Proposed Submission Development and Site Allocations (DaSA) Local Plan

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites

A Report by Rye Town Council on the consistency of the Rye Neighbourhood Plan (RNP) with the Rother DC Development and Site Allocations (DaSA) (Submission Copy)

1.The 2014 Core Strategy recognised that there was a need for a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies.

2. The publication of the DaSA coincides with the RNP Plan Submission to meet Regulations 15 and 16 of the Neighbourhood Planning Act. Therefore this is a consideration of the RNP in relation to the emerging DaSA. Rye notes two specific development issues, tackled by the DaSA:

a. to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

b. to identify development across Rother District in two categories:

i. preferred sites where no Neighbourhood Plan (NP) is being made
ii. Neighbourhood Plans, that identify sites to meet targets; Rye is in this category.

3. Throughout 2018, Rye Town Council has kept abreast of the drafting of the emerging DaSA through its work on the RNP. At this stage Rye has reconsidered the three parts of the DaSA Plan to ensure that the RNP remains consistent.

- The Context (Introduction - Section 1): Where Neighbourhood Plans (NPs) are being prepared these are listed (Rye is listed). We understand the need for the Rye NP to conform to the Core Strategy, the NPPF (initially 2012 now superseded by NPPF 2018) and be consistent with the emerging DaSA. All of which it does, as covered in the Rye NP Basic Conditions Statement. Rye notes the targets as below, which the RNP meets.

- Business: 10,000-20,000sqm at Rye/Harbour Road
- Dwellings: 355-400 at Rye over the planning period. The Rye NP includes figures to show commitments and the residual balance.

Part A: Rye COMMENTS on the Development Policies in the emerging DaSA as below. Some additional work in 2018 has been necessary to ensure that the Rye NP is consistent with the emerging DaSA, and did not unnecessarily duplicate its policies, unless the community wanted to make particular emphasis. The emerging
requirements for the Rye NP area have been periodically reconciled with Rother targets. It should be underscored that we agreed with Rother planning officers in May 2017 that the Rye NP should "overplan" numbers of dwellings as there remains uncertainty about the deliverability of some allocations to sites. We also included the policies for Development Boundaries and the Rye "Strategic Gap".

Part B - Rye NOTES the Site Allocations for those parishes where no NP is being made. Because historically Rye was considered with Rye Harbour for development targets, the Rye Harbour allocation (for 40 dwellings) and the business allocation in the Harbour Road is of interest to Rye and has been considered in the text of the RNP, but not allocated, as instructed by Rother Planners. It is also noted that there are now no traveller sites allocated in Rye.

4. Here is a summary of the comparison of the DaSA with the RNP.

DaSA Policy no: DRM 1
How the RNP relates to the DaSA: None
DaSA Policy: Resources: Water Efficiency
COMMENTS: Agree: provides policy; adopts standard through Bldg Regs

DaSA Policy no: DRM 2
How the RNP relates to the DaSA: E4 Para 4.88
DaSA Policy: Resources: Renewable energy
COMMENTS: Agree: complements RNP E4. We have suggested that Rye Harbour has potential for turbines and biomass. Solar panels and such installations could be fitted to large industrial and educational buildings in Rye.

DaSA Policy no: DRM 3
How the RNP relates to the DaSA: E4
DaSA Policy: Energy Requirements
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO 1
How the RNP relates to the DaSA: B1 and I1
DaSA Policy: Community: Retention of sites of social or economic value
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DCO2
How the RNP relates to the DAaSA: None
DaSA Policy: Community: Equestrian development
COMMENTS: Agree; complements RNP E4

DaSA Policy no: DHG 1
How the RNP relates to the DaSA: Para 4.8
DaSA Policy: Housing: Affordable Housing
COMMENTS: Agree: confirms the policy for Rye: 30% in developments over 10 dwellings

DaSA Policy no: DHG 2
How the RNP relates to the DaSA: N/A
DaSA Policy: Housing: Rural Exception Sites
COMMENTS: Not considered

DaSA Policy no: DHG 3
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Internal space standards
COMMENTS: Agree: national guidelines; complements RNP D1

DaSA Policy no: DHG 4
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Accessible Homes
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 5
How the RNP relates to the DaSA: H2
DaSA Policy: Housing: Homes for older people
COMMENTS: Agree: complements RNP H2

DaSA Policy no: DHG 6
How the RNP relates to the DaSA: H3 and H7
DaSA Policy: Housing: Custom and self-build housing
COMMENTS: Agree: complements RNP H3 and H7 The RNP allocates in two Rye sites to a figure of around 5 homes which is around 3% of target.

