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

Rother District Council DaSA Local Plan, Options and Preferred Options
Site Allocations in Battle

Strutt & Parker's planning department are instructed to respond to the Development and Site Allocations (DaSA) Local Plan, Options and Preferred Options on behalf of the owners of Netherfield Place Farm, which is located at Netherfield. Our comments are in relation to the allocation of housing sites in Battle.

Policy RA1 of the adopted Core Strategy identifies a need for 1,670 additional dwellings in a number of villages during the Plan period 2011 to 2028. Following the deduction of existing commitments, a residual requirement of 800 dwellings is identified for the villages, to come forward through site allocations (paragraph 12.13). It was noted that these site allocations would be made in the DaSA and/or Neighbourhood Plans.

The DaSA provides a breakdown of how the housing requirement for the rural areas will be distributed to each village. Provision is made for 115 dwellings in Netherfield during the Plan period, to include 48 on new site allocations. We note that this figure coincides with the total number of units identified on positively-assessed sites in the 2013 SHLAA, and does not necessarily preclude additional sites that have been assessed positively since then. If the Neighbourhood Plan allocates sites instead of the DaSA, a flexible approach must be taken to the proposed housing requirement because it would otherwise restrict the Neighbourhood Plan Forum to identifying only those sites that were positively assessed in the 2013 SHLAA. Such a flexible approach would accord with the need for the Core Strategy housing requirements to be achieved as 'a minimum'.

The draft DaSA that is subject to the current consultation does not include allocations for Netherfield at all and instead relies on the Battle Neighbourhood Plan for allocations. To rely on a Neighbourhood Plan, which has made no progress at all in the two years since the area was designated, would put a question mark over the ability of the Local Plan to deliver the requisite number of dwellings during the Plan period. Eight other Neighbourhood Plans are being relied upon in this way - albeit two have made sufficient progress that their delivery can be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). It is however impossible to control this process, and the council are placing an unreasonable amount of responsibility on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale. The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control.

It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA where they fall within designated Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of housing site allocations in the DaSA for Netherfield would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area (including Netherfield) could result in insufficient residential development taking place during the plan period, leaving the Council with a housing land supply shortage when assessed against objective needs. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

Site Proposal

Netherfield Place Farm contains a significant area of land to the south east of the main settlement confines, and includes the triangular piece of land located at the junction between the B2096 and Netherfield Road (see enclosed plan). An area measuring 2 hectares is proposed for allocation for approximately 48 dwellings, fronting onto Netherfield Road (see enclosed plan).

Access would be achieved from Netherfield Road, as close to the junction with Darvel Down as possible to ensure good pedestrian connectivity shops and services, including the primary school and post office.

The site could be well screened from the wider landscape by reinforcing the southern boundary of the site with a dense tree buffer. Landscape impact is the only potential constraint to the site, but this can easily be mitigated with additional planting and sensitive design.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28061

Rother District Council DaSA Local Plan, Options and Preferred Options
Site Allocations in Battle

Strutt & Parker's planning department are instructed to respond to the Development and Site Allocations (DaSA) Local Plan, Options and Preferred Options on behalf of the owners of Netherfield Place Farm, which is located at Netherfield. Our comments are in relation to the allocation of housing sites in Battle.

Policy RA1 of the adopted Core Strategy identifies a need for 1,670 additional dwellings in a number of villages during the Plan period 2011 to 2028. Following the deduction of existing commitments, a residual requirement of 800 dwellings is identified for the villages, to come forward through site allocations (paragraph 12.13). It was noted that these site allocations would be made in the DaSA and/or Neighbourhood Plans.

The DaSA provides a breakdown of how the housing requirement for the rural areas will be distributed to each village. Provision is made for 115 dwellings in Netherfield during the Plan period, to include 48 on new site allocations. We note that this figure coincides with the total number of units identified on positively-assessed sites in the 2013 SHLAA, and does not necessarily preclude additional sites that have been assessed positively since then. If the Neighbourhood Plan allocates sites instead of the DaSA, a flexible approach must be taken to the proposed housing requirement because it would otherwise restrict the Neighbourhood Plan Forum to identifying only those sites that were positively assessed in the 2013 SHLAA. Such a flexible approach would accord with the need for the Core Strategy housing requirements to be achieved as 'a minimum'.

The draft DaSA that is subject to the current consultation does not include allocations for Netherfield at all and instead relies on the Battle Neighbourhood Plan for allocations. To rely on a Neighbourhood Plan, which has made no progress at all in the two years since the area was designated, would put a question mark over the ability of the Local Plan to deliver the requisite number of dwellings during the Plan period. Eight other Neighbourhood Plans are being relied upon in this way - albeit two have made sufficient progress that their delivery can be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). It is however impossible to control this process, and the council are placing an unreasonable amount of responsibility on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale. The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control.

It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA where they fall within designated Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of housing site allocations in the DaSA for Netherfield would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area (including Netherfield) could result in insufficient residential development taking place during the plan period, leaving the Council with a housing land supply shortage when assessed against objective needs. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

Site Proposal

Netherfield Place Farm contains a significant area of land to the south east of the main settlement confines, and includes the triangular piece of land located at the junction between the B2096 and Netherfield Road (see enclosed plan). An area measuring 2 hectares is proposed for allocation for approximately 48 dwellings, fronting onto Netherfield Road (see enclosed plan).

Access would be achieved from Netherfield Road, as close to the junction with Darvel Down as possible to ensure good pedestrian connectivity shops and services, including the primary school and post office.

The site could be well screened from the wider landscape by reinforcing the southern boundary of the site with a dense tree buffer. Landscape impact is the only potential constraint to the site, but this can easily be mitigated with additional planting and sensitive design.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28061