Rother Local Plan 2020-2040 (Regulation 18)

Spatial objective 2 - We support this but it is not strong enough. As written, it sounds like support in a broad way but not in detail - but when it comes to the HW Landscape, the devil is often in the detail. There should be a specific requirement to comply with the specifications in the Design Guide.

Spatial objective 3 - It should be made clear that this objective applies to alterations and extensions to existing buildings etc equally as much as to completely new buildings (in a parish such as Brightling with no housing or employment growth planned, most development takes the form of alterations and extensions).

Spatial objective 4 - The term “net zero carbon ready” is used but this term does not appear to be defined. We fear this could be a loophole allowing developments that are not in fact zero carbon but which the developers claim could become net zero in the future. This could make the policy largely ineffective.

Spatial objective 9 - In a parish such as Brightling with no housing or employment growth planned, most development takes the form of alterations and extensions. There is a tendency, over a period of time, for the smaller houses to become larger houses, thus diminishing the availability of smaller houses. The vision of "mixed communities" (which we support) means that proposals to enlarge a residential dwelling may have to be refused, because of the damage to the social mix. This should be spelled out clearly.

We support the proposal to over-ride and not conform with the requirements of the Ministerial statement of 13/12/23. Furthermore, whether or not the Ministerial Statement is complied with, we suggest that building efficiency requirements are spelled out in planning conditions, and not rely on building regulations to enforce any efficiency requirements. Experience shows that enforcement through building regs alone is not always effective particularly in the case of alterations and extensions.

A Rother accreditation scheme for local suppliers with ongoing monitoring would be very worthwhile.

A distinction should be made between commercial and domestic solar panel installations. Ground-mounted solar should be generally supported for domestic installations where a roof-mounted solution is not practicable (either because the building is listed or the roof is unsuitable). "Domestic" installations could be defined as up to 60 sq m of panels, which will be plenty for a domestic property but far too small for a commercial operator. (It is worth noting that newer "all-black" panels have significantly less landscape impact than the previous generation, which were more reflective).

Planning approvals often include a phrase such as "No development shall take place until there has been submitted to and approved by the Local Planning Authority details of the colour, type and make of the roofing tiles, and the development shall be carried out using the approved materials". Despite this, we are aware of many occasions where such a condition is imposed but the building ends up with materials that clearly conflict with the High Weald Design Guide. For example the High Weald Design Guide requires "small-module clay tiles with natural camber", but we see buildings with dead-flat (ie no camber) tiles. The council needs to find a new process to ensure that the building as built actually does comply with the HW Design Guide. Possibly this could be done by a planning condition that specifically references the appropriate detail within the Design Guide.

It has sometimes been the case re: work to listed buildings that samples of building materials are required for approval by planning officers. This should routinely be the case. Planning officers frequently demonstrate a lack of understanding when it comes to the importance of sympathetic construction materials and should work more closely with the High Weald AONB Team. Retrospective checks should also take place.

Encouragement of inter-generational living by relaxing of planning rules to allow conversion of ancillary buildings/extensions particularly in rural areas would enable care of both very young and elderly with huge benefits and savings. Both generations would be able to stay in the community in which they feel they belong; rural/affordable housing problems would be eased; a greater mix of community would be achieved. The present policy of permitting conversion for holiday lets with the aim of promoting the tourist economy should be secondary to allowing the same properties to be converted for extended family use which will enable rural economies, schools and communities to thrive. Such properties could be subject to restrictions meaning ancillary accommodation cannot be sold off separately.

The ubiquitous use of UPVC windows/doors should be heavily discouraged in favour of timber and other more environmentally friendly materials.

Tighter control should be exercised over the disposal/dumping of hardcore and waste. Presently, licenses are easy to acquire with no follow up checks as to the amount or siting of waste, nor the inconvenience relating to noise of dumping/earth moving, HGV access and damage to rural roads. This is frequently a problem in rural areas where farmers are happy to accept waste for a fee.

There does not appear to be specific reference to heat pumps in the document. Use of heat pumps in new, more compact developments covered in LW1 must consider both noise and visual impact.

In this section there is a lack of clear alignment with government policy regarding the transition to electric vehicles (EVs) and other zero emission vehicles and no mention of charging infrastructure.