Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

1. Policy OSS 1 (Overall Spatial Development Strategy} of the adopted Rother Local Plan Core Plan Strategy (September 2014) requires "at least" 5,700 dwellings (net) to be provided up to 2028. Policy RA 1 (Villages) requires 1 ,670 of these additional dwellings (comprising existing commitments, new allocations and windfalls) to be provided at suitable rural settlements in accordance with the 'Distribution of Rural Housing Allocations' set out in Figure 12. Figure 12 distributes this housing requirement to various rural settlements including Westfield.

2. Westfield is assessed as being a 'Local Service Village' and has been identified as being able to accommodate 115 additional dwellings between 2011 - 2028. This includes 24 completions (up to the end of March 2013} and 51 dwelling commitments (sites where housing development has been approved or resolved
to be approved) and 40 dwellings on new allocations.

3. Figure 15 (page 124) of the Options and Preferred Options Development and Site Allocations Local Plan focuses on the requirement for larger sites of 6 dwellings or more. For Westfield, the draft Plan identifies a requirement for 89 additional dwellings on large sites, of which 39 have existing planning permission leaving a residual balance of 50 dwellings that still needs to be provided.

4. The existing commitment comprises an extant outline planning consent (no. RR/2009/322/P) for 39 dwellings at Westfield Down. This land was the subject of a previous housing allocation under the 2006 Rother Local Plan Policy VL 11 as shown on Inset Map 36 for Westfield. This planning permission is however, due to
expire on 15th June 2017 unless consent is granted for the matters reserved for subsequent approval.

5. The Council is proposing that this former allocation and current housing commitment is carried forward into the proposed Development and Site Allocations Local Plan under draft Policy WES1. Given that the site was formally allocated in the previous Local Plan over 1 0 years ago and the site has had outline planning permission since July 2014, there must be doubt as to whether the site will deliver the anticipated 39 dwellings during the Plan period and this should not therefore, be relied upon.

6. As regards meeting the residual balance of 50 additional dwellings (although under the provisions of Core Strategy Policy OSS1, this must be regarded as 'at least' 50 dwellings), the Council proposes two new allocations in the Development and Site Allocations Local Plan comprising 1 0 dwellings at land off Goulds Drive (under draft Policy WES3) and 40 retirement living and sheltered houses for the elderly at the former Moorhurst Care Home site (under draft Policy WES2). This also reflects a previous planning approval (RR/2552/CC) for a 48 bed residential
care unit, but this consent also remained unimplemented and has since expired.

7. Thus, similar to the Westfield Down site, there remains considerable uncertainty as to whether the Moorhurst land will also come forward for development within the Plan period. If so, when the two draft allocations are considered together, there is
doubt as to whether 79 (89%) of the 89 dwellings required on large sites will actually be delivered.

8. Due to this uncertainty, there is a need for a contingency approach to allocate additional housing land at Westfield over and above these two proposed sites. Paragraph 15.109 of the draft Local Plan recognises that "areas on the north-eastern side of the village appear to have the most potential for development to meet the identified needs, being relatively contained within the wider landscape, relatively free of wider environmental impacts and reasonably connected to exiting services."This area includes both the Westfield Down and Moorhurst sites.

9. Consistent with this approach, the land immediately to the rear (west) of the former Moorhurst Care Home site is available, suitable and deliverable to be able to accommodate at least 79 dwellings. The extent of this land is shown on drawing LP01- TN354SU-B contained in Appendix 1 attached and is being promoted on a joint basis by the landowners concerned who have formed a consortium known as 'BHH & Associates'.

10. As illustrated by the aerial photograph also contained in Appendix 1 (drawing no. LP02-TN354SU-A), the 3.7 hectare site is adjoined by existing housing development on the western side of Cottage Lane (at Mill Close) and by existing housing development to the south. This housing development is located within the
settlement's Development Boundary as shown on Inset Map 36 of the Rother District Local Plan. The land is bounded by Mill Lane to the north and by the former Moorhurst Care Home site the subject of draft housing allocation Policy WES2, to the east.

11 . The land contains a mix of uses; part of the land on the eastern side is vacant, the central part is used to grow Christmas Trees and the western part is used to graze sheep. The land abuts Cottage Lane to the west and Mill Lane to the north where there are various exiting access points. There is potential for suitable
access to be achieved from Cottage Lane at the site's south western corner in order to serve housing development on the site. Alternatively, shared access might be achieved through the former Moorhurst Care Home site should this land come forward for development.

12. The land is contained by hedgerows and trees along its existing boundaries which could be reinforced by additional planting. The site has sufficient space for housing development to be at an appropriate density to reflect the site's edge of settlement location and to provide an appropriate transition between the existing
northern developed part of Westfield and the more open countryside beyond Mill Lane to the north, which forms a natural physical boundary to an urban extension within this part of the village.

13. Together with the proposed housing allocations the subject of draft Policies WES1 and WES2, housing on this land as a planned urban extension, would provide a logical rounding of the northern part of the village.

14. To ensure that 'at least' 89 dwellings are deliverable at Westfield during the Plan period, these representations seek to have the land shown on drawing no. LP01-TN354SU-B (in Appendix 1) allocated as a safeguarded housing contingency site for at least 79 dwellings (including 40% affordable housing) as a planned
urban extension. The current Development Boundary drawn around this part of Westfield should be extended accordingly as indicated on the annotated version of Figure 124 of the Options and Preferred Options Development and Site Allocations Local Plan contained in Appendix 2.

15. A new policy and extension to the settlement boundary along these lines would then provide for continuity of housing both during and beyond the Plan period.

