Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28272

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.1 We support the overall vision of the Draft Local Plan set out on page 19 of the Regulation 18 version, because we acknowledge the Council’s recognition of the need to balance competing planning policy objectives. In particular, we support the vision that by 2040 ‘Bold solutions will have successfully addressed the climate and biodiversity emergencies and the housing crisis while protecting the High Weald National Landscape’.

2.2 At paragraph 2.3, the draft Local Plan goes onto state:
Our complex challenges require bold solutions. The Plan must seek to maximise housing delivery in a manner that is appropriate for the protected national landscape and habitat areas which form much of its context. The Plan must also futureproof policy to build in flexibility as national policy and the economy changes.

2.3 The development of land to which these representations relate would help to address the housing crisis and maximise housing delivery, so we support the Plan’s intention to futureproof policy and contain in-built flexibility.

Comment

Representation ID: 28273

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.4 We support the Twin Overall Priorities that have been identified to meet the Local Plan’s vision. The priorities, set out below, balance the needs of housing to support residents and protecting the High Weald Area National Landscape:

Overall Priority 1 – Green to the Core: Being Green to the Core means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald Area National Landscape.
Overall Priority 2 – Live Well Locally: means considering, when making all planning decisions, the goal of creating
● Healthy, sustainable and inclusive communities that support residents across the age spectrum in terms of housing, access to jobs, services and facilities.
● ‘Connected and compact neighbourhoods’ in our towns with ‘village clusters’ in our rural locations, where people can meet most of their daily needs within a Page 4
reasonable distance of their home, with the option to walk, wheel, cycle (active travel) or use public transport.
● New development that creates places that are not just visually appealing, but also inspire and foster a sense of belonging, identity, and shared experience.

2.5 Prioritising housing needs accords with the NPPF which provides a framework within which locally prepared plans can provide for sufficient housing and other development in a sustainable manner. At paragraph 11, the NPPF sets out that plans should apply a presumption in favour of sustainable development and that strategic policies should, as minimum, provide for objectively assessed needs for housing and other uses.

Comment

Representation ID: 28274

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.6 Under its Twin Overall Priorities, the Local Plan outlines 10 key planning issues, which directly feed into the Strategic Spatial Objectives. Among others, we outline specific support for the following issue which recognises the importance of meeting local demand for housing:
● Meeting the overall local demand and need for housing (including affordable and specialist need) and associated growth – taking a landscape and sustainability led approach across the district.

2.7 Seeking to meet the overall demand and need for housing aligns with the new government’s plans to reintroduce mandatory housing targets across each local planning authority in England by autumn of this year. Cognisant of this, Rother Council should be aiming to meet its housing needs in full.

Comment

Representation ID: 28275

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.8 We support the 10 Strategic Spatial Objectives set out in the Draft Local Plan. In particular, Spatial Objective 4 which seeks to ‘Respond to the housing crisis and help facilitate the delivery of housing to meet the needs of different groups in the community, ensuring a variety of high-quality sustainable, zero carbon ready dwellings that meet the needs and income levels of Rother’s wider population for their lifetime’.

2.9 It is also worth noting that the development of land to which these representations relate is also compatible with Spatial Objective 2 which seeks to ‘preserve the historic landscape character of the High Weald National Landscape and protected habitat areas of Rother’ and Spatial Objective 7 which seeks to ‘focus growth in sustainable locations across the district, or places that can be made sustainable through supporting infrastructure and community facilities.’ Done well, development has the capability to reinforce local distinctiveness and character and have an overall positive townscape and visual impact.

Comment

Representation ID: 28276

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.10 We note that the proposed policy wording states that all qualifying development proposals must deliver at least 20% a measurable biodiversity net gain attributable to the development and that this is higher than the minimum mandatory threshold of 10%.

2.11 Whilst we note that the consultation document doesn’t currently appear to be supported by evidence to support why this additional requirement is proposed, we anticipate that the development of the site subject of these representations could be accompanied by suitable proposals to achieve the proposed biodiversity net gain requirement, making use of the northern and southern land parcels within the site, and if necessary use of extended land within Exeter Colleges ownership, on the eastern side of the A21. Comparable to other potentially suitable sites within Robertsbridge, shown in Figure 2, we draw attention to the favourable extent of available land within the ownership of Exeter College which shows that this policy aspiration as currently drafted could be met through the allocation and development of this site.

Comment

Representation ID: 28277

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.10 We note that the proposed policy wording states that all qualifying development proposals must deliver at least 20% a measurable biodiversity net gain attributable to the development and that this is higher than the minimum mandatory threshold of 10%.

