Rother Local Plan 2020-2040 (Regulation 18)

The principles of Live Well Locally as set as the Overall Priority 2 are supported by our client and through their proposals. The priority to ensure that rural communities are able to live in connected and compact neighbourhoods is one of the key elements for our client’s proposed development. The two sites mentioned are adjacent to the development boundary set out in the Ticehurst Neighbourhood Plan (Policy H1) and are roughly 1km from the Centre of Ticehurst meaning it would take 13 minutes to walk or 4 minutes to cycle into Ticehurst Village Centre.
Furthermore, there are bus stops on Lower Platts (180m away) which would connect residents onto the many bus services between Hawkhurst, Hastings and Flimwell.
The proximity of the sites to the village ensures that there is sustainable and inclusive access to the facilities of the village and will help inspire a sense of belonging whilst also reducing the high reliance on the use of private cars by its sustainable location and would help promote active travel.

The village of Ticehurst is also identified as a Moderately Sustainable settlement as set out in the Settlement Study Report. This shows that the settlement can accommodate new homes due to its high sustainability score. It will be able to accommodate new residents and provide many essential services to future residents.
Our clients’ sites both benefit from a local primary school in Steellands Rise in the immediate vicinity, the Ticehurst and Flimwell Church of England Primary School.

We agree with the principles of these policies, however, would highlight in the second criterion the need to focus on housing delivery.
Rother District Council has historic issues with the delivery of new housing, granted this is due to the many landscape designations primarily. The ambition of the new local plan should be to help boost the delivery of all forms of housing on an annual basis alongside meeting the local need.
The identified housing needs as set out in the HEDNA Update sets out that Rother needs 737 dwellings per annum, and this is “considerably higher than the currently adopted housing requirement policies”. The details set out in 2.13 should have a specific target for housing delivery to meet the identified housing needs as set out in the HEDNA. Rother currently only delivers 41% of its required housing and needs to deliver more in order to meet its needs.

Our client supports the general principles set out in the spatial objectives, particularly those which address the delivery of housing in rural locations. The ambition of delivering net zero carbon ambitions is also supported by the client.
The location of the two proposed sites within walking distance of a wide range of services and transport options are elements of the development which the proposed sites will be able to comply with.
As mentioned, the sites are in a settlement which has been identified as a moderately sustainable location and the fact the sites are located within 1km of the village centre offering a wide range of services within a suitable distance for active travel options.
The development of the sites will do everything possible to comply with the ambitions in terms of delivering net zero carbon, improving nature recovery, protecting the High Weald National Landscape, promoting high quality design, creating prosperity in rural areas, delivering growth in sustainable locations, enhancing sustainable connections and sustainable transport methods, supporting safe, healthy, vibrant and mixed communities, and deliver strategic planning opportunities.

The client considers the overarching objectives to be acceptable. However, we would suggest that a quantifiable housing target should be implemented within these objectives. As mentioned above, there is an identified housing need of 737 dwellings per annum and a history of underdelivering on housing. A target should specifically be included within the overarching strategic targets for the new local plan.

The principles and targets for delivering net zero standards set out in the draft policy are supported by the landowner/clients and they will strive to incorporate standards into the development of the sites where reasonable and appropriate, should the sites be allocated for development.

The landowner/clients is of the opinion that these standards are essential for the delivery of a net zero carbon world. They consider these to be very important.

The principles of the policy are supported by the client.

The general principles of the policy are in line with The Environment Act 2021. We do note however that the 30-year maintenance requirement is not embedded within the policy, and we believe that it should be as a matter of completeness. We will comment on the minimum requirement below.

The Environment Act mandates a 10% Biodiversity Net Gain for new developments, which must be maintained for at least 30 years. Since the policy exceeds this minimum there needs to be further justification as to why across the entire district exceeding the minimum is suitable.
As mentioned a number of times, Rother District Council is an area which is rural in character and has a significant area of the district within the High Weald National Landscape, alongside other landscape designations which reduce the overall development capacity.
Furthermore, the District has a historic lack of delivery of housing as evidenced by the most recent Housing Delivery Test Figures (41%). The introduction of a higher BNG requirement will contribute to a continued underdeliver. Granted the levels of off-site opportunities are significant in Rother, in comparison to other parts of the country, but this has been exclusively set out as a last resort by Natural England.
Developers, particularly with sites in more rural areas will most likely be hamstrung by this policy rather than urban areas. We agree with the significant role that the links between our natural environment to our economic growth play in delivering sustainable development, however when we consider that the evidence base does not exist, yet it is clearly premature to insist on the 20% uplift. This will severely limit the level of development in rural areas.

The client’s sites are located within the High Weald National Landscape. We agree with the overarching objective to ensure that new development should fit into the landscape and not harm the said landscape. We recognise that this has the highest status of protection, but it must be made clear that due to the historic lack of delivery of housing in the district, sites which can deliver housing in sustainable locations within the High Weald National Landscape should be supported, as long as they are sensitive to the objectives set out within the NPPF. There is a clear need for housing development and given the significant portion of Rother District Council being located within the High Weald National Landscape, that it is necessary for the council to support development within it.