Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28069

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

Bellway supports the vision to provide growth on the edges of Bexhill through greenfield sites. Although the site at Clavering Walk benefits from planning permission, its allocation as an identified site would reflect this vision and help to realise RDC’s approach to securing sustainable growth in this location. It would also reflect the Council’s aspiration to secure further development in west Bexhill (paragraph 5.37) and well connected and sustainable growth (paragraph 5.40). In this regard, and in relation to paragraph 5.38, it is relevant to note that an acceptable approach for drainage has been secured for the site which ensures the protection of the adjacent Pevensey Levels.

Comment

Representation ID: 28070

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

The vision refers to making urban extensions a higher density. In order to comment on this aspect, Bellway would seek to understand what parameters there are for this and what factors would be considered by RDC to inform the policy and associated decisions. It is however agreed that in the highly sustainable locations (as per figures 13 and 14) in and around Bexhill for example, a higher density of development is likely to be appropriate.

Comment

Representation ID: 28071

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

Figure 16 of the ELP includes the site as an identified site for 70 homes. Bellway supports the identification of the site for housing delivery.

In the HELAA, the site is given reference BEX0016. The HELAA recognises that “identified” sites are “Existing allocations and sites with planning permission. Sites are assumed to be suitable, available and achievable for development, unless otherwise stated”

The site meets these requirements not simply because it benefits from planning permission, but from a planning permission that has been implemented and therefore is capable of bringing forward homes early in the plan period.

See the attached letter, specifically pages 3 and 4, for a table summarising the comments on HELAA site BEX0016, which in summary, seek that the site is allocated for the 85 dwellings approved at the Outline planning permission RR/2018/3127/P.

Bellway does not wish to comment at this time on any other site that has been identified in the HELAA, including those which are earmarked as potential growth options. However, it is essential to ensure identified sites such as BEX0016 are allocated to provide a secure housing provision.

Comment

Representation ID: 28072

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

The HEDNA confirms that the LHN is 737 dpa. However RDC is currently proposing to target between 258 to 364dpa, markedly lower than the assessed needs.

RDC is reminded that whilst the updated NPPF advises at paragraph 61 that the standard method is an advisory starting point for establishing housing needs in an area, it is also clear that:

“There may be exceptional circumstances, including relating to the particular demographic characteristics of an area[fn25] which justify an alternative approach to assessing housing need; in which case the alternative approach should also reflect current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for [fn26]”

In this case, the HEDNA advises that there are no exceptional local circumstances that justify deviation from the standard method (para xxxiii of the executive summary; chapter 6 summary, chapter 6 paragraph 6.40). It is not clear whether RDC has considered any unmet needs from neighbouring authorities.

Furthermore, the NPPF continues to reflect the Government objective of “significantly boosting the supply of homes” (paragraph 60) and at present the ELP would not meet this objective.

Thus in order to work towards meeting the district’s housing needs and comply with the NPPF, sites with planning permission for housing, such as Land at Clavering Walk, must be allocated and safeguarded. RDC must also consider further ways to deliver much needed housing in sustainable locations, including enabling a higher density on sites (as per the vision) where this is appropriate.

Comment

Representation ID: 28073

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

The purpose of having a stepped trajectory is not clear, particularly as figure 37 of the ELP shows that even the lower end of the housing requirements have not been met over the last 10 years.

On this basis, it is questionable whether the current LHN would also be met, and to what extent a stepped trajectory would assist. If anything, it may give a false illusion that housing needs are being met (or nearly so) when in fact, the wider picture would show otherwise.

Thus, RDC should be focusing on securing sites that can deliver homes early in the plan period to boost supply early on and enable a more consistent housing delivery target over the plan period.

Comment

Representation ID: 28074

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

With regards to the proposed policy on development boundaries, Bellway has some concerns over the wording proposed in the policy (DEV3). However, given the nature of this representation to encourage the allocation of the site in the ELP, no specific comments are provided at this stage. This is however on the assumption that the site will be allocated for housing and will be included within the settlement boundary.

In any event, RDC must be mindful of the overall objectives of the plan, and how this policy aligns with that, in addition to how RDC will otherwise anticipate housing and development needs meeting sufficiently met over the plan period. There is a risk that this policy could be too restrictive and not allow for the essential growth that is needed.

Bellway supports the intention of RDC to review settlement boundaries as part of the ELP process, and would expect that all site allocations are included within the revised boundaries to allow for growth to come forward quickly and effectively. RDC should consider further how it would address needs in more rural locations which may not benefit from a defined settlement boundary. In such instances, it should not be assumed that only limited development needs exist, as this could exclude groups within the community and force them away from their preferred living and working areas.

Comment

Representation ID: 28075

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

With regards to the proposed policy on development boundaries, Bellway has some concerns over the wording proposed in the policy (DEV3). However, given the nature of this representation to encourage the allocation of the site in the ELP, no specific comments are provided at this stage. This is however on the assumption that the site will be allocated for housing and will be included within the settlement boundary.

In any event, RDC must be mindful of the overall objectives of the plan, and how this policy aligns with that, in addition to how RDC will otherwise anticipate housing and development needs meeting sufficiently met over the plan period. There is a risk that this policy could be too restrictive and not allow for the essential growth that is needed.

Bellway supports the intention of RDC to review settlement boundaries as part of the ELP process, and would expect that all site allocations are included within the revised boundaries to allow for growth to come forward quickly and effectively. RDC should consider further how it would address needs in more rural locations which may not benefit from a defined settlement boundary. In such instances, it should not be assumed that only limited development needs exist, as this could exclude groups within the community and force them away from their preferred living and working areas.

Comment

Representation ID: 28076

Received: 23/07/2024

Respondent: Bellway Homes

Agent: Savills

Whilst there are additional policies relating to housing provision, that are not considered in this representation, this is owing to the focus on Clavering Walk, Cooden. Bellway may comment on these and other aspects of the ELP at later consultation stages where considered relevant.