Rother Local Plan 2020-2040 (Regulation 18)

Search representations

Results for Persimmon Homes Ltd search

New search New search

Comment

Rother Local Plan 2020-2040 (Regulation 18)

116. What are your views on the Council's proposed policy on affordable housing?

Representation ID: 28023

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that no percentage has been provided in this policy to clarify the level of affordable provision to be provided on qualifying sites. We look forward to seeing and being able to comment upon the final requirement at Reg 19. In addition, we note that policy HOU2 also looks to see the affordable units well-integrated and designed to the same high quality to create tenure-neutral and socially inclusive homes and spaces; and that the affordable housing should be apportioned individually or in small clusters and where this is not proposed it should be robustly justified. Whilst we appreciate and support the need to ensure integration and to create more balanced communities, that has to be weighed against the management objectives of the affordable provider, who often find small clusters to be inefficient, such that this requirement needs to provide for those instances where the affordable provider feels a different approach is justified in that particular instance.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

129. What are your views on the Council's proposed policy on access standards?

Representation ID: 28024

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that policy HOU8 requires all new homes to be NDSS, and that as has already been established in the adopted development plan, there is a requirement for all new dwellings in the district to be M4(2) compliant, and 5% of affordable dwellings to meet M4(3)(2)(b) standards where a need exists. In addition, however, policy HOU8 includes a requirement for 5% of new market housing to meet the “wheelchair adaptable dwellings” standard in Part M4(3)(2)(a). Whilst para 8.71 of the plan suggests that these policy expectations are justified by the district’s ageing population and levels of disability, and the need for homes to appropriately meet the demands of occupiers throughout their lifetimes, this is not in our opinion clear and convincing evidence to justify this requirement and as such we would submit that this part of policy HOU8 should be deleted.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

131. What are your views on the Council's proposed policy on specialist housing for older people?

Representation ID: 28025

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note that policy HOU9 requires all developments of 100 (+) dwellings to set aside at least 10% of the total number of dwellings as specialist housing for older people. It is not clear whether this is in addition to, or as part of, the requirement also being set out in policy HOU8, or whether this could just be bungalows, or buildings that have to have communal areas. As drafted the policy is unclear and thus ineffective. In addition, subject to clarity it could be overly onerous when coupled with other requirements and thus likely to affect a sites viability.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

137. What are your views on the Council's proposed policy on Self-Build and Custom Housebuilding?

Representation ID: 28026

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

It is not clear from the evidence base how many SCHB plots would be required if the existing commitments were taken into consideration. This needs to be established to ensure the policy is justified and will be effective in meeting the outstanding demand. The Council will need to examine other opportunities for meeting the needs of those who want to self-build (see paragraph 57-014 of PPG) such as the disposal of a Council's own assets or supporting regeneration of brownfield sites. A need for self-build plots should not automatically lead to a policy requiring their provision on sites of 20 (+) dwellings. PPG notes that LPAs should be encouraging developers to consider providing plots but makes no reference to requiring their provision. The role of the the LPA is working to identify opportunities rather than placing responsibility on to the development industry to provide plots.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

137. What are your views on the Council's proposed policy on Self-Build and Custom Housebuilding?

Representation ID: 28027

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

The feasibility of delivering SCHB plots on all sites of 20+ dwellings requires consideration. Often, especially on larger sites, there are multiple contractors and large machinery operating, and the development of single plots by individuals operating alongside this construction activity raises both practical and health & safety concerns. Any differential between the lead-in times / build out rates of self & custom build plots and the wider site may lead to construction work outside of specified working hours, building materials stored outside of designated compound areas and unfinished plots next to completed and occupied dwellings, resulting in consumer dissatisfaction. Whilst some sites may be able to locate self-build plots in a manner that reduces these potential risks, on others this will be impossible with developers unable to co-ordinate the provision of self & custom build plots with the development of the wider site.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

138. Are there any alternatives or additional points the Council should be considering?

Representation ID: 28029

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We would submit that the requirement to deliver 5% Self/ Custom-Build Housing on all sites of 20 (+) dwellings is likely to deliver very little in the way of tangible benefits, whilst creating significant difficulties for the builders involved. It would be a lot more effective for the Council to identify self-build sites or allocate certain sites to deliver a higher proportion of Self/ Custom-Build Housing.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

6. What are your views on the Council's proposed policy for net zero standards and which parts of the policy do you support?

Representation ID: 28031

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note the requirements of Policy GTC1. Whilst Persimmon Homes support the Government’s approach set out in the Future Homes Standard, the Government have set out a clear roadmap as to how low carbon homes will, alongside the decarbonisation of the national grid, ensure that the commitments to net zero by 2050 can be met; and recognises the improvements in energy efficiency should be a transition so new homes continue to come forward. The plan has to acknowledge the implications of the transitional period and the need for flexibility during this period, in accordance with the aims and objectives of national policy. As such, not only is policy GTC1 overly complex and likely to impact on delivery/ viability, it is also clearly inconsistent with the approach advocated in the Written Ministerial Statement (Dec 2023). Policy GTC1 should revert to the requirements set out in Building Regs.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

20. What are your views on the Council's proposed policy for Local Nature Recovery Areas?

Representation ID: 28032

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

We note this policy requires all new development to meet the objectives of the East Sussex (including Brighton and Hove) Local Nature Recovery Strategy (LNRS). We do not believe it is inappropriate to require all new development to meet the objectives set out in a document that is not a development plan document. Whilst the council can suggest that development has regard to the LNRS it is not consistent with national policy to require them to meet these objectives. It would also be perverse to require all new developments to adhere to a set of objectives that the council itself only has a duty to have regard to in its decision-making processes. We would therefore recommend that this policy is amended to advise that all new development has regard to the objectives set out in the LNRS

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

22. What are your views on the Council's proposed policy for Biodiversity Net Gain?

Representation ID: 28034

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

Whilst there does not appear to be any justification as to why a 20% BNG requirement is needed, such that we would submit the policy is unsound; Persimmon Homes are committed to doing as much as possible to meet the councils’ aspirations and as such would suggest that rather than require development to deliver at least 20% BNG, the Council recognises in policy that the 10% mandatory requirement is a minimum and that they will look favourably on development that seeks to go beyond this figure. If, however, the 20% BNG requirement is retained the council need to set out that where 20% is not deliverable it will seek to negotiate the viable level that can be provided over the 10% minimum required by the Environment Act 2021.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

23. What are your views on the Council going above the national minimum requirement of 10%?

Representation ID: 28037

Received: 22/07/2024

Respondent: Persimmon Homes Ltd

Agent: Judith Ashton Associates

Representation Summary:

The council need to have regard to the ecological baseline and the difficulties delivering 10% BNG, let alone 20% can have where the baseline is already high, such that offsite credits will be required, the level of which for smaller sites would be financially prohibitive such that the actual capacity of said sites may needs to be revisited. To this end we are aware of anecdotal evidence that suggests that to deliver 20% BNG a sites net to gross will fall from circa 75 to circa 65%, which can as a result impact on its overall development capacity and the councils associated housing land supply.

Attachments:

For instructions on how to use the system and make comments, please see our help guide.