided for any potential cross
boundary impacts on Tunbridge Wells
Borough following consideration and
discussion through Duty to Cooperate
meetings.
TWBC would welcome further discussion
with RDC on the proposals for the
Northern Rother sub-area and the
potential impact of this on Tunbridge
Wells Borough as the RLP is progressed.
TWBC would also welcome discussion
on the identified A21 growth corridor and
further details of what the aspirations are
for this area over the longer term. This
should include ongoing engagement with
Kent Council Council Highways in
particular, and with National Highways.
See attached document
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26547
Received: 20/07/2024
Respondent: Burwash Common and Weald Residents Association
3.2 Generally speaking we support the vision in the draft Local Plan for Northern Rother as set out on page 156. While the further development of modes of active travel can be applauded, it is very important to note that the relative lack of a public transport infrastructure and the age profile of the local population means that ‘active travel’ for many is unrealistic and travel by private car will remain the only viable mode of transport for many. It should not be made more difficult than it already is.
3.3 A particular issue for us, the residents of Burwash Common and Burwash Weald, is the relative remoteness of our nearest railway station, Stonegate. Once reached, Stonegate provides easy access north to Tunbridge Wells and London and south to Hastings. Perhaps some consideration could be given to the development of a scheme similar to the patient transport scheme that already exists in a different context to get people to and from the rail services at Stonegate?
Full submission attached
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26689
Received: 23/07/2024
Respondent: Devine Homes PLC
Agent: Nexus Planning
See attached submission (specifically pages 1 and 2) for comments on the vision for Northern Rother.
Please see attached full submission from Nexus Planning on behalf of their client Devine Homes regarding the Local Plan and HELAA Site SAL0012: Land at Bishops Lane, Robertsbridge
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27119
Received: 23/07/2024
Respondent: Batcheller Monkhouse
Housing Need
Representations relate to Housing Need, Preferred Spatial Development Options, Relevant Draft Local Policies and concern two parcels of land considered under the HELAA ref HUG0015. It is located within in the High Weald National Landscape area the Land at Yew Tree Farm is capable of accommodating some development without adverse effect on the natural beauty of the High Weald. The land is located entirely within Flood Zone 1. Paragraph 70 of the NPPF recognises that small scale developments can deliver housing at a faster rate, a small-scale development here could be delivered at a relatively quick rate. The Council should pursue a higher growth strategy to fully meet the full identified housing need for the plan period.
See attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27216
Received: 23/07/2024
Respondent: Homes England
Agent: Luken Beck
Please see the "Homes England - Draft Reps R18 plan and Hodson's Mill Robertsbridge" attachment, specifically page 14
See attachments for full submission comprising:
- Homes England - Draft Reps R18 plan and Hodson's Mill Robertsbridge (which also contains Appendices A and B);
- Appendix C - Landscape Statement; and
- Appendix D - Site Boundary
The submission contains general comments on the Local Plan and HELAA sites SAL0003 and SAL0024, as well as answers to specific questions as set out in the Local Plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27292
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
Generally, our clients agree that sensitive and sustainable housing developments will help deliver the aims of the plan, however the proposed vision overarchingly suggests that no new development sites are required other than those already identified in the Ticehurst Neighbourhood Plan. This is considered unacceptable given the significant levels of lack of delivery of housing. They identify the clients two sites. TIC0043- Land at Cherry Tree Field, Lower Platts, Ticehurst and TIC0044- Land at Steellands Farm, Ticehurst, as potential additional growth. We believe that they are sustainably located and can be designed in a manner to minimise any impact on the National Landscape through sensitive design.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27352
Received: 22/07/2024
Respondent: High Weald AONB Unit
‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.
‘Vision for Northen Rother’
We are concerned about the somewhat vague statement ‘bypasses to Flimwell and Hurst Green could
open up opportunities for future development along the A21 corridor.’ Any such proposals, both for bypasses and future development, would have the potential to impact significantly on the natural beauty
of the High Weald AONB. Certainly this statement should be qualified in the vision by the addition of
text such as ‘subject to careful consideration of impacts on the natural beauty of the High Weald
National Landscape….’ Moreover, as any potential for future development is as yet not assessed, it
may also be more appropriate to delete the reference to that, and instead focus the statement on the
role that such bypasses could play in achieving sustainable transport goals.
See attached full representation
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27445
Received: 22/07/2024
Respondent: Network Rail
Network Rail support the proposal to use the two rail stations as transport hubs around
which development can be brought forward. An approach which prioritises pedestrian and
cycling access to the stations should be maximised as should the quantum and density of
development of the sites.
Network Rail note the number of rejected sites in the HELAA around the Etchingham
station. The Council should review these if insufficient sites can be found elsewhere as
they are located in a highly sustainable location. Where sites are close to the station,
Network Rail can assist the Council in identifying of there are any impacts on the station
itself and how it functions. It is noted that the views from the station, especially
northwards, are highly sensitive.
