Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 26816

Received: 31/07/2024

Respondent: Northern Parishes Group

Housing allocations pages 157-161 and 175 and HELAA Part 2 Chapter 5 page 11-21
39) The group anticipates that this is the section that the authors had the most difficulty with. It is certainly the area that the group found taxing. The group would prefer a different system for allocation, but that is not an option. The group worked with the current system, although what will happen to the system is hard to predict.
40) The group's basic position is they ‘want the right houses in the right places.’ This is what the group told central government in one of their consultation exercises, and were rather surprised when the government adopted the phrase as their policy.
41) The need for new housing is clear. The fact that 84% of Rother district is in the High Weald National Landscape and 92% of the district has some protection or other, makes grave difficulties for the authors. Much of the 8% of the district is already built on. Under the new definition of sustainability, finding sites becomes even more difficult. Everyone should give mental well-being a high priority but putting urban people in an isolated position in the countryside often goes wrong. The group's ultimate position was that what is needed is a good balancing exercise of all the factors.
42) An additional problem with this is that with the cost of housing, new houses bring in an influx of people from elsewhere wanting the village life and not providing affordable houses for local people. The way to deal with that was considered to be Exception sites and the use of affordable homes.

Comment

Representation ID: 26818

Received: 31/07/2024

Respondent: Northern Parishes Group

48) The group particularly welcomes the sentence at part ii).

Comment

Representation ID: 26819

Received: 31/07/2024

Respondent: Northern Parishes Group

49) It is noted that this policy is in conflict with itself and the authors are invited to consider carefully whether the policy adds anything at all. It is perhaps likely to confuse and there are clear advantages to planning applications in stages for some sites. It is suggested that this policy will be ignored and the planners at Rother are in a good position to make the decisions on a case by case basis. The authors are suggested to consider whether this whole policy is better deleted.

Comment

Representation ID: 26820

Received: 31/07/2024

Respondent: Northern Parishes Group

50) The problem with this policy is that the various sentences contain principles that should be separated out. It therefore lacks clarity. An alternative wording would be as follows.
‘Areas within the development boundaries are where the principle of development is accepted. Areas outside the development is where the principle of development is presumed not acceptable.
Development in both areas, must be consistent with national and local planning rules. Planning decisions will be made after a careful evaluation of all the factors giving proper weight to each one.’

Comment

Representation ID: 26821

Received: 31/07/2024

Respondent: Northern Parishes Group

Infilling, redevelopment and change of use page 185 para 5.116
51) Para 5.116 of the Draft Local Plan reads as follows.

52) The suggestion that there is a presumption that infilling, redevelopment and changes of use will be acceptable subject to other policies of the Local Plan, creates considerable problems and goes further than appropriate. It would be far better to have no presumptions and allow the specific facts of the individual application to be determined under normal principles.
53) Making change of use acceptable within a development boundary cuts across very strong public policy. This would mean anybody could turn anything into a group of flats. If there is only one pub in a large settlement, it should not be removed simply because the landlord could make more money by selling it to a developer. Also Rother District Council and the Inspectorate have been careful about preserving village hospitality and employment places. To discard that would be wrong.
54) A similar problem arises in relation to infilling being generally acceptable. Planning inspectors have pointed out that on occasions when there is a continuous line of housing, a gap creates a feeling of well-being.
55) The group points out paragraphs 5.114- 5.118 are in part in conflict with the overall policy and are in conflict with each other. This means they lack clarity and consistency. Many of the policies referred to are best dealt with in the lead policy for that area. The paragraphs generally weaken this Local Plan. The plan would be better if they're all removed.

56) The Core strategy instructs developers and plans to avoid ribbon development.

(ii)-(v) Not listed.

(vii)-(viii) Not listed.
57) The draft local plan has no similar instruction.
58) There is however instruction for infilling. At page 185 para 5.116 of the Draft Local Plan which says the follows.

59) There is a clear distinction between ribbon development and infilling. Around a village core infilling is not only acceptable, it is often desirable. On roads leaving out of the settlement, filling in the gaps between houses is ribbon development, because the development is outside the settlement. Ribbon development has traditionally been unacceptable, because it blights the countryside and stretches the provision of services, like sewage disposal and electricity supply.
60) The group suggests the proposed policy DEV 3 should be widened to include restrictions for ribbon development.

Comment

Representation ID: 26822

Received: 31/07/2024

Respondent: Northern Parishes Group

61) There then follows five examples of green gaps.
62) In para i) ‘between’ should read ‘of’. The overall problem of this policy is that it doesn't make clear what makes a green gap. There are hundreds of settlements within the Rother district but it is only in a few cases that the green gap principle applies. Adding the words ‘strategic’ only confuses the matter. An alternative wording would be as follows.
‘Rother District Council will protect green gaps between settlements where development in adjoining settlements threatens to damage or remove in part the boundary between the settlements.
The policy seeks to:
• Protect the separate identity of settlements.
• Prevent the amalgamation of settlements.
• Contribute to well-being.’
63) It is suggested it is wrong in principle for examples to be in a policy. Examples should be in the text. It is suggested that the Burwash Weald and Burwash green gap, the Flimwell and Ticehurst green gap, and the Etchingham and Hurst Green green gap should be included in the examples.

Comment

Representation ID: 26823

Received: 31/07/2024

Respondent: Northern Parishes Group

65) The group welcomes this new policy and considers it is well drafted. The group reminds the authors, that rural mental health and poor physical health is frequently overlooked. This is because it is often hidden and because rural poverty is also hidden. Further there is often a distinct lack of facilities and understanding of the problem in rural areas.

Comment

Representation ID: 26824

Received: 31/07/2024

Respondent: Northern Parishes Group

66) It is suggested that this policy would be improved if instead of ‘Health’, there was substituted ‘Physical and Mental Health’. As the cost of these assessments will not fall on the local council and because the figures are too high, it is suggested 100 dwellings should read 50 dwellings, 2,000 square metres should read 1,000 square metres and five hectares should read 3 hectares. There needs to be an ‘or’ at the end of para i). That should also be a requirement for pre-application consultation when this policy applies.

Comment

Representation ID: 26825

Received: 31/07/2024

Respondent: Northern Parishes Group

67) The problem with this policy is that it is unlikely to be referred to because all it does is state the obvious and principles that are dealt with in other places. However, it does have one additional problem. It is not being followed by the planners for good reason. In the first paragraph of (A) it says the planning for developments will be refused where the infrastructure is not present. Currently, if there are insufficient doctors, school places and sewage capacity, planning permission is still granted. This is on the principle while the development is being built the local NHS Trust, East Sussex County Council and Southern Water will be invited to provide the capacity. If this policy was not in place, large developments would never be given planning permission, because the three bodies listed above would not provide the capacity until permission was granted.
68) The office are invited to conclude that INF1 policy is unnecessary, wrong in principle and adds nothing of significance.

Comment

Representation ID: 26826

Received: 31/07/2024

Respondent: Northern Parishes Group

69) This new policy is most welcome.