Rother Local Plan 2020-2040 (Regulation 18)

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Comment

Rother Local Plan 2020-2040 (Regulation 18)

49. Are there any alternatives or additional points the Council should be considering?

Representation ID: 25097

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

To ensure the successful adoption of EVs, it is imperative that the plan includes detailed provisions for EV charging infrastructure in both urban and rural settings.

Full text:

While these questions (48, 49, 50) address new car parking requirements, they fail to consider the necessity of EV charging facilities. This omission is significant as access to commercial rapid charging sites often involves travelling considerable distances. Also, the differential VAT rate is considerable and affects those without home charging units.

Additionally, on-street parking presents challenges for EV charging and is not addressed. It is crucial that new housing developments include on-street charging points to facilitate the transition to electric vehicles.

On-street parking is a necessary requirement in some rural villages such as Rushlake Green, Dallington and Brightling. However, there is no suggestion as to how these locations should manage on-street EV charging.

Although electric charging is mentioned in LWL3 in the context of cycling, and zero-emission vehicles are referenced in 4.31 xiii, there is no detailed explanation regarding the ‘integrated provision of infrastructure’. Furthermore, while LWL6 4.53 anticipates the need for EV charging in relation to solar power generation from roof-mounted solar panels, it does not provide a comprehensive plan for EV charging infrastructure across all areas.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

5.92

Representation ID: 25098

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

The supporting evidence notwithstanding, the requirement for so many new pitches is still questioned. However, with any new provision, strong preference should given to publicly owned sites - and only in sustainable locations. Such sites should be principally for the use of members of the travelling community. The establishment of private sites should be subject to the same rigorous prior planning procedures as any other settlement/building.

Full text:

The supporting evidence notwithstanding, the requirement for so many new pitches is still questioned. However, with any new provision, strong preference should given to publicly owned sites - and only in sustainable locations. Such sites should be principally for the use of members of the travelling community. The establishment of private sites should be subject to the same rigorous prior planning procedures as any other settlement/building.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

8.51

Representation ID: 25099

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

We oppose this change. "Meaningful community engagement" is classic weasel wording. The community might be bitterly opposed to the proposed development but as long as the developers have had a few presentations etc explaining the proposals, they would be deemed to have "engaged".

This is dangerous. The groups and individuals can be lobbyists for the developers, whereas the Parish Council is an elected body whose views have democratic credentials.

Former policy DHG2 should be retained. The only possible change would be that if a village / parish does not have a Parish Council, then local support could be demonstrated by other means (but this should refer to support, not just "engagement".
"Viability evidence" has been widely abused by developers and the council does not have the resources to challenge and check viability claims. Rural exception sites should be 100% affordable without exception.

Full text:

We oppose this change. "Meaningful community engagement" is classic weasel wording. The community might be bitterly opposed to the proposed development but as long as the developers have had a few presentations etc explaining the proposals, they would be deemed to have "engaged".

This is dangerous. The groups and individuals can be lobbyists for the developers, whereas the Parish Council is an elected body whose views have democratic credentials.

Former policy DHG2 should be retained. The only possible change would be that if a village / parish does not have a Parish Council, then local support could be demonstrated by other means (but this should refer to support, not just "engagement".
"Viability evidence" has been widely abused by developers and the council does not have the resources to challenge and check viability claims. Rural exception sites should be 100% affordable without exception.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

8.167

Representation ID: 25100

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

The recent popularity of timber framed extensions - kitchens/garden rooms etc - have often incorporated large expanses of glass. Whilst the timber design/construction may be sympathetic to an overall scheme, the modern glass is not. Apart from glare, it is contrary to dark skies policies.

Full text:

The recent popularity of timber framed extensions - kitchens/garden rooms etc - have often incorporated large expanses of glass. Whilst the timber design/construction may be sympathetic to an overall scheme, the modern glass is not. Apart from glare, it is contrary to dark skies policies.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

Proposed Policy ECO10: Equestrian Developments

Representation ID: 25101

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

We welcome the introduction of a policy on Equestrian Developments since these can present a real threat to the HW National Landscape.

Full text:

Individual applications may not cause major damage to the HWNL but the cumulative effect can be considerable and this should be reflected in policy. However, the proposed policy needs a number of changes. The broad principle should be that an equestrian development within the HWNL should generally be given planning permission (if it complies with other policies) provided that it is close to a dwelling house, to be used as part of the domestic amenities of that house (ie not let out as a business). Within the HWNL, equestrian developments should not be given planning permission if they are an isolated development not close to a dwelling house. (Existing equestrian businesses should be allowed to expand, provided that there is a proper business case and the development is acceptable on other planning grounds). Rationale: equestrian developments do not contribute to the supply of housing, nor to the economic development of the district. They rarely provide employment and where they are purely for private enjoyment they cannot justify any damage to the HWNL.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

9.91

Representation ID: 25102

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

The word "Ideally" gives a huge loophole. The word "Ideally" should be deleted. If that is not possible, then there should be some words such as "Except in rare circumstances…"

Full text:

The word "Ideally" gives a huge loophole. The word "Ideally" should be deleted. If that is not possible, then there should be some words such as "Except in rare circumstances…"

Comment

Rother Local Plan 2020-2040 (Regulation 18)

9.91

Representation ID: 25103

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

The word "Ideally" gives a huge loophole. The word "Ideally" should be deleted. If that is not possible, then there should be some words such as "Except in rare circumstances…"

The second sentence of section 9.91 is another potential loophole. In fact, mobile shelters can have much the same impact as permanent . Mobile shelters are often designed on skids so that they can in theory be dragged by tractor into a new position but people often don't bother, and this would be a hard thing to enforce through enforcement.

Full text:

The word "Ideally" gives a huge loophole. The word "Ideally" should be deleted. If that is not possible, then there should be some words such as "Except in rare circumstances…"

The second sentence of section 9.91 is another potential loophole. In fact, mobile shelters can have much the same impact as permanent . Mobile shelters are often designed on skids so that they can in theory be dragged by tractor into a new position but people often don't bother, and this would be a hard thing to enforce through enforcement.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

9.94

Representation ID: 25104

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

Section 9.94 has the right idea, but the wording is too weak. It is too easy for someone to say "my horses are fed hay so they don't need a hectare each". Perhaps one way of tackling this would be to require that if someone wants to provide for a greater density than one horse per hectare, that they have to present a land management plan as part of their application to justify the higher density.

Full text:

Section 9.94 has the right idea, but the wording is too weak. It is too easy for someone to say "my horses are fed hay so they don't need a hectare each". Perhaps one way of tackling this would be to require that if someone wants to provide for a greater density than one horse per hectare, that they have to present a land management plan as part of their application to justify the higher density.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

9.92

Representation ID: 25105

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

This is too weak. The policy should state that equestrian developments in remote and isolated locations and not next to a dwelling house will generally not be acceptable within the National Landscape area.

Full text:

This is too weak. The policy should state that equestrian developments in remote and isolated locations and not next to a dwelling house will generally not be acceptable within the National Landscape area.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

9.93

Representation ID: 25106

Received: 09/07/2024

Respondent: Brightling Parish Council

Representation Summary:

This is too weak. The policy should state that equestrian developments in remote and isolated locations and not next to a dwelling house will generally not be acceptable within the National Landscape area.

Full text:

This is too weak. The policy should state that equestrian developments in remote and isolated locations and not next to a dwelling house will generally not be acceptable within the National Landscape area.

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