Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27289

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

We support the design principles set out in this policy. We also support the principles of ensuring that the High Weald Nation Landscape is protected.

In terms of the re-use of materials, this is generally acceptable in principle but clear design guides for rural villages within the High Weald National Landscape should be carried out.

Comment

Representation ID: 27290

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

We agree with the principles of the proposed policy, however we believe that the policy should be underwritten by the fact that the district has a history of failing to deliver on housing. The need for housing and the protection of the landscape should be given similar value in a planning assessment.

Comment

Representation ID: 27291

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

We fundamentally disagree with the approach that the council has set out to housing delivery. We appreciate that the final housing target is to be determined, however the council has provided clear evidence that the identified housing needs in Rother imply the construction of 737 new dwellings per annum over the plan period. This is “considerably higher that then currently adopted housing requirement policies” as identified in the HEDNA, yet the strategy wording sets up a target to reach a minimum average rate of 258-364 a year.

Even if the district was to adopt the higher end of the threshold, this would still be less than 50% of the homes needed in the district. Given the fact that Rother currently only delivers 41% of its required housing and needs to deliver more in order to meet its identified needs.

Though this sets out sensitive development in other rural settlements of the district will be included, it is considered that many villages, in particular Ticehurst has the capacity to accommodate further sensitively located housing given the services provided in the village. The landowner’s/clients sites will comply with the principles of the 20-minute neighbourhood, and this should be a consideration as part of the wider strategy.

Overarchingly, a more significant commitment is required to the delivery of housing in sustainable locations in rural villages which can accommodate development which are in line with the key objectives of the local authority.

Comment

Representation ID: 27292

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

Generally, our clients agree that sensitive and sustainable housing developments will help deliver the aims of the plan, however the proposed vision overarchingly suggests that no new development sites are required other than those already identified in the Ticehurst Neighbourhood Plan. This is considered unacceptable given the significant levels of lack of delivery of housing. They identify the clients two sites. TIC0043- Land at Cherry Tree Field, Lower Platts, Ticehurst and TIC0044- Land at Steellands Farm, Ticehurst, as potential additional growth. We believe that they are sustainably located and can be designed in a manner to minimise any impact on the National Landscape through sensitive design.

Comment

Representation ID: 27293

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

We believe that the suggested identified distribution lacks the overarching needs for the wider district. Sites for housing delivery where they are in a sustainable settlement in terms of services should be increased.

Robertsbridge seems to have a disproportionate number of homes allocated for a smaller settlement than Ticehurst.

We believe that a more sustainable way to deliver housing would be to even the spread of development across the northern villages.

Comment

Representation ID: 27294

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.

Comment

Representation ID: 27296

Received: 23/07/2024

Respondent: Trustees of Steellands Farm

Agent: Mr Geoff Megarity

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” (Paragraph 5.118). The policy clearly seeks that “the development boundaries to define the area within sustainable settlements where development is permitted” (Proposed Policy DEV3: Development Boundaries). 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 (Figure 38) 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

Representation ID: 27297

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.

Comment

Representation ID: 27298

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.

Comment

Representation ID: 27299

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.