Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27356

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LWL5: Distinctive Places
This policy is generally supported, and the reference to the High Weald Housing Design Guide where
relevant is welcomed, as is the explanatory text. We consider the policy would be better renamed
‘Well -designed and distinctive places’ to be clearer for users of the Local Plan, and to more closely
align with the NPPF.
We consider the policy would be strengthened by the addition of the following text (in bold) in the
introductory line:
“All development proposals for one or more new dwelling must be of high design quality by
meeting the following criteria”
Under part (i) Response To Site, Character and Landscape Context, we advise that the words
‘including settlement pattern and streetscape character’ be added after the words ‘and beyond’.
We also consider that part iii) could be reworded to simplify; suggested rewording:
“Development within of affecting the setting of the High Weald National Landscape should
be landscape-led and designed in a way that follows the guidance in the High Weald AONB
Housing Design Guide and Colour Study (see GTC9)”
And we suggest the following rewording to part vi)
“Existing Site Assets and Landscape Features: Retain and use existing on-site or site adjacent
assets/landscape features, such as mature trees, ponds and streams, as key placemaking
within the scheme around which the layout is structured, and capitalise on other existing
features such as key views beyond a site.”
And we suggest parts vii) and viii) could be merged into one point, to simplify the policy.

Comment

Representation ID: 27357

Received: 22/07/2024

Respondent: High Weald AONB Unit

We would also like to see Proposed Policy LWL6: Built Form also include specific reference to the
HW AONB Housing Design Guide (as LWL5 does) as this applies equally to this policy.

Comment

Representation ID: 27358

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LWL8: Multimodal Parking
We consider the structure of this policy could helpfully be amended, as part iii) should apply to all
car-parking, not just on-street parking. To address this, we recommend that part ii) should be renamed ‘Car-parking Strategies’, then list points a-e that are in currently in part iii, then add the
current part ii text as a point f to that list.
Also we note that part vi) Car Parking Courts sets out that ‘Rear car parking courts serving houses
must be avoided where possible.’ The High Weald Housing Design Guide does include parking
courtyards as a suitable parking type to serve terraces or mews (Design Theme DG6: Parking
Strategies, p31) but qualifies this by advising they must be small-scale, usually serving no more than
five dwellings, well overlooked, and where possible defined by buildings bordering the space,
arranged to animate the courtyard, or bounded by appropriate planting, rather than enclosed by
bleak runs of close-board fences to back gardens. We would like to see the policy be amended to
adopt similar language.
Part vi) also seems to contradict part ix) Communal ‘Remote’ Car Parking – we suggest these two
parts could be combined and rationalised, to avoid confusion, and the term ‘remote’ omitted as it
could be misinterpreted.

Comment

Representation ID: 27359

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LWL7: Streets for All
Whilst we are pleased to Historic Streets in part xii) of this draft policy, and references to Historic
England’s Streets for All publication, we consider this part xii) might be better re-located to within
Proposed Policy HER1: Heritage Management, which would offer the opportunity to include greater
reference and weight to the subject of the historic public realm (highlighted in the High Weald AONB
Management Plan within the Settlements character component)- this is expanded below under our
comments for Policy HER1.

