Proposed Submission Development and Site Allocations (DaSA) Local Plan

Northiam Parish Council (NPC)
Comments on Rother Development & Site Allocation Policies
Cabinet Version
November 2018

1. Introduction

1.1 Legislation establishes a clear "plan-led" planning system and requires local planning authorities to produce a Local Plan for its area.

1.2 In September 2014, the Council adopted its Rother Local Plan 'Core Strategy', which sets out its vision, overarching development strategy and strategic policies for development and change, and conservation, for Rother District over the period up to 2028. The Core Strategy identified the need to prepare this further Plan to both set out more detailed 'development policies' for certain topics in order to assist in determining proposals and to identify specific 'site allocations' to deliver the agreed housing and other development targets.

1.3 This Development and Site Allocations ("DaSA") Local Plan is effectively "part two" of the Council's Local Plan. It has been prepared to be in general conformity with the Core Strategy and has the same time horizon.

1.4 Together with the Core Strategy, this DaSA Local Plan provides the basis for determining planning applications in much of the district and supersedes all generic policies and relevant spatial policies from the earlier 2006 Rother District Local Plan.

1.5 The Core Strategy replaced the broader policies of the earlier 2006 Rother District Local Plan. This Local Plan now supersedes most of the remaining more detailed 2006 Local Plan polices, as listed at Appendix 2, exceptions being a few 2006 policies, mainly site allocations, not covered by this Local Plan but within a neighbourhood area where a Neighbourhood Plan is yet to be made.

1.6 National planning policies are contained in the 'National Planning Policy Framework' (NPPF). Local planning policies should be consistent with national planning policies, unless there are reasons justifying a local exception. The NPPF is also a material consideration in determining applications.

1.7 The NPPF defines the purpose of the planning system in terms of contributing to "sustainable development", with three interdependent economic, social and environmental objectives. It includes a 'presumption in favour of sustainable development', which is applied locally through Core Strategy Policy PC1.

1.8 The first NPPF, published in 2012, has recently been revised through the publication of a new NPPF in July 2018. While this Local Plan has been prepared to accord with the 2012 NPPF, notably in terms of housing provisions (which are set by the current Core Strategy), regard has also been had to the 2018 NPPF. Hence, it is believed that this Plan's policies, as set out in Part A and Part B, are also consistent with this latest statement of Government policy.

1.9 These development policies apply to all development applications including those relating to a site within a area with a Neighbourhood Plan which. When the D&SAP is formally adopted the policies within the D&SAP will have primacy over local neighbourhood plan policies unless there is a compelling case for the adoption of the NP policy.

Development Policies

Resource Management

Policy DRM1: Water Efficiency
Limits daily household water consumption to no more than 110litres/person per day.
NPC supports.

Policy DRM2: Renewable Energy Developments
General support for low energy schemes where they meet other Core strategy and D&SAP policies. No support for large scale wind farms.
NPC supports.

Policy DRM3: Energy Requirements
Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floor space should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement.
NPC supports.

Communities

Policy DCO1: Retention of Sites of Social or Economic Value
18 month period to show that use is no longer a prospect of continuing use.
NPC Strongly supports.

Policy DCO2: Equestrian Developments
NPC supports.

Housing

Policy DHG1: Affordable Housing
Sets requirement for affordable housing % (Rye 305 on sites with 10 or more/. 3 hectares)
Viability still a factor although 2018 NPPF sets standard for viability threshold.
NPC supports

Policy DHG2: Rural Exception Sites
NPC supports

Policy DHG3: Residential Internal Space Standards
To adopt government space standards.
NPC strongly supports.

Policy DHG4: Accessible and Adaptable Homes.
All dwellings are required to meet M4 (2): Category 2 - Accessible and Adaptable Dwellings. This does not provide for wheel chair access but where there is an identified need on the Housing Register, sites that provide affordable housing in line with Policy DHG1, are as part of the affordable housing requirement, expected to provide 5% of the total housing requirement to meet M4 (3): Category 3 - Wheelchair Accessible Dwellings.
NPC supports.

Policy DHG5: Specialist Housing for Older People.
Supports such schemes with 'walkability' an issue.
NPC strongly supports.

