Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27644

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy in principle.

With regard to criteria (vi), we consider the draft wording to be complicated and that it may be difficult to apply when determining planning applications. As drafted, it appears the policy would allow for two houses on the edge of a settlement but then no further additions. While we note the intention, it has the potential to lead to ribbon development along main routes into villages and coalescence of settlements. Once the new houses have been built, it may be difficult to resist further developments, particularly at the end of the plan period as policies become weaker and/or if the exact same approach isn’t continued in future local plans.

The definition of frontages is also open to interpretation and may make it difficult to resist back land schemes within the rural settlements. We note paragraph 5.118 states that: “While development boundaries will normally follow physical boundaries, on occasion, the full depth of property curtilages may be excluded to make clear a policy statement that back land or in-depth development is unacceptable, often because of its additional visual or amenity impact.” There may therefore be situations where the curtilage of a property is excluded from the development boundary, but the dwelling itself is within the settlement boundary. Depending on the layout and pattern of the surrounding settlement, draft Policy HOU13 may make provision for developing the curtilage of this property. This is therefore in conflict with the approach set out at paragraph 5.118 (please see also our response to Q82). We suggest amending the wording to refer to “in-fill” developments on sites which front the public highway and follow the pattern of development found in the locality.

Comment

Representation ID: 27645

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy in principle.

With regard to criteria (vi), we consider the draft wording to be complicated and that it may be difficult to apply when determining planning applications. As drafted, it appears the policy would allow for two houses on the edge of a settlement but then no further additions. While we note the intention, it has the potential to lead to ribbon development along main routes into villages and coalescence of settlements. Once the new houses have been built, it may be difficult to resist further developments, particularly at the end of the plan period as policies become weaker and/or if the exact same approach isn’t continued in future local plans.

The definition of frontages is also open to interpretation and may make it difficult to resist back land schemes within the rural settlements. We note paragraph 5.118 states that: “While development boundaries will normally follow physical boundaries, on occasion, the full depth of property curtilages may be excluded to make clear a policy statement that back land or in-depth development is unacceptable, often because of its additional visual or amenity impact.” There may therefore be situations where the curtilage of a property is excluded from the development boundary, but the dwelling itself is within the settlement boundary. Depending on the layout and pattern of the surrounding settlement, draft Policy HOU13 may make provision for developing the curtilage of this property. This is therefore in conflict with the approach set out at paragraph 5.118 (please see also our response to Q82). We suggest amending the wording to refer to “in-fill” developments on sites which front the public highway and follow the pattern of development found in the locality.

Comment

Representation ID: 27646

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy in principle.

With regard to criteria (vi), we consider the draft wording to be complicated and that it may be difficult to apply when determining planning applications. As drafted, it appears the policy would allow for two houses on the edge of a settlement but then no further additions. While we note the intention, it has the potential to lead to ribbon development along main routes into villages and coalescence of settlements. Once the new houses have been built, it may be difficult to resist further developments, particularly at the end of the plan period as policies become weaker and/or if the exact same approach isn’t continued in future local plans.

The definition of frontages is also open to interpretation and may make it difficult to resist back land schemes within the rural settlements. We note paragraph 5.118 states that: “While development boundaries will normally follow physical boundaries, on occasion, the full depth of property curtilages may be excluded to make clear a policy statement that back land or in-depth development is unacceptable, often because of its additional visual or amenity impact.” There may therefore be situations where the curtilage of a property is excluded from the development boundary, but the dwelling itself is within the settlement boundary. Depending on the layout and pattern of the surrounding settlement, draft Policy HOU13 may make provision for developing the curtilage of this property. This is therefore in conflict with the approach set out at paragraph 5.118 (please see also our response to Q82). We suggest amending the wording to refer to “in-fill” developments on sites which front the public highway and follow the pattern of development found in the locality.

Comment

Representation ID: 27647

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and welcome the provision of guidance on these matters. With regard to criteria i), we consider it necessary to allow greater flexibility regarding the provision of private amenity space in flatted schemes. On some sites (e.g. small sites) and in certain circumstances (e.g. some users may not have a desire for private amenity space), the provision of communal amenity space in lieu of private space may be appropriate. This should ensure a balance is struck on making full and efficient use of sites, meeting the needs of different groups/end users, while achieving a good quality development. We therefore suggest amending the wording to allow this flexibility.

Comment

Representation ID: 27648

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and welcome the provision of guidance on these matters. With regard to criteria i), we consider it necessary to allow greater flexibility regarding the provision of private amenity space in flatted schemes. On some sites (e.g. small sites) and in certain circumstances (e.g. some users may not have a desire for private amenity space), the provision of communal amenity space in lieu of private space may be appropriate. This should ensure a balance is struck on making full and efficient use of sites, meeting the needs of different groups/end users, while achieving a good quality development. We therefore suggest amending the wording to allow this flexibility.

Comment

Representation ID: 27649

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and welcome the provision of guidance on these matters. With regard to criteria i), we consider it necessary to allow greater flexibility regarding the provision of private amenity space in flatted schemes. On some sites (e.g. small sites) and in certain circumstances (e.g. some users may not have a desire for private amenity space), the provision of communal amenity space in lieu of private space may be appropriate. This should ensure a balance is struck on making full and efficient use of sites, meeting the needs of different groups/end users, while achieving a good quality development. We therefore suggest amending the wording to allow this flexibility.

Comment

Representation ID: 27650

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of the policy. This is on the basis the policy makes provision for people to adapt their homes to suit changing needs. In certain circumstances, this may avoid the need to move which can remove pressure from the housing market. See also our response to Q151.

Comment

Representation ID: 27651

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of the policy. This is on the basis the policy makes provision for annexes and therefore allows people to adapt their homes to suit changing needs. In certain circumstances, this may avoid the need to move, for families to have multiple dwellings and allows people to care for family members. This therefore removes some pressure for new homes and care homes. The wording could be slightly more positively worded, in a similar way to draft condition HOU16. For example: “The creation of residential annexes will be permitted in accordance with the sequential approach below:…”. See also our response to Q149.

Comment

Representation ID: 27652

Received: 23/07/2024

Respondent: Southern Housing

Paragraphs 1.12-1.18, page 9 – For the Reg 19 document, we suggest adding a table setting out the local plan preparation stages. This would help all readers’ understanding of the process and enable them to better identify which stage has been reached (see attached example from the London Borough of Harrow).

Comment

Representation ID: 27653

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy in principle. 18 months of marketing is the timeframe often required by councils when considering the loss of community and other types of important uses. However, it may be beneficial to provide some evidence on why this period is appropriate for Rother. Details regarding the type of marketing required may also be beneficial. This should be based on evidence and could be included as an Appendix to the plan – see the attached example from the London Borough of Wandsworth.