2.11 Whilst we note that the consultation document doesn’t currently appear to be supported by evidence to support why this additional requirement is proposed, we anticipate that the development of the site subject of these representations could be accompanied by suitable proposals to achieve the proposed biodiversity net gain requirement, making use of the northern and southern land parcels within the site, and if necessary use of extended land within Exeter Colleges ownership, on the eastern side of the A21. Comparable to other potentially suitable sites within Robertsbridge, shown in Figure 2, we draw attention to the favourable extent of available land within the ownership of Exeter College which shows that this policy aspiration as currently drafted could be met through the allocation and development of this site.

Comment

Representation ID: 28280

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.12 The proposed Policy GTC9 states:
All development within or affecting the setting of the High Weald National Landscape (AONB) shall conserve and enhance its distinctive landscape character, ecological features, settlement plan and scenic beauty, having particular regard to the impacts on its character components, as set out in the latest version of the High Weald AONB Management Plan.

Development within the High Weald National Landscape should be small-scale, in keeping with the landscape and settlement pattern, and designed in a way that reflects its nationally designated status as landscape of the highest quality, following the guidance in the High Weald AONB Housing Design Guide and Colour Study. Major development should not take place in the AONB save in exceptional circumstances as outlined at paragraph 183 of the NPPF.

2.13 We note the proposed conservation of the High Weald National Landscape and agree with the principle that all development within the National Landscape should be in keeping with the landscape and settlement pattern.

2.14 We consider that the development of land to which these representations relate could be allocated for residential purposes in the emerging Plan and developed for residential uses in a manner compatible with this policy in principle and such that it does not have a significant adverse impact on the purposes for which the High Weald National Landscape has been designated.

2.15 Notwithstanding the sensitivity of the National Landscape, the NPPF also supports the sustainable development of rural areas. In particular, 83 of the NPPF states that in rural areas planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. The NPPF at paragraph 11 also states, inter alia, that plans should apply a presumption in favour of sustainable development, which for plan-making, means that all plans should promote a sustainable pattern of development that seeks to meet the development needs of their area. We therefore consider that the presence of the High Weald National Landscape should not present an in-principle reason to restrict growth where sensitively achievable and in line with the evidence.

Comment

Representation ID: 28281

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.16 We note that the proposed Policy GTC9 sets out prescribed density ranges for new residential development, dependent on a sites location, as follows:
d. Village areas (with development boundaries): 25-45 dph
e. Countryside areas (including villages and hamlets without development boundaries): in the instances where residential development is supported by policies in this plan, the density should reflect the existing character of the area.

2.17 In general, we agree to the principle of proposing indicative densities to inform the efficient use of land, however, we object to the wording of the proposed policy as it currently stands on the basis that it is too prescriptive and lacks flexibility to take account of individual locational circumstances. The appropriate density for development on a site should be considered on a case-by-case basis taking into account the specificities of the sites location, context, and wider design-related policies and should not be bounded to pre-determined ranges.

2.18 We therefore suggest that the wording is amended to enable greater flexibility to allow for smaller or greater quanta of development, where appropriate.

Comment

Representation ID: 28283

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.19 The Council has considered a series of potential spatial development options (SDO’s 1-12), and these have individually undergone a Sustainability Appraisal. These are detailed in the Development Strategy Background Paper which forms part of the Draft Local Plan Evidence Base.

2.20 With respect to the land to which these representations relate, the following options appear to be compatible with the further sustainable growth of Robertsbridge:
● SDO10: A21 Corridor – Development along the A21 within an identified corridor of settlements, with opportunities for growth. Opportunities for sustainable travel through enhanced bus services and cycle track along this corridor.
● SDO4: Sustainable Development Growth – prioritise new development on the edge of sustainable settlements, providing major development and extending settlement boundaries where appropriate.
● SD011: Growth in the settlements with train stations – development around train stations in settlements served by them.

2.21 The Development Strategy concludes that the most appropriate spatial development options to take forward as Rother’s proposed development strategy is a combination of the following options:
● Brownfield intensification and redevelopment within sustainable settlements (SDO6)
● Bexhill greenfield growth on the northern and western edges of the built-up area of Bexhill to create new compact, connected communities (SDO3A)
● Hastings Fringes urban growth (SDO5)
● Radial settlement network connected to Bexhill and Hastings (SDO2)
● Village clusters centre around Rye and Battle (SDO1)
● Sustainable settlement growth (SDO4) with longer term, a focus on the A21 Corridor
(SDO10).

2.22 Spatial Development Options 3B, 7, 8, 9 and 12 are explicitly discounted at paragraph 10.5 of the Background Paper. SDO11 is not outlined as either being taken forward or discounted, however, the vision for Northern Rother (see paragraph 2.37) would appear to suggest that it has been taken forward, which we would support.

