Proposed Submission Development and Site Allocations (DaSA) Local Plan

Dear Sirs,

Re: Proposed Submission Development and Site Allocations Local Plan

Gladman write to offer some brief comments on the Rother Site Allocations Local Plan. It is noted that the document follows on from the original Core Strategy adopted in 2014. Gladman make specific comments on Part A and Part B of the Site Allocations Local Plan below, but as an overarching point we consider that given the Site Allocations Local Plan has a very short life span, less than 10 years even before its submission for examination, both the Core Strategy and the Site Allocations Local Plan should be reviewed immediately post adoption of the Site Allocations Local Plan. Otherwise the Local Plan is in danger of being time expired prior to a new plan being put in place. This is especially important given that the government's standard methodology for housing need is likely to increase the housing requirement significantly. We do not consider that the plan can be found sound without commitment for an immediate review.

PART A

Policy DHG4 - Accessibility and Adaptability Standards

The Planning Practice Guidance (Paragraph 56-007) requires local authorities to evidence and demonstrate the need for these requirements to be applied to new homes. This evidence should include the likely future need for housing for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. Whilst Gladman understand the need for the delivery of accessible homes the Council must provide a local assessment evidencing the specific case for the scale of need proposed in Rother. This should justify the inclusion of optional higher standards for accessible / adaptable homes in policy DHG4. At present Gladman do not conclude that the evidence justifies the application of the standards to all new build homes.

Part B

Gladman do not wish to comment specifically on any of the individual allocations at this time, however we would comment on the overall level of housing supply within the plan. Paragraphs 8.1-8.18 set the context for the levels of development which have been achieved so far and the commitments that are made, a residual need of 1,574 dwellings to come forward through the Site Allocations DPD and Neighbourhood Plans is identified. The Site Allocations DPD confirms allocations for 1,562 dwellings in Figure 18, there is therefore a shortfall against the total requirement.

The plan is silent on the status of neighbourhood plans in Rother and whether or not it is realistic that the forthcoming neighbourhood plans will allocate the level of housing envisaged in Figure 18 and make up the difference in units aspired to hit the 5,700 unit total. What must also be remembered is that whilst the target may be 5,700 units to be delivered, there is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building any flexibility into the plan for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would in effect be a buffer to ensure overall plan levels of development are delivered is not sound.

Gladman consider it likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.

As a leading land promoter Gladman would welcome the opportunity to further discuss the content of this representation at the examination into the soundness of the Site Allocations DPD.

Policy DHG6: Self Build and Custom Build Housing

Gladman support the provision of self and custom build housing however we object to the policy in its current form. The approach taken by the Council in seeking to provide 5-10% of plots on sites over 20 dwellings as self-build will lead to the overprovision of plots for self-build and slow the rate of site delivery down on medium and large scale sites.

Figure 4 shows that in the last 12 years 108 people have registered interests in obtaining a self-build plot. However, paragraph 4.53 acknowledges that not all people who apply have a local connection and that indeed some participants acknowledge they have also registered in other areas. Paragraph 4.56 goes on to state that the majority of people would prefer a detached dwelling in a countryside location, whilst this is not surprising it is not the type of plot which will be delivered through carving off a percentage an allocated site for self-build. Gladman do not therefore consider that there is sufficient evidence of demand for self-build plots within allocations and the Council will need to consider alternative means of providing self-build housing, if it is to meet the aspirations of those who wish to build their own home.

Policy DEN3: Strategic Gaps

Policy DEN3 is a policy which severely restricts the potential for sustainable development to come forward, in the context of a district which has such a significant portion of its land in the AONB and therefore where meeting development needs is already challenging. The next iteration of the Core Strategy will need to deal with significantly increased housing need and whilst justification may exist for some parts of the identified strategic gaps it is unlikely that their full outlined scale will be justified. In any event the Strategic Gaps would be better considered through the review of the Core Strategy in the context of the increased housing need.

Policy DIM2: Development Boundaries

Gladman consider that the plan would benefit from a more flexible approach to development on its boundaries, given the context of the overall supply of housing planned for (discussed below) and the incoming change in housing needs for Rother through the implementation of the standard methodology. To this end in order for the policy to be found sound we believe that the final paragraph of the policy should be deleted and replaced with a criteria based policy for edge of settlement development. In this regard we would recommend a policy similar to that contained within the emerging Ashford Local Plan, which has been the subject of main modifications consultation. We attach a copy of draft policy HOU5 from the Ashford Local Plan to this letter.

Gladman do not wish to comment specifically on any of the individual allocations at this time, however we would comment on the overall level of housing supply within the plan. Paragraphs 8.1-8.18 set the context for the levels of development which have been achieved so far and the commitments that are made, a residual
need of 1,574 dwellings to come forward through the Site Allocations DPD and Neighbourhood Plans is identified. The Site Allocations DPD confirms allocations for 1,562 dwellings in Figure 18, there is therefore a shortfall against the total requirement.

The plan is silent on the status of neighbourhood plans in Rother and whether or not it is realistic that the forthcoming neighbourhood plans will allocate the level of housing envisaged in Figure 18 and make up the difference in units aspired to hit the 5,700 unit total. What must also be remembered is that whilst the target
may be 5,700 units to be delivered, there is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building any flexibility into the plan for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would
in effect be a buffer to ensure overall plan levels of development are delivered is not sound.

Gladman consider it likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.

As a leading land promoter Gladman would welcome the opportunity to further discuss the content of this representation at the examination into the soundness of the Site Allocations DPD.