Comment

Representation ID: 27360

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy HOU13: New Dwellings in the Countryside
We are concerned about proposed part vi) to this policy – whilst we support the intention of allowing
very small-scale growth to small settlements and hamlets within the AONB to support thriving rural
communities, we are concerned that the policy could lead to ribbon development or the construction
of large single dwellings in edge-of-settlement locations that could erode the distinctive landscape
settings of settlements and settlement pattern and character in the AONB. Furthermore we are
concerned about the wording that promotes development where the site is either a small gap in an
otherwise built-up frontage – frequent green spaces within settlements, offering glimpse views to the
countryside beyond, are identified in the AONB Management Plan as a key characteristic of the
‘Settlement’ character component of the High Weald’s natural beauty, and Objectives S1 and PQ2 of
the AONB Management Plan are also particularly relevant in this regard. The wording of such a policy
therefore needs careful consideration; we suggest amended wording to part vi) as follows: (though
we would be happy to continue discussing this with you further in more detail)
vi) Very small-scale development; pairs of dwellings or small terraces of 3 or 4 units,
either within a settlement without a development boundary or adjacent to an
existing development boundary, to support thriving rural communities, where:
a) the site is adjacent to the edge of an otherwise built-up frontage; and
b) where the site accords with policies within the Live Well Locally chapter and is
close to local services including public transport connections and accessible to
them by wheeling, walking or cycling; and
c) where the siting, scale and design of the development would support and not
detract from the historic settlement pattern and character of the locality; and
d) where the location of the development would not extend beyond any highly
legible visual and landscape termination to the existing settlement; and
The High Weald Joint Advisory Committee is a partnership between: East Sussex, West Sussex, Kent and Surrey County Councils; Horsham, Mid Sussex,
Tandridge, Sevenoaks, Wealden and Rother District Councils; Tunbridge Wells, Hastings, Ashford, Crawley and Tonbridge & Malling Borough Councils;
Defra; and organisations representing farming, forestry, community, business and recreation interests.
e) where the location of the development would not result in the coalescence of
distinct settlements/dwellings; and
f) where the development would not infill important green gaps through which the
High Weald National Landscape is glimpsed and appreciated.
g) In all cases the proposal must accord with policies in the Landscape Character
and Heritage chapters, safeguarding intrinsic and distinctive landscape character
and scenic beauty and paying particular regard to the conservation of the High
Weald National Landscape and historic environment.
h) To prevent the inappropriate extension of settlements, proposals adjacent to a
site which has previously been developed under this provision will not usually be
permitted.
We are also concerned that at present the draft Local Plan sets out no policy for the retention of
housing for land-based workers through the resistance of removal of Agricultural Occupancy
conditions (or similar) – this is set out as a specific ‘Action’ within the Land-based economy & Rural
Living character component of the High Weald AONB Management Plan, in order to help meet rural
housing needs of land-based workers.
An example of such a condition is:
To support the housing needs of the rural land-based sector, land-based workers’ dwellings
will be restricted to remain available for meeting the accommodation needs of a land-based
worker or any resident dependants living withing the property. The removal of an
occupancy condition will only be permitted where it can be demonstrated to the
satisfaction of the Council that:
a) There is unlikely to be any need for such rural worker dwellings at the site or within the
local area as demonstrated by an up-to-date assessment of the demand for land-based
worker dwellings;
b) It can be demonstrated that the agriculture, forestry or land based rural business is no
longer financially viable; and
c) Robust and comprehensive evidence has been provided to demonstrate that the property
has been subject to continuous marketing for an 18-month period at either a rental or sale
price that reflects the occupancy condition in place.
We advise that a similar condition, with appropriate explanatory text, be included either within
Proposed Policy HOU13 or in a dedicated Land-based Workers Housing policy.

Comment

Representation ID: 27362

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy HWB6: Public Rights of Way
We would wish to see this policy include reference to the High Weald AONB Management Plan (for
PROWs within the High Weald NL), in particular to the Management Plan’s Objectives relating to
historic routeways as a key character component of natural beauty in the HWNL.

Comment

Representation ID: 27363

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy ECO5: Tourism Activities, Facilities and Accommodation
There seems to be some duplication and some inconsistency between this policy and the subsequent
Proposed Policy ECO6: Holiday Sites. We suggest these be reviewed to see if they can be combined.
If not, then ECO5 should also include the caveats set out in parts (i) and (ii) of ECO6 relating to
landscape character, the HWNL and the needs of agriculture

Comment

Representation ID: 27364

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy ECO7: Agriculture Development and Forestry
within the ‘New Agricultural Tracks’ section, under part (ix) we would like to see the following text
added:
“…and uses a landscape-appropriate choice of surface material such as crushed stone,
hoggin or road planings, permeable where possible, and avoiding tarmac. Particular care
should be taken in woodlands, including ancient woodlands, where the location and surface
material of any new/enlarged track should not adversely impact on root areas of trees, the
biodiversity of ground flora, or landscape character.”

