Rother Local Plan 2020-2040 (Regulation 18)
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Rother Local Plan 2020-2040 (Regulation 18)
70. What are your views on the potential sites identified in the draft HELAA that could accommodate more growth in Northern Rother?
Representation ID: 26000
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The views are that the district is in desperate need of housing across its entirety due to the historic under delivery of housing over the course of many years. This has contributed in turn to greater levels of unaffordability in the district and the provision of more housing could directly address this topic.
The sites for which these representations relate are in a highly sustainable settlement and are in a highly sustainable location and hope to be delivered by people with a proven track record of delivering much needed housing in the National Landscape and in the village itself. We appreciate that the National Landscape will need to be protected as it should. However, through careful landscape led design, we believe that these sites can deliver much needed housing in a northern rural settlement.
The views are that the district is in desperate need of housing across its entirety due to the historic under delivery of housing over the course of many years. This has contributed in turn to greater levels of unaffordability in the district and the provision of more housing could directly address this topic.
The sites for which these representations relate are in a highly sustainable settlement and are in a highly sustainable location and hope to be delivered by people with a proven track record of delivering much needed housing in the National Landscape and in the village itself. We appreciate that the National Landscape will need to be protected as it should. However, through careful landscape led design, we believe that these sites can deliver much needed housing in a northern rural settlement.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
82. What are your views on the Council's approach to development boundaries?
Representation ID: 26001
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
We believe the Local Authority should update settlement boundaries in the new local plan to include future sustainable allocations. The current policy gives the Authority significant discretion, despite many sustainable sites promoted through the Call for Sites process that meet 20-minute neighbourhood principles. Greater clarity is needed on the "locally agreed need" test for small-scale development, as the housing requirement for all parishes is not specified. The policy indicates development boundaries define areas within sustainable settlements where development is permitted, with development outside these boundaries being unacceptable. New boundaries, as seen in Playden, should also be established in Ticehurst to accommodate sustainable development. This would reduce ambiguity for developers and residents.
We believe that the Local Authority should as part of the new local plan process deliver a set of updated settlement boundaries which will include future sustainable allocations being included in the boundaries. We believe that the policy wording allows a significant amount of discretion to the local authority which has a number of sustainable sites which have been promoted through the Call for Sites process which meet the 20-minute neighbourhood principles and can deliver high quality housing in the plan period.
In respect of small-scale development, there is a need for greater clarity on the test for ‘locally agreed need’. The documents do not set a housing requirement for all parishes in the district, so there must be another method of considering local need in these other parishes.
Furthermore, there is no suggestion the wording of the policy sets out that “Development boundaries form policy lines and they do not necessarily represent the exact edge of settlements as such” . The policy clearly seeks that “the development boundaries to define the area within sustainable settlements where development is permitted”. This would set the policy position that development outside these boundaries would be unacceptable.
We have seen that new development boundaries have been made in Playden through the Regulation 18 process and we believe that the provision of an amended boundary in Ticehurst to accommodate development that is considered to be sustainable development by the Local Authority. This removes ambiguity for developers and residents alike.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
114. What are your views on the Council's proposed policy on mixed and balanced communities?
Representation ID: 26002
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The proposed policy wording and mix of housing is considered to be justified. The proposed mix seems to comply with the findings of the HEDNA and is something that the client would try to comply with. We would recommend that the policy should make a provision for cases where this is unable to be complied with that this would only be acceptable subject to viability.
The proposed policy wording and mix of housing is considered to be justified. The proposed mix seems to comply with the findings of the HEDNA and is something that the client would try to comply with. We would recommend that the policy should make a provision for cases where this is unable to be complied with that this would only be acceptable subject to viability.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
116. What are your views on the Council's proposed policy on affordable housing?
Representation ID: 26003
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The key issue with the proposed policy is that there is no percentage of affordable housing provided as part of the policy. The client accepts the principle of such policy, subject to viability, but cannot adhere to the policy wording as it stands in the absence of a percentage. Only once a percentage is included in the policy can there be a proper assessment of the policy wording.
The key issue with the proposed policy is that there is no percentage of affordable housing provided as part of the policy. The client accepts the principle of such policy, subject to viability, but cannot adhere to the policy wording as it stands in the absence of a percentage. Only once a percentage is included in the policy can there be a proper assessment of the policy wording.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
137. What are your views on the Council's proposed policy on Self-Build and Custom Housebuilding?
Representation ID: 26004
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The clients are supportive of policies aimed at boosting rates of delivery of self and custom build plots. However, the selected approach should go further. The policy suggests 5% self / custom build plots on sites larger than 20 homes, but this would not apply to allocations which are rolled forward. In the latter case, the policies for those allocations similar says “make provision for a portion of self-build” which is lacking in clarity and imprecise.
The Council is subject to a legal duty (as set out in the Self Build and Custom Housebuilding Act 2015) to grant planning permissions to meet identified need for self and custom build housing, as evidenced by the registers.
The clients are supportive of policies aimed at boosting rates of delivery of self and custom build plots. However, the selected approach should go further. The policy suggests 5% self / custom build plots on sites larger than 20 homes, but this would not apply to allocations which are rolled forward. In the latter case, the policies for those allocations similar says “make provision for a portion of self-build” which is lacking in clarity and imprecise.
The Council is subject to a legal duty (as set out in the Self Build and Custom Housebuilding Act 2015) to grant planning permissions to meet identified need for self and custom build housing, as evidenced by the registers.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
2. What are your views on proposed twin Overall Priorities to be 'Green to the Core' and 'Live Well Locally'?
Representation ID: 27274
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
Objective 2- Live Well Locally
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.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?
Representation ID: 27275
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
We overarchingly 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 had 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 Rother and Hastings 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 identified needs.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
4. What are your views on the Council's objectives for the Local Plan?
Representation ID: 27276
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
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.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
5. Are there any alternatives or additional objectives and/or the ways to achieve the objectives the Council should be considering?
Representation ID: 27277
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
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.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
6. What are your views on the Council's proposed policy for net zero standards and which parts of the policy do you support?
Representation ID: 27278
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
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.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
