These two questions shouldn't be conflated, they aren't the same impacts. Subdividing homes is a far cry from HMO.

Support:
Turning houses into maisonettes or terraces is usually done with good (often improved) housing quality, sufficient parking and minimal impact on the local amenity.

Object:
Conversely, HMOs may keep the building the same visually but invariably cause parking problems, sudden density and demographic change to an area and - due to the yields involved - incentivise overcrowding and poor maintenance.

Landlords of single occupation houses usually work to maintain the property to a reasonable standard for future value in letting / selling. HMO landlords know that a future sale will probably mean refurbishing back to a single property (HMO licences aren't transferrable) so fixtures and fittings are cheap. Also, the tenants are short-term so both parties have little interest in maintaining the property, inevitably leading to lower standards of housing.

Individual comments made on specific policies as logged

Support for representations made by Ticehurst Parish Council.

Individual comments made on specific policies as logged.

Please also see attached a draft policy for Bewl Water drawn up by the Northern Parishes Group.

Please see attachment

Q1: Re: "1.7 The plan sets twin overall priorities (‘Green to the Core’ and ‘Live Well Locally’)" - I applaud the ambition, but am concerened to see, additionally, a clear statement that BOTH priorities are EQUAL, even if one has to written before the other.

Q6: This is a highly technical policy that really needs another section before ()A) for application to small developments, being undertaken without the benefit of highly qualified experts.

Q9: Agreed a good Policy

Q11: Agreed a good Policy

Q18: Re: "3.36 The opportunity for the development of wind turbines within the district, is extremely limited..." - I beleive very small scale wind power turbines down to single dwelling capability should be considered since technology could deliver economical useful machines within the timescale of this Plan.

Q22/23: RE: "All qualifying development proposals must deliver at least a 20% measurable
biodiversity net gain..." - understood but the metric for qualification is not easy to find?
Agreed a good Policy to go beyond 10%.

Q25: Agreed a good Policy

Q28: Re: "a. Urban areas in Bexhill, Battle and Rye: 60-90+ dph, with higher densities
around transport hubs and town and district centres.
b. Suburban areas in Bexhill, Battle, Hasting Fringes and Rye: 45-75 dph." - it is hard to understand the difference between Urban and Suburban, even with Fig 8? Until 4.15 work is carried out I reserve my judgemment on this Policy.

Q32: In essence a good policy, but some examples e.g. bank have long since gone even from towns within Rother so hardly an OK exemplar. I wonder if 800m is the right parameter - in my road many residents would get their car out for such a distance, few possibly only 20% would walk that distance.

Q33: Whist overall I agree this is a good Policy - I think it needs to be more clearly sectioned, maybe even several seperate Ploicies. Re: "g. Appropriate signage and wayfinding." -this has often or nearly always been overlooked - so a very welcome improvement.

Q35: I particularly like this policy and the 400m parameter, which of course certainly should apply to the Blackfriars development - so a major step forward if it is applied, since previously RDC has in effect only considered on-site access not off-site access.

Q37: I am concerned that no mention is made of former PRoW (FPs) being re-routed through development sites across multiple driveways; rather tah finding contiguous routings through or outside the site connecting to the existing network without having to contend with multiple drive crossings. Though see also Q104 comment.

Q38: Agreed about ixc) Shared Use Routes - the higher age range demographic deprecate shared use, due to (anecdotally) cyclists lack of concern for less ambulant walkers. Very little chance of people buy-in to Demand Responsive Transport, car clubs and car shares!

Q45: Agreed a good Policy; though I note: "inclusively designed so that people with visual, mobility or other limitations will be able to use the street confidently and safely.", so do not see why "iii) Dementia Friendly District" is highlighted, when it would be better to categorise as for example "those with reduced sensory perceptions and mobility"?

Q51: Agreed a good Policy. Crowhurst should be in the Battle SDO; whereas it may be better to exclude Sedlescombe for the battle SDO, due to the decisive split that the A21 causes and Sedlescombe fees more adjacent (connected) to Westfield. Quite evident in Fig 12.

Q62: Re: "5.56 Battle is a small, historic market town." Umm - not a good summary, it should be: "Battle is a small, historic FORMER market town.", since all banks now gone...

Q74: This policy area is so heavily over burdened by national and county council legislation and determination, I recommend the LP only provides for the minimal provision since there is nowadays negligible agricultural seasonal employment upon which much of the legislation appears to be based.

Q76: Fig 35/36 - I do not agree that Battle has " Greater opportunity for growth, since already the constraints discussed show minimal opportunity e.g. NPPF/NL conditions. Furtermore the employment locations expansion in Battle are, as the Neighbourhood Plan Calls showed, almost negligible and certainly not as RDC pushed for when the NP was being developed.

Q84: Agreed a good Policy.

Q90: It is hard to understand why the RDC/Inspector refused to allow the proposed Gap along the Hastings Road at Telham was not allowed in the Battle NP, given these arguments it would have enhanced the protection: "The Gap between Battle and Hastings/St Leonards provides an important function in maintaining the separate identities of Battle and the built-up area of Hastings/St Leonards. The break in the ribbon development between the edge of Telham and the Hastings Borough boundary at Breadsell Farm is highly vulnerable to change particularly in more open areas and the higher ground and ridges."

Q96: In view of the source of this Policy will it now be applied Rother wide?

Q104: Agreed a good Policy. I welcome this new Policy, especially the aspects regarding diversion of FPs within development sites be required to deliver "equivalent" access and "must be replicated" See also comment to Q37.

Q109: Agreed a good Policy.

Q112: Agreed a good Policy.

Q119: I do not favour "100% affordable housing schemes". Surely "pepperpotting" is a better solution?

Q121: Given my comment on Q119, I do not really agree with is Policy, however given the intent for "substantially affordable housing", I would accept the need could be so satisfied.

Q125: Agreed a good Policy.

Q131: I welcome further work on this need.

Q133: Agreed a good Policy.

Q147: I would like to see a strengthening to no permission would be given to changing natural boundary hedges and trees.

Q149: Conversions/extensions of an older wood construction building by using modern brick construction, for example, should not normally be permitted, since they would significantly alter the street scene.

Q153: Agreed a good Policy, however I do not agree that in 8.179 Laurel is preferred - it is too fast growing and likely to over burden other growth.

Q170: Agreed a good Policy. I particularly welcome "xi) Where practicable, the track is opened as a path for permissive public usage or as Public Right of Way, and should be accessible from the existing Public Rights of Way network", since this would make the applicant aware that they could provide a beneficial PRoW spin-off from their operations, not previously or normally offered.

Q178: Agreed a good Policy.

Q180: Agreed a good Policy.

Q182: Agreed a good Policy. Welcomed and for reasons of energy saving an emphasis on PIR use should be paramount.

Q195: Agreed a good Policy. But I am confused by this wording: "vi) For Ancient Woodland, create a development buffer zone of at least 15 metres. An impact assessment will be required where any development is proposed within 25 metres of Ancient Woodland to demonstrate that the proposed buffer zone avoids negative effects on the habitat.", since surely a single buffer zone of 25m would suffice?

Appendix 2: Surely "Market square including Jempsons shop and others should be considered as in the "Battle Town Centre and Primary Shopping Area", even if not contiguously connected? The south-eastern limit of the appears to miss out several shops/cafes of importance...

Q208: "proposed monitoring framework" appears to be a comprehensive methodology to adopt. but i wonder how it will be reported?