Comment

Representation ID: 27365

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LAN1: Rural Environments and Landscape Character
This policy is supported, and its references to the High Weald National Landscape are welcomed, as
are references to open landscape between clearly defined settlements, including the visual character
of settlements, settlement edges and their rural fringes, Ancient Woodlands tranquil and remote
areas, including the dark night sky and other key landscape features

Comment

Representation ID: 27366

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LAN2: Trees, Woodlands and Hedgerows
The intention of this policy is generally supported. Trees, woodland and hedgerows, including ancient
woodland, are identified in the High Weald Management Plan as key character components of the
natural beauty of the High Weald. However, in order to give appropriate weight to this, to clarify that
this doesn’t only apply to ‘locally-valued’ or ‘protected’ examples, and to align with the Objectives and
Actions of the HW AONB Management Plan, would wish to see some additions/amendments to the
proposed policy.
We advise the following amendments (additions in bold, also strikethroughs to delete text) to the
opening lines of the policy:
“Development must protect, and, where appropriate, enhance and expand the district’s tree,
hedgerow and woodland resource for landscape character (with particular regard to the HWNL),
ecological habitat, role in climate change adaptation and health and wellbeing.
Development that would result in the unacceptable loss of, or damage to, or threaten the
continued well-being of, locally valued and/or protected trees, hedgerows, community orchards,
veteran trees or woodland will not be permitted. The following criteria must be met:”
In addition, we make the following comments to parts (i), (ii), (iii) and (v) of the policy:
Part (i) Sets out: ‘A CAVAT assessment submitted with all applications impacting on individual
or groups of trees in order to quantify the public amenity value.’ – Our understanding
of the CAVAT method is that it is for individual, usually urban trees, and it doesn’t offer
any number for wider landscape value other than the setting of that tree. It is not
considered a useable tool for woodlands in its current form. It therefore may not be
appropriate to list this as a criteria to be met for all applications, nor to give it such
weight as a primary consideration.
It is also important that the wording of this policy makes clear that amenity value is
not the only consideration; additional wording should be included to set out that
contribution to landscape character and the natural beauty of the HWNL are critical
factors to be considered. References to LVIA assessment could be included here.
The High Weald Joint Advisory Committee is a partnership between: East Sussex, West Sussex, Kent and Surrey County Councils; Horsham, Mid Sussex,
Tandridge, Sevenoaks, Wealden and Rother District Councils; Tunbridge Wells, Hastings, Ashford, Crawley and Tonbridge & Malling Borough Councils;
Defra; and organisations representing farming, forestry, community, business and recreation interests.
Part (ii) sets out: ‘No net loss of hedgerows, as they form a key component of local ecological
networks and ecosystem services.’ Again, its not solely an ecological consideration;
additional wording should be included to set out that contribution to landscape
character and the natural beauty of the HWNL are critical factors to be considered.
Also, the word ‘net’ should be deleted from this line – objectives and actions of the
HW AONB Management Plan place great emphasis on the retention of existing
hedgerows. The policy should set out that there should be no loss.
Part (iii) As above, we consider the words ‘and/or hedgerows’ should be deleted from this part
of the policy.
Part (v) This part of the policy could helpfully also refer not just to proposed soft landscaping
details, but also to the need for planning applications to include details of any proposed
works to existing trees or hedgerows associated with the proposed development.
We also note that the matter of Ancient Woodland is covered not in LAN2, but instead in Proposed
Policy ENV5: Habitats and Species. Whilst we understand why this may have been considered the
appropriate location, we consider that this will lead to confusion for users of the Local Plan, and we
advise that parts vi) and vii of ENV5 be relocated to LAN2, along with explanatory text paras 11.54 –
11.57 inclusive, in order that all consideration relating to trees and woodland are in one place in the
Plan.