Additional supporting information was submitted with this representation and can be viewed here: http://www.rother.gov.uk/CHttpHandler.ashx?id=28060

1. Policy OSS 1 (Overall Spatial Development Strategy} of the adopted Rother Local Plan Core Plan Strategy (September 2014) requires "at least" 5,700 dwellings (net) to be provided up to 2028. Policy RA 1 (Villages) requires 1 ,670 of these additional dwellings (comprising existing commitments, new allocations and windfalls) to be provided at suitable rural settlements in accordance with the 'Distribution of Rural Housing Allocations' set out in Figure 12. Figure 12 distributes this housing requirement to various rural settlements including Westfield.

2. Westfield is assessed as being a 'Local Service Village' and has been identified as being able to accommodate 115 additional dwellings between 2011 - 2028. This includes 24 completions (up to the end of March 2013} and 51 dwelling commitments (sites where housing development has been approved or resolved
to be approved) and 40 dwellings on new allocations.

3. Figure 15 (page 124) of the Options and Preferred Options Development and Site Allocations Local Plan focuses on the requirement for larger sites of 6 dwellings or more. For Westfield, the draft Plan identifies a requirement for 89 additional dwellings on large sites, of which 39 have existing planning permission leaving a residual balance of 50 dwellings that still needs to be provided.

4. The existing commitment comprises an extant outline planning consent (no. RR/2009/322/P) for 39 dwellings at Westfield Down. This land was the subject of a previous housing allocation under the 2006 Rother Local Plan Policy VL 11 as shown on Inset Map 36 for Westfield. This planning permission is however, due to
expire on 15th June 2017 unless consent is granted for the matters reserved for subsequent approval.

5. The Council is proposing that this former allocation and current housing commitment is carried forward into the proposed Development and Site Allocations Local Plan under draft Policy WES1. Given that the site was formally allocated in the previous Local Plan over 1 0 years ago and the site has had outline planning permission since July 2014, there must be doubt as to whether the site will deliver the anticipated 39 dwellings during the Plan period and this should not therefore, be relied upon.

6. As regards meeting the residual balance of 50 additional dwellings (although under the provisions of Core Strategy Policy OSS1, this must be regarded as 'at least' 50 dwellings), the Council proposes two new allocations in the Development and Site Allocations Local Plan comprising 1 0 dwellings at land off Goulds Drive (under draft Policy WES3) and 40 retirement living and sheltered houses for the elderly at the former Moorhurst Care Home site (under draft Policy WES2). This also reflects a previous planning approval (RR/2552/CC) for a 48 bed residential
care unit, but this consent also remained unimplemented and has since expired.

7. Thus, similar to the Westfield Down site, there remains considerable uncertainty as to whether the Moorhurst land will also come forward for development within the Plan period. If so, when the two draft allocations are considered together, there is
doubt as to whether 79 (89%) of the 89 dwellings required on large sites will actually be delivered.

8. Due to this uncertainty, there is a need for a contingency approach to allocate additional housing land at Westfield over and above these two proposed sites. Paragraph 15.109 of the draft Local Plan recognises that "areas on the north-eastern side of the village appear to have the most potential for development to meet the identified needs, being relatively contained within the wider landscape, relatively free of wider environmental impacts and reasonably connected to exiting services."This area includes both the Westfield Down and Moorhurst sites.

9. Consistent with this approach, the land immediately to the rear (west) of the former Moorhurst Care Home site is available, suitable and deliverable to be able to accommodate at least 79 dwellings. The extent of this land is shown on drawing LP01- TN354SU-B contained in Appendix 1 attached and is being promoted on a joint basis by the landowners concerned who have formed a consortium known as 'BHH & Associates'.

10. As illustrated by the aerial photograph also contained in Appendix 1 (drawing no. LP02-TN354SU-A), the 3.7 hectare site is adjoined by existing housing development on the western side of Cottage Lane (at Mill Close) and by existing housing development to the south. This housing development is located within the
settlement's Development Boundary as shown on Inset Map 36 of the Rother District Local Plan. The land is bounded by Mill Lane to the north and by the former Moorhurst Care Home site the subject of draft housing allocation Policy WES2, to the east.

11 . The land contains a mix of uses; part of the land on the eastern side is vacant, the central part is used to grow Christmas Trees and the western part is used to graze sheep. The land abuts Cottage Lane to the west and Mill Lane to the north where there are various exiting access points. There is potential for suitable
access to be achieved from Cottage Lane at the site's south western corner in order to serve housing development on the site. Alternatively, shared access might be achieved through the former Moorhurst Care Home site should this land come forward for development.

12. The land is contained by hedgerows and trees along its existing boundaries which could be reinforced by additional planting. The site has sufficient space for housing development to be at an appropriate density to reflect the site's edge of settlement location and to provide an appropriate transition between the existing
northern developed part of Westfield and the more open countryside beyond Mill Lane to the north, which forms a natural physical boundary to an urban extension within this part of the village.

13. Together with the proposed housing allocations the subject of draft Policies WES1 and WES2, housing on this land as a planned urban extension, would provide a logical rounding of the northern part of the village.

14. To ensure that 'at least' 89 dwellings are deliverable at Westfield during the Plan period, these representations seek to have the land shown on drawing no. LP01-TN354SU-B (in Appendix 1) allocated as a safeguarded housing contingency site for at least 79 dwellings (including 40% affordable housing) as a planned
urban extension. The current Development Boundary drawn around this part of Westfield should be extended accordingly as indicated on the annotated version of Figure 124 of the Options and Preferred Options Development and Site Allocations Local Plan contained in Appendix 2.

15. A new policy and extension to the settlement boundary along these lines would then provide for continuity of housing both during and beyond the Plan period.

Additional supporting information was submitted with this representation and can be viewed here: http://www.rother.gov.uk/CHttpHandler.ashx?id=28060