Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 26839

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates fully supports the Council's aspirations to enhance the green credentials of development. We also, as a company, support the principle of net zero ready housing development as well as aspirations to decarbonise development. However, as the Council has recognised, the recent WMS has set out that local plans should not go beyond the highly aspirational national standards unless there are exceptional local circumstances and viability has been considered. We note that there are numerous competing elements to viability including matters such as affordable housing and BNG. We note that delivering development within Rother has been challenging with developments such as Blackfriars stalling for a significant amount of time and unable to deliver a high percentage of affordable housing. Given the significant need for affordable and older people accommodation in Rother, there needs to be a balance struck between the green requirements and the ability to deliver sufficient housing at affordable levels. As such, we recommend that this policy is simplified to set out that the Government targets will be required. We also accept that there should be an aspiration to exceed such standards either in specific locations and / or specific developments where viability has been demonstrated that these standards can be met.

Comment

Representation ID: 26840

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates recognises that England is one of the most biodiversity depleted countries in the world and that step-change is required in order to reverse the decline. The Government's 10% increase in BNG, imposed through the Environment Act, will ensure that development sites will enhance biodiversity post their completion and ensure that this enhancement is managed. The Council seeks to double this requirement to 20%. We consider this approach to be unnecessary and unsound. Firstly, the Council has not assessed the viability of this approach. As noted in our response elsewhere, viability is already extremely challenging in Rother and further burden on the development industry will only lead to less development coming forward. Secondly there is no evidence that there is a specific need in Rother to enhance biodiversity by this level. As such, it is our view that the 10% minimum should be enshrined in the Local Plan. However, we accept that the Plan should be looking to go beyond this 10% and we suggest that the 10% is set out as a minimum figure with the Plan making it clear that it is envisaged that where possible and viable that this would be exceeded.

Comment

Representation ID: 26841

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates support the Council's preferred spatial development option and consider that it is sound. It is important that the Council seeks to enable the delivery of the highest number of homes possible within the constraints that are set out. It is recognised that there are significant constraints that may limit the number of homes that can be delivered, but as the Council sets out, no stone should be left unturned in terms of seeking to delivered the quantum of housing required. As such, we recognise that no one option can deliver this housing and an amalgamation of options, as set out, is most suitable.

Sustainability is a central plank to the overall strategy and as such, concentrating development on brownfield sites and the most sustainable settlements is an appropriate spatial strategy. Wates notes that Battle is one of the most sustainable locations in the District with a range of services as well as good public transport connections. As such, continued development at Battle will contribute to the 20-minute neighbourhood notion. Clearly, any development would have to be located appropriately and limit the effects on the AONB whilst seeking wider improvements.

Comment

Representation ID: 26842

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates has noted that the Council should be seeking to maximise the number of homes that the Plan facilitates the delivery of, and, as such, allocate as many sites as possible in order to meet this need. In doing so, the Council has to be realistic in its assumptions, but also consider the effects of infrastructure delivery and the delays that this may have (and has had historically) on delivery. As such, sites that have more limited infrastructure constraints should be prioritised, especially given the poor housing land supply position and the continued affordability challenges in the District.

Wates does not wish to comment on the overall numbers at this stage, however, does consider that the Council's assessment of sites capacities may be pessimistic. For example, Wates' site at Battle could accommodate more than the 100 units set out in the Council's evidence. We recognise that there needs to be a balance between opportunities and constraints, however, given the significant housing need, significant weight should be afforded to delivery of housing.

The latest affordability ratio for Rother, at 12.84 is lower than the 13.71 high at 2021, however, is still the highest in East Sussex and a significant increase over the past few years. This coupled with a a dire housing land supply position requires a significant uplift in housing delivery. The Local Plan sets out a minimum range of between 258 and 364 new homes per annum with the 258 based on no new allocations whilst the 364 figure includes potential sites (including Wates' site at Battle for 100 new homes).

This figure has to be compared with the Local Plan Core Strategy figure of 335 dwellings per annum. As such, a lower figure than 335 would not realise the required ambition for growth and would not support the required housing needs for the local community. It would also affect the ability to deliver affordable housing across the District. When looking at housing completions since 2011, delivery has been significantly below even the 335 figure at 219 homes per annum (albeit, there has been an improvement recently and larger sites are likely to start delivering soon.