2.23 We support Spatial Development Option 04 and the approach to focus growth in settlements that score highest with regards to sustainability, which as outlined in paragraph 2.42 includes Robertsbridge. This would be fundamentally in line with NPPF paragraph 11 which states that all plans should promote a sustainable pattern of development. The development of land to which these representations relate would be compatible with this preferred Spatial Development Option.

2.24 We support the principle of SDO10, however, we do not consider that this should be limited to longer-term growth only. We are supportive of this option’s aspiration to anticipate and respond to long-term requirements but this should be in recognition of existing suitable opportunities along the A21 to deliver sustainable growth on deliverable sites in the shorter-term, for example at Robertsbridge. The development of such sites should not be delayed unnecessarily, especially when such sites are available now.

Comment

Representation ID: 28284

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

Housing Need
2.25 On page 112, the draft Local Plan sets out the overall Spatial Development Strategy. This states:
The Council will meet the local need for all forms of housing, jobs, facilities and services by strengthening Rother’s pattern of development through a landscape-led spatial development strategy that focuses on the ‘Live Well Locally’ concept. To achieve this, a minimum of [5,158 to 7,287]* dwellings, at an average rate of [258 to 364]* per year…will be constructed by the end of the Plan period in 2040.

*The final housing and employment target will be minimum figures. For the Regulation 18 consultation, the overall housing and employment figures are presented as a range, with the lower figure representing the totals of the “identified sites” (current allocations and sites with planning permission), and the upper figure representing the identified sites plus the total capacity of “potential additional sites” (sites identified in the daft HELAA as being potentially suitable, available, and achievable for development during the Local Plan period). Therefore, the range is subject to change (either by an increase or reduction).

2.26 It is understood that using the national standard method, Rother’s minimum local housing need (LHN) figure is 733 dwellings per year (2023 Base Date). This is in contrast to the adopted Core Strategy target of 355 dwellings per annum, and significantly exceeds the delivery rates of housing delivery between 2011-2028 which averages at 219 net additional dwellings per year.

2.27 The Housing and Economic Land Availability Assessment (HELAA) (Draft Regulation 18 Version – April 2024) forms part of the evidence base underpinning the Draft Local Plan. At paragraph 2.5 it states ‘the HELAA will determine the amount of land available for residential development and the resulting number of dwellings that could be accommodated in Rother over the plan period, in line with NPPF paragraph 67. This figure may be compared to the minimum local housing need (LHN) figure defined using the standard method calculation’.

2.28 The HELAA goes onto state at paragraph 7.7:
it is clear that in terms of dwellings numbers, insufficient potential has been identified to meet the local housing need (LHN) figure, calculated using the standard method calculation set out in the NPPF (discussed in section 2 above). The current standard method calculation identifies a need for 14,660 dwellings over the 20-year period of the new Local Plan (2020- 2040) (733 dwellings per annum). In contrast, as shown in Figure 4, the potential identified in the HELAA plus dwellings already constructed plus a windfall projection is between 5,158 and 7,287 dwellings over the 20-year period.

2.29 The current evidence base, therefore, indicates a significant shortfall in sites, as summarised in Table 1 (within the attached representation).

2.30 We note that the housing supply doesn’t propose to meet the LHN in full, which means that the Council should progress with the Plan on the basis of the higher housing need figures, as a minimum. Not factoring in the ‘potential addental sites’ would put the housing supply at 35.1% of the housing need. This would be at conflict with the overarching vision of the Local Plan and its Twin priorities and Spatial Objectives which we endorse. It would also fail to support the Government’s objective of significantly boosting the supply of homes.

2.31 On the basis that the Council is unable to meet its LHN, it is important that the Council plans to allocated additional land to increase its supply position, and/or work existing sites to ensure that more efficient use of land could be used where appropriate, such as the Land at Grove Farm (Phase 2), Robertsbridge, which is attributed an indicative capacity of 35 dwellings but could deliver more. At the very least, additional sites that have not been discounted within the Council’s own HELAA, such as the one to which these representations relate, should, be considered favourably and taken forward as an allocation within the emerging Local Plan where they are available and deliverable.

2.32 ‘SAL0022: Land at Grove Farm (Phase 2), Robertsbridge’, the site to which these representations relate, counts towards one of the ‘potential additional sites’ outlined in Table 1. Within the HELAA this site is assessed as being potentially suitable, potentially available and potentially deliverable, subject to further assessment or investigation. The initial assessment states ‘While it is located within the High Weald National Landscape (HWNL), the site has few other environmental constraints and could form a logical extension to the permitted development, in a sustainable location within walking distance of services and public transport links in Robertsbridge’.

2.33 Further detail on the suitability and development capacity of this site are provided in Chapter 3. To summarise this is one example of a site which should be taken forward as an allocation within the emerging Local Plan in order to increase the Council’s Housing Supply Position which currently falls significantly behind housing need.