Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28397

Received: 23/04/2025

Respondent: Gladman Developments

Gladman are generally supportive of the vision and overall priorities of the Rother Local Plan
although consider that a further priority should be supported in facilitating growth. The new
government has been clear about the importance of supporting growth and this should be
recognised through the vision of the Local Plan whilst striking a balance between the two
identified priorities.

Whilst the vision sets out an appropriate aspiration, it is not backed up by the policies in the
local plan which is currently proposing not to meet housing needs, which in turn will have
significant consequences for the local community.

Comment

Representation ID: 28398

Received: 23/04/2025

Respondent: Gladman Developments

Whilst we agree that there is a need to act to reduce carbon emissions through the
construction and operation of new buildings, we would suggest that this should not be undertaken through local plan policies given that there is already a national approach, the
Future Homes Standard, being taken forward to achieve the same goal. Delivering these
improvements through building regulations has a distinct advantage over delivering a
variety of different approach across the country in that it provides a single approach that all
developers understand and can be rolled out at scale. This allows supply chains and skills to
be improved prior to implementation and ensure that improvements to building standards
are actually deliverable from the point at which they are introduced.

Comment

Representation ID: 28399

Received: 23/04/2025

Respondent: Gladman Developments

The policy states that all development must meet the objectives of the East Sussex
(including Brighton and Hove) Local Nature Recovery Strategy (LNRS). It is inappropriate
to require development to meet objectives in a document that is not a development plan
document. Whilst the council can suggest that development have 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 development to adhere to a set of objectives that the council itself
only has a duty to have regard to in its decision-making processes. Gladman recommends
this amended to state development will have regard to the objectives set out in the LNRS.

Whilst Gladman would agree with the principle of having regard to Local Nature Recovery,
it is considered that additional clarity would be required by what is meant by directing
‘Biodiversity Net Gain to where it can be of most benefit’ and a suitable balance must be
struck in supporting the environment whilst also facilitating development.

Comment

Representation ID: 28400

Received: 23/04/2025

Respondent: Gladman Developments

Recognising that the Environment Act sets the 10% as a minimum and Government
statements indicate that Councils can go further in local plans, this would need to be
justified that there is both a need to go beyond 10% and that this requirement will not, when
considered in combination with other policies impact on the deliverability of the local plan.

The Council must recognise that delivering statutory net gains is still in its infancy and as
such there is great uncertainty as to the most effective way of delivering BNG, the cost of delivering 10% net gain, and whether there will be sufficient local offsite credits in the short
and medium term to support schemes that cannot deliver a 10% gain on site.

The Councils must also be clear as to ecological reasons why development would be
required to deliver a higher level of net gain than the statutory minimum. A 10% net gain
will ensure that development leaves more biodiversity than was previously the case.

Comment

Representation ID: 28401

Received: 23/04/2025

Respondent: Gladman Developments

Recognising that this policy is seeking to ensure that new developments are well designed,
attractive and healthy places sufficient flexibility should be afforded to the densities of new
development to ensure good place making. Over prioritising higher densities does not
necessarily lead to better place making. Gladman consider that further flexibility should be
applied to these development densities.

Comment

Representation ID: 28402

Received: 23/04/2025

Respondent: Gladman Developments

Whilst recognising the desire for developments to be located within 800m walking distance
of a number of key services and facilities this is not always possible in the largest most
sustainable settlements in the district.

In instances such as this, the flexibility afforded to larger villages and countryside locations
should equally apply to the most sustainable settlements, which whilst not necessarily
within the 800m walking distance, a greater number of services and facilities are available
to communities in the vicinity.

Comment

Representation ID: 28403

Received: 23/04/2025

Respondent: Gladman Developments

Gladman are generally supportive of the proposed policy on walking, wheeling, cycling and
public transport outside of the site but consider that flexibility should be applied and the
400m distance should be used as a guide and not used to restrict otherwise sustainable
development proposals.

Comment

Representation ID: 28404

Received: 23/04/2025

Respondent: Gladman Developments

Gladman are generally supportive of the proposed approach to walking, wheeling, cycling
and public transport within the site, with many of the requirements generally
considerations of good place making and developments that Gladman bring forward.

We have brought forward mobility hubs, incorporating car clubs and car sharing alongside
bike hire successfully on a number of development projects and are willing to consider it on
projects we are promoting through the Local Plan.

Comment

Representation ID: 28405

Received: 23/04/2025

Respondent: Gladman Developments

Gladman would suggest that a number of elements of this policy would be considered as
good place making and what we strive for on each of our developments. There is no one
size fits all approach and this flexibility should be recognised when considering
development proposals.

Comment

Representation ID: 28406

Received: 23/04/2025

Respondent: Gladman Developments

Recognising the significant constraints that affect the district, 83% of the district is within
the High Weald National Landscape (NL), historic constraints and environmental
designations whilst planning for housing development is complex, the spatial strategy
essentially determines itself.

The draft Local Plan states that this is a landscape-led spatial strategy that will deliver
between 258 to 364 dwelling per annum (dpa) over the plan period. This is between 369 and
475 homes each year below what the minimum required by the standard method. The
failure to meet needs in full also means that affordable housing delivery will be substantially
below what is needed.

As a main transport and community hub in the district, significant housing delivery in Bexhill
will be essential in providing for a successful spatial strategy. North and West of Bexhill are
the most sustainable locations in the district and significant housing should be allocated to
the town on sites capable of delivering housing, whilst balancing the recognised constraints
of the district. It is essential that sites allocated are maximised to ensure that the most
effective use of land is utilised.

Gladman consider it essential to recognise the significant impact that not meeting housing
needs will have on its population and starts to take a more positive approach to meeting
housing needs. Whilst we recognise that there are a range of constraints in the district the
NPPF is clear in Paragraph 11 that these must provide strong reasons for restricting growth
and as part of these considerations the Council must also take full account of the social and
economic impacts of not meeting needs, not just the potential harms.

It will also be vital that the council seeks to maximise development on each site it does
allocate give the significant shortfall between housing needs and supply. The Council should
look to ensure that all land within submitted sites that are considered suitable for
development are allocated for development. In allocating sites, the Council should be
mindful that to maximize housing supply the widest possible range of sites, by size and
market location are required so that house builders of all types and sizes have access to
suitable land in order to offer the widest possible range of products. The key to increased
housing supply is the number of sales outlets.

The maximum delivery is achieved not just because there are more sales outlets but
because the widest possible range of products and locations are available to meet the
widest possible range of demand. In summary a wider variety of sites in the widest possible
range of locations ensures all types of house builder have access to suitable land which in
turn increases housing delivery.

Gladman support the important role that Bexhill plays in the spatial strategy for the district
and are promoting a series of development interests in this area that could contribute to
the timely delivery of housing within the plan period.