Rother Local Plan 2020-2040 (Regulation 18)

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Comment

Rother Local Plan 2020-2040 (Regulation 18)

54. What are your views on the Council's proposed spatial development strategy and proposed minimum targets for housing and employment growth?

Representation ID: 28012

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

In terms of the additional HELAA potential sites, we note that the HELAA discounts an unquantified number of ‘Other Potentially Suitable Sites Where Availability is Unknown’ and Rejected Sites (sites assessed as currently unsuitable/ unavailable/ unachievable), and that it is unclear how releasing some of these sites would come to enabling the council to meet their LHN if the assessment criteria were reviewed/ the sites themselves reassessed in terms of the overall area to be developed/ development capacity were reviewed. Given the scale of the unmet need we would respectfully suggest that no stone should be left unturned in looking to achieve the LHN and that whilst not all of the rejected sites will be acceptable, some may, with further consideration, have been suitable, such that the overall quantum of deliverable sites and thus the plans ‘capacity’ based housing figure could be higher.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

51. What are your views on the Council's preferred spatial development options?

Representation ID: 28014

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

Figure 33 shows that a considerable amount of the proposed growth, both committed and proposed, that 46% of the proposed growth is in and around Bexhill, with only 9% being directed towards Battle, only 3.6% to the Hastings fringe. Whilst we acknowledge that Bexhill is the least constrained of the main centres, one has to wonder if this is a sustainable approach, especially given the public transport links and level of services available in the likes of Battle and Robertsbridge. Comparing figure 35 of the Reg 18 Plan (the opportunities for housing growth) with Figure 12 of the settlement study (part 1) (Settlement Sustainability Score Table), the level of growth proposed in the Sustainable and Moderately Sustainable settlements is significantly less than in Bexhill, which whilst it is the only ‘Highly Sustainable’ settlement seems somewhat out of proportion and could lead to market saturation and actually prejudice housing land supply.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

80. What are your views on the Council's proposed policy on comprehensive development and masterplanning?

Representation ID: 28015

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note the requirements of Policy DEV2. Where sites are in multiple ownership, we would suggest that as long as a framework masterplan covering the whole site, and an infrastructure delivery strategy has been agreed, either through the site promoters and the council or via an SPD, there should be nothing to stop one party looking to promote their site in advance. As long as the application reflects the framework masterplan and s106 proceeds in accordance with the infrastructure delivery plan we fail to see how this would prejudice the plan. Indeed, it may well allow sites to proceed more quickly and thus actively assist the council in their housing land supply.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

82. What are your views on the Council's approach to development boundaries?

Representation ID: 28016

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note Policy DEV3. Whilst we assume the development boundaries will be redrawn to reflect the proposed allocations, we would also suggest that given the shortfall in the housing land supply, that the council should look to have a criterion based policy that enables development immediately adjacent to the limits of built development subject to certain criteria. For example, within Mid Sussex, policy DP6 provides for the expansion of settlements outside defined built-up area boundaries subject to meeting certain criteria. A similar policy approach would we believe be appropriate here and would assist the council in meeting their LHN.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

87. What are your views on the Council's strategy approaches to small sites and windfall development?

Representation ID: 28017

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that DEV5 refers to the windfall rate of 39dpa. Given our comments above, this will need to be properly justified within the evidence base for the Reg 19 Plan.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

90. What are your views on the Council's approach to strategic gaps and those that are identified?

Representation ID: 28018

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

Turning to DEV6, and the Strategic Green Gaps, the current strategic gap between Bexhill and Hastings should not be seen as a constraint on development on a par with the AONB or any other NPPF footnote 7 constraint, and should not in our opinion be carried over from the current core strategy without first being reviewed to establish if they can accommodate some growth to assist the council in meeting their LHN/ meeting the unmet needs of their neighbours, especially Hastings.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

94. What are your views on the Council's proposed policy on requiring a Health Impact Assessment for certain applications?

Representation ID: 28019

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that policy HWB2. Whilst Persimmon Homes would agree that HIA are an essential part of plan making to ensure the Council understand the health outcomes of its strategy and is thus able to ensure these are effectively addressed, this should be achieved through the preparation of a whole plan HIA which will help inform the Council that the policies the plan contains address the key health outcomes for the area. It is unnecessary for future development proposals that accord with this plan to undertake a separate HIA. If a development meets the policies in the plan, then it is by default addressing the health outcomes already identified by the Council. The only circumstance where an HIA may be appropriate would be for a larger unallocated site where the impacts may not have been fully considered by the council as part of the plan wide HIA.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

101. What are your views on the Council's proposed policy on green and blue infrastructure?

Representation ID: 28020

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

Criterion 5 of HWB5 requires developments of 300 (+) dwellings to provide playing pitches on site in line with the recommendations of Rother’s Playing Pitch and Built Facilities Strategy and Sport England’s standards. Whilst not opposing this criterion, Persimmon Homes would suggest that the following is added to criterion 5 ‘unless evidence suggests that this is unachievable” as a sites topography may not make this possible/ economies of scale may mean providing / contribution to offsite provision is in certain circumstances preferable; or that this would fetter a developer’s ability to deliver BNG on site as such facilities do not assist in trying to deliver BNG. Indeed, they can actively prejudice it.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

109. What are your views on the Council's proposed policy on strategic infrastructure requirements?

Representation ID: 28021

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that policy INF1 (A) indicates that ‘Where new infrastructure capacity is required, it must be demonstrated that it can be delivered upfront or early in the development phasing.’ As the councils will be aware, the question of the supply of utilities to support development (including residential development) is a matter that is dealt with through separate statutory regimes. Providers such as the water and energy companies are required, among other things, to ensure a supply of services adequate to meet the needs of the plan-led system. As such policy INF41 (A) should not require applicants for planning permission to demonstrate that there is sufficient capacity with regard to provision of utilities such as water and power. Furthermore, when considering other infrastructure requirements, the policy should have regard to the cash flow implications of this criteria and be caveated accordingly.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

114. What are your views on the Council's proposed policy on mixed and balanced communities?

Representation ID: 28022

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

In noting the unit mix proposed in policy HOU1, we would in the first instance question the extent to which policy HOU1 should look to be prescriptive on the market housing to be delivered across the district for the whole of the plan period; rather the Council should recognise the need for flexibility, as per the NPPF and PPG, as the fact is the needs of the area may well change over the lifetime of the plan, particularly given the current uncertainty in the housing market, and that different areas will inevitably deliver different forms of housing i.e. apartments within more urban town centre locations and family housing in suburban areas; and that it is the combination of the two that will ultimately address the overall need.

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