Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27554

Received: 23/07/2024

Respondent: Southern Housing

We’re supportive of this policy.

Comment

Representation ID: 27555

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy. Where contributions are requested for speculative heat network schemes or for evidence gathering (as opposed to planned schemes), clawback mechanisms should be included in the s106 agreements to ensure developers can reclaim financial payments where the money isn’t utilised for its intended purpose.

Comment

Representation ID: 27556

Received: 23/07/2024

Respondent: Southern Housing

There doesn’t appear to be multiple approaches to choose from.

Comment

Representation ID: 27557

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy. The Plan’s support for roof-mounted solar is welcome. However, some additional guidance regarding solar may be beneficial, particularly for schemes within conservation areas or relating to heritage assets.

Comment

Representation ID: 27558

Received: 23/07/2024

Respondent: Southern Housing

We support the approach to identifying broad locations for wind development.

Comment

Representation ID: 27559

Received: 23/07/2024

Respondent: Southern Housing

We support this policy in principle. However, we note criterion i) states development will need to demonstrate that: “it will not harm or adversely affect an area or areas identified as being of importance for biodiversity or as areas that could become of importance for biodiversity (opportunities for nature recovery).” The Plan should provide clear guidance on what constitutes an area that could become important for biodiversity to provide certainty for the development industry. This will ensure developers can identify potential areas and therefore factor the costs of enhancing or mitigating the impacts of development on these areas as part of their scheme.

Comment

Representation ID: 27560

Received: 23/07/2024

Respondent: Southern Housing

Whilst we support the principle of biodiversity net gain, there doesn’t appear to be compelling justification for an increase above the statutory 10% requirement. Paragraph 3.48 states the increase is justified on the basis opportunities for off-site mitigation are available locally. However, this relies on either acquiring land outside of developers’ control or co-operating with third party landowners to provide off-site mitigation. This is likely to increase development costs and should therefore be robustly viability tested. It’s also likely a proportion of the land available for the off-site opportunities will be used to provide BNG credits to cater for the schemes that cannot provide net gain on-site or off-site. Therefore, we believe further justification is necessary to ensure the 10% requirement is suitable for Rother and to help justify the approach at the examination stage.

Comment

Representation ID: 27561

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy. The draft wording refers to the “High Weald National Landscape (AONB)”. Given the name change to National Landscape is fairly recent, it may be worth providing the full definition of AONB e.g. “High Weald National Landscape (formerly Area of Outstanding Natural Beauty (AONB))”. This should avoid confusion while the High Weald AONB Management Plan remains in place.

Where reference is made to paragraph 183 of the NPPF, we suggest re-wording to reference the fact major development should also be in the public interest e.g. “Major development should not take place in the AONB save in exceptional circumstances and where the scheme is in the public interest as outlined at paragraph 183 of the NPPF.”

Comment

Representation ID: 27562

Received: 23/07/2024

Respondent: Southern Housing

Where reference is made to paragraph 183 of the NPPF, we suggest re-wording to reference the fact major development should also be in the public interest e.g. “Major development should not take place in the AONB save in exceptional circumstances and where the scheme is in the public interest as outlined at paragraph 183 of the NPPF.”

Comment

Representation ID: 27563

Received: 23/07/2024

Respondent: Southern Housing

We support the approach and welcome the range of densities and the fact the policy is based on evidence set out in the Rother Density Study. While this is the case, we believe “compact development”, as described in the supporting text (paragraphs 4.12-4.13), is only likely to be achievable in Bexhill, Rye and some of the other larger settlements. The reason being that some parts of Rother are very low density. RDC should, therefore, consider amending the term “Compact Development”. A more appropriate term could be “Making effective and efficient use of land”.