Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27543

Received: 23/07/2024

Respondent: Southern Housing

It might be helpful to clarify that the Core Strategy and Development and Site Allocations documents will make up the current plan for Rother. For example, the second sentence could be amended as follows: “Once adopted, it will replace Rother’s current local plan as set out in the Core Strategy (2014) and Development and Site Allocations (2019) documents.”

Comment

Representation ID: 27545

Received: 23/07/2024

Respondent: Southern Housing

In the first section, we suggest additionally referring to business. Although “work” is mentioned, we believe the Local Plan should explicitly state Rother encourages business to attract investment into the District. The third section references close working with Parish and Town Councils. Given the previous section regarding collaborative working with Hastings Borough Council, we believe it would also be beneficial to reference joint working with these smaller councils. This doesn’t necessarily need to happen within the third section, but could instead be in the supporting text at paragraphs 2.1-2.3). This should help ensure Rother continually works with Hastings and other neighbouring authorities to deliver the objectives of the plan. Reference to working with East Sussex County Council (ESCC) may also be beneficial, especially given the traffic issues within coastal areas of the District and the level of services which ESCC provides.

Comment

Representation ID: 27546

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of the twin objectives as they’re supported by a robust evidence base (the Rother Climate Change Study (2023) prepared by Arup).

Comment

Representation ID: 27547

Received: 23/07/2024

Respondent: Southern Housing

As per our response to Q2, whilst the issues appear to be consistent with the priorities, the Plan should demonstrate they’re based on robust local evidence. At present, the key issues appear somewhat generic. We suggest reviewing them alongside the relevant evidence and adapting as required to ensure they’re locally specific. References to the evidence base should also be made within this section.

Comment

Representation ID: 27548

Received: 23/07/2024

Respondent: Southern Housing

We support the spatial objectives in principle. Where the objectives relate to transport-related matters, the Plan should specifically reference working with East Sussex County Council. We note this has been included for Spatial Objective 9 (safe, healthy, vibrant and mixed communities) and there are also references to working with Hastings Borough Council.

Comment

Representation ID: 27549

Received: 23/07/2024

Respondent: Southern Housing

Depending on the evidence available, RDC could consider adding a separate objective for tourism or sustainable tourism. We note the Plan mentions tourism within Spatial Objective 3. However, given the issues identified later regarding the lack of jobs in rural areas etc… and the proximity and connection to Hastings, a separate objective might be beneficial to help encourage tourism in a sustainable way.

Comment

Representation ID: 27550

Received: 23/07/2024

Respondent: Southern Housing

It’s positive to see RDC have included the Total Energy Use Intensity (TEUI) target as this is more robust than other methods. We believe the Council should consider making stronger links between the Green to the Core section and Live Well Locally section. The policies within each are complementary and should be considered alongside one another. For example, LWL3 and LWL4, which deal with transport and, amongst other requirements, encourage sustainable patterns of development to reduce reliance on the private car and the provision of electric vehicle charging points and other infrastructure. This is in line with recommendations in the Rother Climate Change Study (2023), which identifies the transport sector as having “huge potential for decarbonisation” (paragraph 10.1.4). Cross references between the two sections would, therefore, help make these connections explicit and ensure new developments consider climate change more holistically.

Comment

Representation ID: 27551

Received: 23/07/2024

Respondent: Southern Housing

We support the targets on the basis they are based on evidence in the Rother Climate Change Study (2023). However, although the study references viability, it appears the overall viability of delivering some of these targets may not have been tested vigorously. It is important to ensure the policy remains deliverable for the plan period to be found sound. RDC should also consider bolstering the evidence base to ensure the approach is correct for Rother. Central Lincolnshire has recently adopted a net zero carbon policy which was based on evidence prepared by a team of consultants (Bioregional, Etude, Mode Transport Planning, RSK and Currie & Brown). This is important to ensure the impacts on development, including housing delivery, are tested in full.

Comment

Representation ID: 27552

Received: 23/07/2024

Respondent: Southern Housing

We note paragraph 3.21 of the supporting text references LETI’s Climate Emergency Retrofit Guide, which targets energy consumption reductions of 60-80% for the average home. While we acknowledge this, many of the types of works associated with retrofitting can be completed under permitted development. Some large-scale residential conversions involving retrofit can also be completed under permitted development (e.g. Class MA - commercial, business and service uses to residential) where energy efficiency and climate change are not considerations. In addition, where similar works do require planning permission, the permitted development alternative may be a material consideration (fallback) when determining the application. It may, therefore, be beneficial to explain more about what types of development the policy is aimed at (e.g. non permitted development conversions) and how the fallback position of permitted development will be considered.

Comment

Representation ID: 27553

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy. We believe RDC should also consider referencing Construction Environmental Management Plans (CEMPs), which are often required for large-scale schemes. CEMPs will cover a wide range of matters at the construction stage, including material sourcing and storage and sorting of waste at the site. If not included here, a cross reference could be made to LWL3 (see also the responses to Q33).