Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28285

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

Proposed Development Strategy
2.34 Having established the housing targets for the Local Plan period, the Draft goes that the focus for growth will be in the following broad locations:
● West and North Bexhill to consolidate Bexhill as the most sustainable town, within the capacities of the existing transport network;
● clusters of villages based around the towns of Battle and Rye which act as key transport hubs;
● settlements on radial routes connected to the main urban areas of Bexhill and Hastings, allowing sensitive development in locations that rely on the larger towns for services and facilities;
● development at Hastings Fringes, providing sensitive growth; urban intensification and redevelopment across the district in appropriate and sustainable brownfield site locations;
● sensitive development in other rural settlements of the district; and
● in the longer-term, sensitive growth along the A21 Corridor.

Delivering the Spatial Strategy
2.35 Rother’s proposed development strategy has been split into five spatial sub-areas, which align with the focus areas of growth presented above. Each of these spatial sub-areas has their own vision statement and identified distribution of development. The five sub-areas comprise:
• Bexhill;
• Hastings Fringes and settlements that radially link to Hastings;
• Battle and its cluster of connected settlements;
• Rye and its cluster of connected settlements; and
• Northern Rother – the settlements in the north-east of the district.

2.36 In all five-sub areas there is open countryside, which relates to those areas outside of villages with development boundaries and includes farmland, woodland, hamlets and scattered development.

Comment

Representation ID: 28286

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.37 We support the vision for the Northern Rother sub-area which states:
Northern Rother’s rural settlements and communities will continue to thrive, through smallscale sensitive residential development and growth in villages to create sustainable forms of development and protect and enhance the landscape character and scenic beauty of the High Weald National Landscape. This will ensure that health and wellbeing and community cohesion is maintained and improved.

While inevitably most rural residents have no choice but to travel primarily by car, connectivity between rural settlements and the Hastings-London rail line will be enhanced through promoting and improving sustainable and active transport infrastructure including walking, wheeling and cycling, enabling communities to lead healthy and active lifestyles.

The two stations at Etchingham and Robertsbridge will continue to act as transport hubs for wider villages in Northern Rother. There are opportunities for sensitive development in the short term, where sustainable and related to an existing settlement. Also, the area will continue to be served by the smaller Stonegate station.

Longer term (over a 30-year timeframe), the delivery of significant improvements to create a sustainable transport corridor, including bypasses to Flimwell and Hurst Green could open up opportunities for future development along the A21 corridor.

2.38 However, we consider that the policy wording ‘through small-scale sensitive residential development and growth in villages’ should be amended to also support sustainable expansions of existing villages where appropriate. This would align with the intention of Spatial Development Option 4 which is centre on prioritising new development on the edge of sustainable settlements and extending settlement boundaries where appropriate.

Comment

Representation ID: 28287

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.39 We further support the classification of Robertsbridge as a Settlement of ‘Good Sustainability’ and as one of the most sustainable rural villages in the district in the settlement study.

2.40 Fig 29 of the Plan identifies potential for an additional 305 dwellings to be delivered in the village of Robertsbridge. This includes 178 dwellings on sites either allocated or with planning permission (shown in purple in Figure 2), and an additional 127 dwellings across sites assessed as being potentially available, potentially suitable and potentially achievable within the HELAA (shown in orange in Figure 2 [map 5.9 of the HELAA Part 2 Chapter 5: Northern Rother]).

2.41 The number of sites identified in orange in Figure 2 above appears to reflect the numbers suggested in Table 2, reflecting a mix of available sites around Robertsbridge. Note that the Grove Farm (Phase 2), Robertsbridge appears to be the largest of these HELAA Potential Sites and therefore has the potential to accommodate not only the largest number of homes but also onsite biodiversity net gain in accordance with the Council’s emerging 20% aspiration. The site would form a natural extension of the already consented and deliverable Phase 1 scheme immediately to the west and would mesh with the existing settlement in a sustainable manner, offering sustainable transport links into the heart of Robertsbridge.