As such, we would support the figure of at least 364 homes per annum but consider that a higher figure should be supported.

Comment

Representation ID: 26843

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates supports the vision for Battle especially "A greater amount of sensitive growth will take place south of North Trade
Road and west of Hastings Road with linked opportunities for habitat creation, restoration, enhancement and community access". Wates' site accords with the overall vision and can deliver sensitive growth in this location, enhancing local biodiversity and increasing community access. Development of the Wates site could lead to a greater number of homes than 100 whilst respecting the neighbouring habitat and enhancing it with significant buffers and tree planting proposed. In addition, the development would be sensitively located to reduce wider effects including on heritage assets. Furthermore, the site is not currently accessible to the wider public and development of the site will allow public access to a significant new area of open space as well as have potential to improve wider links.

In terms of the distribution of housing, we support the notion that the greatest number of homes should be delivered at Battle, but that some development could be accommodated in surrounding villages to ensure that they continue to be viable.

However, when considering the potential sites in Battle (one of which is Wates' site) additional housing could be accommodated without affecting the overall vision. As such, we would suggest that Battle is identified to accommodate at least 535 new homes over the plan period.

In terms of Figure 24, the Council should ensure that all these sites continue to be deliverable. Several of these sites have been allocated for some time and have not come forward which may be an indication of challenges in bringing the sites forward. Increasing the supply from the Wates site would allow for a buffer to be included to ensure that non-delivery elsewhere does not materially affect housing delivery.

Comment

Representation ID: 26844

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates supports the approach that identifies Battle as a location for greater opportunity for growth and that the settlement could accommodate more development than set out. In terms of the overall housing numbers, these do not meet the standard method figure and every effort should be done to close this gap. The Council should also look into the windfall figures as including windfalls from 23/24 is double counting with sites that already have planning permission. Generally, across the country windfalls only start counting from either year three or four, so there is likely to be a reduction in the overall supply.

Comment

Representation ID: 26845

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates do not support the notion of a stepped trajectory for three main reasons. Firstly, the majority of the sites are already identified as having permission and / or allocations and therefore can come forward early in the plan period. Secondly, allocations coming forward, such as the Wates site, are deliverable and can come forward in the first five years of the plan. Finally, there is significant housing need now and pushing delivery to the end of the plan period will not solve the really challenging housing conditions and deliver housing for people that need it now.

Comment

Representation ID: 26846

Received: 23/07/2024

Respondent: Wates Developments Ltd

Whilst we understand the Council's aspirations for comprehensive development there are many cases where land interests and timings do not align so that one party seeks to progress a planning application in advance of a separate party. As such, a requirement for comprehensive masterplanning cannot be enforced but should be set out as an aspiration. In addition, the requirement for a masterplan at the outline stage of an application which "must set the vision and implementation strategy for the entire site and propose parameters relating to the scale and layout of development, mix of uses, affordable housing, sustainable transport and access; green infrastructure (including sustainable drainage and biodiversity net gain) and other infrastructure (secured directly or through funding contributions)" goes well beyond national legislation on such matters and, in many cases, would not be able to be complied with. Furthermore, the requirement to comply with other policies is superfluous. As such,we would suggest the policy DEV2 is removed from the plan.

Comment

Representation ID: 26847

Received: 23/07/2024

Respondent: Wates Developments Ltd

Wates appreciate the need to provide balanced and mixed communities, however, does not agree that a prescriptive minimum percentage of 1 and 2-bed market units would be an appropriate policy. Whilst the overall need is for 30% 1 and 2 bed units, some sites will deliver a significant higher percentage of these, whilst other sites would not be suitable to accommodate such need. Indeed, given that this is market housing, it is for the market to determine the overall mix, rather than trying to influence market forces. The policy current drafted may lead to significant over-delivery of smaller units and may undermine the viability of schemes.

Comment

Representation ID: 26848

Received: 23/07/2024

Respondent: Wates Developments Ltd

Whilst Wates recognises the need for older people accommodation, it very strongly objects to a requirement to deliver at least 10% of housing on sites over 100 units. This approach is simply undeliverable and is not supported by the market (no developer will deliver and maintain only 10 units as part of a wider scheme). An approach to deliver care on larger site (over 500 units) has been accepted elsewhere and it is this scale of development that may accommodate alternative accommodation.