Similarly, there are some possible sites close to Robertsbridge station. Network Rail
understand the reasoning for rejecting SAL00034 however it is located in a sustainable
location albeit within a sensitive context. SAL 00015 could contribute towards improving
access to the station and providing a better linkage through to the village centre.
The longer term vision involving the A21 bypasses does present the opportunity to unlock
additional land for development however it should be reviewed robustly to ensure that
introducing new roads is justified in the current environmental climate. From a railway
perspective, this could increase the accessibility of stations in northern Rother however its
unlikely to facilitate a modal shift away from the car to public transport.
Please see attached full representation
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27602
Received: 23/07/2024
Respondent: Southern Housing
We support the approach in principle, as we consider it important to ensure some development takes place in rural settlements to ensure the creation of more balanced communities. As with the approach to Rye and the eastern area, it’s encouraging to see there is support for new infrastructure improvements in the northern area. This will help deliver the identified growth and improve accessibility for the communities in the area. The text at paragraph 5.73 states residents in this area are likely to travel to Tunbridge Wells and settlements in Wealden for certain services and facilities. Collaborative working with these two authorities is therefore required. The text at paragraphs 5.77-5.78 references farm diversification and meeting the needs of farming communities. RDC should consider mentioning farming within the text of the Vision for Northern Rother to ensure it carries greater weight in future decision-making and/or include a cross reference to the “Vision for the Countryside” (see also our response to Q72).
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27719
Received: 23/07/2024
Respondent: Colony Developments Ltd
Agent: Apt Planning Ltd
2.1 The vision takes insufficient account of the proximity to a large range of services in Heathfield, c.3 kms to the north west of the District boundary.
2.2 The Draft Local Plan accepts that Burwash, Burwash Common and Burwash Weald are linked ridge-topped villages along the A265.
The NPPF supports development in linked villages where services in one village are supported by the population in linked villages. The Development Strategy does not reflect that these are linked villages with a population of c.3,000 population.
2.3 The three linked villages should be assessed together, rather than separately.
A larger scale of development could then be justified in keeping with the character of three linked villages with a population of c.3,000 people.
2.4 The HEMA report should have considered that land at Linkway, Vicarage Road, Burwash Common was suitable for development, because development constraints could be resolved in a detailed planning application, and the site is more closely related to the existing built up area on A265 and Vicarage Road/Vicarage Lane.
1. Question 51 on page 111 of Draft Local Plan.
Our views on Development Strategy.
1.1 The Development Strategy should comply with the new Labour Government manifesto commitment for mandatory housing targets that will deliver 300,000 new homes per year over 5 years = 1.5 million new homes, based on revisions to the NPPF.
1.2 This could be achieved by adoption of the Standard Method. The HELDA report accepted that there were no exceptional circumstances for not using the Standard Method in Rother, which would result in a local housing need of 737 homes per year plus a 20% buffer. But it is inconsistent in also considering household formation would justify a significantly reduced level of growth.
1.3 The justification for this approach is that the HELDA report identifies Rother population growth declining from +12% in 1980-1990, to +6% in 2000 - 2010, and +3% in 2010-2020. The Development Strategy needs to reverse this declining trend to boost housing supply, to comply with the NPPF. An attainable level was achieved in the 1980-1990s.
1.4 There is a specific local housing need for older people with the HELDA report noting that Rother has the 2nd highest median age, after North Norfolk, in England. The forecast increase in population aged 75+ is +82%. The local level of services needed to support this rural population will require an increase in the younger population aged 0-65 years.
1.5 Practically the only Development Strategy that would reverse the decline of population aged 0-65 years, would be by using the Standard Method, as shown in the HELDA report.
1.6 Both the Vale of White Horse and South Oxfordshire Districts have Green Belt and National Landscape( AONB) constraints. But both Districts have adopted Local Plans that increased house completions from c.200 homes per year to c.800-1,000 homes per year. This has led to local services being improved and an increase in younger population aged 0-65 years.
2. Questions 68-70 on the vision for Northern Rother.
2.1 The vision takes insufficient account of the proximity to a large range of services in Heathfield, c.3 kms to the north west of the District boundary.
2.2 The Draft Local Plan accepts that Burwash, Burwash Common and Burwash Weald are linked ridge-topped villages along the A265.
The NPPF supports development in linked villages where services in one village are supported by the population in linked villages. The Development Strategy does not reflect that these are linked villages with a population of c.3,000 population.
2.3 The three linked villages should be assessed together, rather than separately.
A larger scale of development could then be justified in keeping with the character of three linked villages with a population of c.3,000 people.