2.42 We support the distribution of growth across the sub-areas set out in Figure 29 of the Local Plan, which prioritises growth in Robertsbridge. As outlined in the Settlement Study, Robertsbridge is the highest scoring settlement in sustainability terms outside of Bexhill, and Rye and the most sustainable rural village in the district, alongside Northbridge Street. Given the extent of the identified housing shortfall in the emerging Plan, there should be no doubt that sites considered “potentially suitable” on the edge of settlements, such as the Land at Grove Farm (Phase 2), Robertsbridge, should be upgraded to form part of the “Identified Level of Housing Growth” to help boost the supply of deliverable housing land in the district.

Comment

Representation ID: 28288

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.43 For the reasons set out in Chapter 3, we support SAL0022: Land at Grove Farm. Development on this site would form a logical extension to the adjacent Phase 1 will benefits from planning permission and will soon be developed. The owner of both sites is a major institutional landowner who has best interests in ensuring a positive legacy on the site.

2.44 Given the extent of the identified housing shortfall in the emerging Plan, there should be no doubt that sites considered “potentially suitable” on the edge of settlements, such as the Phase 2 Land at Grove Farm, should be upgraded to form part of the “Identified Level of Housing Growth” to help boost the supply of deliverable housing land in the district.

2.45 The HELAA identifies the site as having an estimated development potential of 35 dwellings. The accompanying illustrative masterplan has been informed by technical evidence to demonstrate the site’s deliverability. It shows a potential development layout of 35 dwellings – note however that this would be at a density of only 21 dwellings per hectare within the core development area (i.e. not the areas in the north or south identified as sensitive landscape) (1.7ha), and so there is clearly the potential for the density of development to be optimised. This would help the Council boost the supply of housing on sites considered favourably by its own evidence base.

In addition, see Section 3 of the attached representation which providers greater details on the site including:
- Site Context;
- Site Boundaries;
- Relationship to High Weald National Landscape;
- Redefining the Village Edge;
- Responding to Visual Sensitivity;
- Greenspace and Vegetation Structure;
- Vehicular Access;
- Flood / Drainage;
The representation is also supported by the three appendices within the attached.

Comment

Representation ID: 28289

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.46 As outlined at paragraph 2.19, we support the 30-year vision for the A21 transport corridor and the proposed sustainable travel improvements, however, we do not consider that this should be limited to longer-term growth along this corridor should be unnecessarily delayed. There are already suitable opportunities along the A21 to deliver sustainable growth in the shorter-term, for example at Robertsbridge.

Comment

Representation ID: 28290

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

2.47 Proposed Policy DEV3: Development Boundaries states:
"Development boundaries define the area within sustainable settlements where development will be permitted, provided it is consistent with this Local Plan.
"Priority shall be given to reuse of brownfield sites, in order to make efficient use of previously developed land in sustainable settlements. Some greenfield development will be necessary in order to deliver housing and employment need, but this will be limited to inside development boundaries.
"In the countryside (that is, outside of defined development boundaries), development shall be limited to that which accords with specific Local Plan policies or that for which a countryside location is demonstrated to be necessary. Brownfield development will be prioritised, in order to make efficient and sustainable use of previously developed land."

2.48 As outlined in Table 1, there is currently, a significant shortfall in the availability of land for housing and the district is unable to achieve its Local Housing Need target. Even when factoring in potential sites from the HELAA, the district still has a significant undersupply.

2.49 We, therefore, support the review of each settlement’s boundary, as outlined in paragraph 5.119 of the Draft Local Plan. In the context of the land to which these representations relate, it is considered that the A21 to the east already forms a logical and defined boundary which a revised settlement boundary could follow. The masterplan for the site to which these representations relate, attached within Appendix 1, demonstrates an indicative edge of development in order with the opportunities and constraints of this site, which a revised settlement boundary in this location could follow.