Policy DHG6: Self-build and Custom House building.
Supports concept. On sites of 20 or more dwellings, provision for 5-10% of the total number of dwellings to be provided should be made available as serviced plots for self and custom house builders. Plots should be made available and marketed through relevant marketing agencies for a period of at least 12 months. If the plots are not sold within this time period, the dwellings may be released for conventional market housing in line with the terms set out in the relevant legal agreement.
NPC supports.

Policy DHG7: External Residential Areas.
For dwellings, private rear garden spaces of at least 10 metres in length will normally be required.
Provision for car parking and safe and secure cycle storage should be made in accordance with Core Strategy Policy TR4 and East Sussex County Council's 'Guidance for Parking at New Residential Development' and 'Guidance for Parking at Non Residential Development'.
Waste and Recycling: Sufficient bin storage and collection points must be provided on all new residential developments and changes of use. Their siting and design should be considered at the outset.
NPC supports.

Policy DHG8: Extensions to Residential Gardens.
NPC supports.

Policy DHG9: Extensions, Alterations and Outbuildings.
NPC supports.

Policy DHG10: Annexe.
NPC supports.

Policy DHG11: Boundary Treatments.
NPC supports.

Policy DHG12: Accesses and Drives.
RCS supports

Economy

Policy DEC1: Shopfronts, Signage and Advertising.
NCP supports.

Policy DEC2: Holiday Sites.
NCP supports.

Policy DEC3: Existing Employment Sites and Premises.
Where continued employment use of a site/premises is demonstrated not to be viable, permitting complementary enabling development as part of an overall scheme to make most effective use of the property for employment purposes; and if a mixed use scheme is not viable, prioritising alternative community uses, affordable housing (where affordable housing would be sought in line with Policy DHG1) and then market housing, subject to local needs.
NPC supports.

Environment

Policy DEN1: Maintaining Landscape Character.
NCP strongly supports.

Policy DEN2: The High Weald Area of Outstanding Natural Beauty (AONB).
NCP strongly supports.

Policy DEN3: Strategic Gaps.
Not applicable to Northiam

Policy DEN4: Biodiversity and Green Space.
Development proposals should support the conservation of biodiversity and multi-functional green spaces in accordance with Core Strategy Policy EN5. Larger developments of more than 2 hectares or 50 dwellings (whichever is the smaller) should produce a Green Infrastructure masterplan as part of their proposals.
NCP supports.

Policy DEN5: Sustainable Drainage.
NCP supports but would like to see requirement for all new water courses to be open accept for access requirements and for 'daylighting' where appropriate of existing culverts stated in policy not just in supporting text.

Policy DEN6: Land Stability.
NCP supports.

Policy DEN7: Environmental Pollution.
NCP strongly supports.

Implementation

Policy DIM1: Comprehensive Development.
Policy needs to be clarified as to where and how it is applied

Policy DIM2: Development Boundaries.
NCP supports.

Site Allocation Policies
Overview Policy OVE1: Housing supply and delivery pending plans.

NOR 1
Policy NOR1: Land south of Northiam Church of England Primary School.
Northiam

Land south of Northiam Church of England Primary School, as shown on the Policies Map, is allocated for housing. Proposals will be permitted where:

(i) Some 6 dwellings are provided, of which 40% are affordable;

(ii) vehicle access is to the A28 to the satisfaction of the Highway
Authority;

(iii) existing trees on the eastern and western boundaries, protected by Tree Preservation Orders, are retained; and the hedgerow on the eastern boundary is retained and enhanced with native species; and

(iv) an assessment and evaluation of the she's archaeological potential has been carried out and mitigation measures are implemented.

NPC supports.

NOR 2
Policy NOR2:Land south of The Paddock/Goddens Gill Northiam

Land south of The Paddock Goddens Gill, as shown on the Policies Map, is allocated for residential development. Proposals will be permitted where:

(i) either:

(a) some 52 age-restricted dwellings for older people are provided;
or

(b) some 36 dwellings are provided. In both cases, 40% of the dwelling units shall be affordable.

(ii) vehicle access b via The Paddock to the satisfaction of the Highway
Authority;
(iii) tree belts and hedgerows on (he site boundaries are maintained and reinforced with planting of native species, and provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), on the eastern boundary, between the edge of development and the ancient woodland.

We have concerns as to the proposed density of dwellings on this site

Appendix B: D&SAP Policies attached:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31180