2.4 The HEMA report should have considered that land at Linkway, Vicarage Road, Burwash Common was suitable for development, because development constraints could be resolved in a detailed planning application, and the site is more closely related to the existing built up area on A265 and Vicarage Road/Vicarage Lane.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27780
Received: 23/07/2024
Respondent: Salehurst & Robertsbridge Parish Council
The plan appears to be more focused on urban areas with less thought on how it will impact rural communities which we assume reflects the reality which is that there will be significantly more development in urban areas. We are pleased to note the vision for the Northern sub-area is for ‘small scale sensitive residential development and growth in villages’.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28103
Received: 23/07/2024
Respondent: Mr & Mrs Hedges
Number of people: 2
Agent: Batcheller Monkhouse
Our client’s land at Staplecross is located on the edge of one of the villages within Northern Rother so in principle is in line with this aspect of the proposed policy. The land has the potential to deliver small-scale development which is respectful of the character of the High Weald National Landscape it lies within.
As demonstrated in the landscape statement the existing settlement of Staplecross is not clearly defined on its northern or eastern edge. Development on the site will present the opportunity to create a strongly defined settlement edge. This is in line with the aspirations set out within the Landscape Management Guidelines for Rother Valley, which aims to “establish defined development edges to villages with new tree planting”. This could be achieved by bringing forward the site for small scale residential development. The site relates strongly to existing built form within the settlement, and residential development will enable the creation of strong and defined boundaries that are physical recognisable on the ground.
Figure 29 of the Regulation 18 plan sets out the potential housing growth for settlements in Northern Rother. In respect of Staplecross it is currently only identified for the growth of 16 additional houses. In light of our commentary earlier on in this letter about the need to plan for a higher level of housing growth it is considered that the capacity of Staplecross to accommodate a higher level of housing growth should be considered. If the Council do decide to increase the level of housing growth at Staplecross our client’s land is considered to be appropriate for accommodating additional growth.
See attached documents which comprise the submission regarding HELAA sites EWH0009: Land east of Hop Gardens, Northiam Road, Staplecross and EWH0018: Land south of Watts Wood, Staplecross.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28222
Received: 23/07/2024
Respondent: Mr & Mrs Hedges
Agent: Christine Dadswell
Figure 29 of the Regulation 18 plan sets out the potential housing growth for settlements in Northern Rother. In respect of Staplecross it is currently only identified for the growth of 16 additional houses. In light of our commentary earlier on in this letter about the need to plan for a higher level of housing growth it is considered that the capacity of Staplecross to accommodate a higher level of housing growth should be considered. If the Council do decide to increase the level of housing growth at Staplecross our client’s land is considered to be appropriate for accommodating additional growth.
For full text please see attached submission document.
Submission by Christine Dadswell of Batcheller Monkhouse on behalf of Mr & Mrs Hedges regarding:
Promotion of HELAA sites:
- EWH0009 land east of Hop Gardens, Northiam Road
- EWH0018 Land South of Watts Wood, Staplecross
Housing Need
Proposed Strategy: Overall Spatial Development Strategy
Vision for Northern Rother
Proposed Policy DEV3: Development Boundaries
Please see attached documents for full representations.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28286
Received: 23/07/2024
Respondent: The Rector and Scholars of Exeter College
Agent: Bidwells
2.37 We support the vision for the Northern Rother sub-area which states:
Northern Rother’s rural settlements and communities will continue to thrive, through smallscale sensitive residential development and growth in villages to create sustainable forms of development and protect and enhance the landscape character and scenic beauty of the High Weald National Landscape. This will ensure that health and wellbeing and community cohesion is maintained and improved.
While inevitably most rural residents have no choice but to travel primarily by car, connectivity between rural settlements and the Hastings-London rail line will be enhanced through promoting and improving sustainable and active transport infrastructure including walking, wheeling and cycling, enabling communities to lead healthy and active lifestyles.
The two stations at Etchingham and Robertsbridge will continue to act as transport hubs for wider villages in Northern Rother. There are opportunities for sensitive development in the short term, where sustainable and related to an existing settlement. Also, the area will continue to be served by the smaller Stonegate station.
Longer term (over a 30-year timeframe), the delivery of significant improvements to create a sustainable transport corridor, including bypasses to Flimwell and Hurst Green could open up opportunities for future development along the A21 corridor.
2.38 However, we consider that the policy wording ‘through small-scale sensitive residential development and growth in villages’ should be amended to also support sustainable expansions of existing villages where appropriate. This would align with the intention of Spatial Development Option 4 which is centre on prioritising new development on the edge of sustainable settlements and extending settlement boundaries where appropriate.
See attached representation which responds to:
- Certain questions within the Local Plan; and
- HELAA site Land at Grove Farm (Phase 2), Robertsbridge. This includes three appendices within the attached document.