DaSA Policy no: DHG 7
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: External residential areas
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 8
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions to residential gardens
COMMENTS: Agree ; complements RNP D1

DaSA Policy no: DHG 9
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Extensions and alterations
COMMENTS: Agree: complements RNP D1 Extensions should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 10
How the RNP relates to the DaSA: D1
DaSA Policy: Annexes
COMMENTS: Agree; complements RNP D1 Annexes should be examined on an individual basis but have sense of place and must not cause over development, loss of amenity or excessive density

DaSA Policy no: DHG 11
How the RNP relates to the DaSA: D1
DaSA Policy: Housing: Boundary treatments
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DHG 12
How the RNP relates to the DaSA:
DaSA Policy: D1 Drive Access
COMMENTS: Agree; complements RNP D1

DaSA Policy no: DEC 1
How the RNP relates to the DaSA: D1 and E3
DaSA Policy: Economy: Shopfronts and advertising
COMMENTS: Agree: complements RNP Complements RNP D1 and E3

DaSA Policy no: DEC 2
How the RNP relates to the DaSA: None
DaSA Policy: Economy: Holiday Sites
COMMENTS: Agree but not directly applicable

DaSA Policy no: DEC 3
How the RNP relates to the DaSA: B1
DaSA Policy: Economy: Existing employment sites
COMMENTS: Agree; complements RNP B1

DaSA Policy no: DEN 1
How the RNP relates to the DaSA: D1 and E2
DaSA Policy: Environment: Landscape
COMMENTS: Agree: strongly support Complements RNP D1 and E2

DaSA Policy no: DEN 2
How the RNP relates to the DaSA: Para 4.72, 4.88
DaSA Policy: AONB
COMMENTS: Agree: support; provides policy. Has formed part of the Rye objection to the BP proposal off the Udimore Road which is adjacent to the AONB

DaSA Policy no: DEN 3
How the RNP relates to the DaSA: E1 and para 4.72 to 4.76
DaSA Policy: Environment: Strategic Gaps Rye-Rye Harbour
COMMENTS: Agree: strongly support map (DaSA Figure 8) and policy, that complements RNP E1

DaSA Policy no: DEN 4 E
How the RNP relates to the DaSA: 2- E3 Paras 4.77 to 4.80
DaSA Policy: Environment: Bio diversity and Green Space
COMMENTS: Agree; complements RNP E2 and E3

DaSA Policy no: DEN 5
How the RNP relates to the DaSA: F1 and para 4.32
DaSA Policy: Environment: Sustainable Drainage
COMMENTS: Agree ; complements RNP F1

DaSA Pollicy no: DEN 6
How the RNP relates to the DaSA: Para 4.89
DaSA Policy: Environment: Land Stability
COMMENTS: Agree; provides policy We have raised the risk of (sandstone) rockfall around Rye. DaSA now lists Rye's risk locations include East, South and West Citadel; land above Military Rd and at Cadborough.

DaSA Policy no: DEN 7
How the RNP relates to the DaSA: None
DaSA Policy: Environment: Pollution
COMMENTS: Agree: provides policy. Vehicle pollution is a particular issue for those adjacent to the A259

DaSA Policy no: DIM 1
How the RNP relates to the DaSA: Individual site policies
DaSA Policy: Implementation: Comprehensive Development
COMMENTS: Agree; support as this complements policy for several of our allocated sites

DaSA Policy no: DIM 2
How the RNP relates to the DaSA: E1
DaSA Policy: Implementation: Development Boundaries
COMMENTS: Agree; complements RNP E1. RNP proposes two changes to the development boundary of Rye, otherwise the development boundary should remain

DaSA Policy no: Rye Targets
How the RNP relates to the DaSA: H1 H2
DaSA policy: Targets: Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour) 10-20,000 sqm employment
COMMENTS: Dwellings Number Breakdown has been agreed with Rother DC Officers:
Total Site: 355
Completions: 277
Large Site: 6
Small Site: 25
Windfall: 6
Balance: 81

DaSA Policy no: Rye Harbour Target
How the RNP relates to the DaSA: Para 4.2
DaSA Policy: Targets: Allocation to Rye Harbour 40 dwellings
COMMENTS: Agree: as directed by Rother DC; for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish). The 40 are included in the Rye target of 400 as above but site allocation if left to Rother/Icklesham.

DaSA Policy no: Other Policies
How the RNP relates to the DaSA: None
DaSA Policy: Traveller Sites
COMMENTS: No sites