Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27574

Received: 23/07/2024

Respondent: Southern Housing

The same principles apply as outlined in our response to Q30. The proximity of a site to public transport should be a consideration. But we think it’s necessary to verify the 400m distance stated in the draft policy is appropriate for the local context and doesn’t stop the delivery of appropriate new development. Our point made above relating to CEMPs and the links to policies GTC3 and LWL3 are also relevant.

Comment

Representation ID: 27575

Received: 23/07/2024

Respondent: Southern Housing

This policy has multiple links to other policies within the draft plan, including to GTC1, GTC3, GTC8, GTC9, LWL1, LWL3 and LWL4. For example point iv)-Material Banks for Future Development relates directly to GTC3: Construction Materials and Waste). Our responses to Q6, Q11, Q22, Q25. Q27, Q33 and Q36 are therefore relevant. While we support the principle of this policy and its overall aims, most of the matters covered are already addressed in other policies. RDC should, therefore, consider amending this policy so its main focus is distinctive design and placemaking with references to the other relevant policies in the supporting text.

Comment

Representation ID: 27576

Received: 23/07/2024

Respondent: Southern Housing

This policy has multiple links to other policies within the draft plan, including to GTC1, GTC3, GTC8, GTC9, LWL1, LWL3 and LWL4. For example point iv)-Material Banks for Future Development relates directly to GTC3: Construction Materials and Waste). Our responses to Q6, Q11, Q22, Q25. Q27, Q33 and Q36 are therefore relevant. While we support the principle of this policy and its overall aims, most of the matters covered are already addressed in other policies. RDC should, therefore, consider amending this policy so its main focus is distinctive design and placemaking with references to the other relevant policies in the supporting text.

Comment

Representation ID: 27577

Received: 23/07/2024

Respondent: Southern Housing

This policy has multiple links to other policies within the draft plan, including to GTC1, GTC3, GTC8, GTC9, LWL1, LWL3 and LWL4. For example point iv)-Material Banks for Future Development relates directly to GTC3: Construction Materials and Waste). Our responses to Q6, Q11, Q22, Q25. Q27, Q33 and Q36 are therefore relevant. While we support the principle of this policy and its overall aims, most of the matters covered are already addressed in other policies. RDC should, therefore, consider amending this policy so its main focus is distinctive design and placemaking with references to the other relevant policies in the supporting text.

Comment

Representation ID: 27578

Received: 23/07/2024

Respondent: Southern Housing

The policy includes part (A), which sets out a list of criteria, and part (B), which aims for major housing schemes to have a form factor of 1.7. Part (A) includes eight criteria for assessing new development covering a range of matters. The supporting text only appears to focus on (A)(ii) Orientation and (B). The other criteria are not discussed or evidenced in any way. The supporting text introduces form factor (paragraphs 4.54-4.55) and references the Climate Emergency Guide, but doesn’t explain why the 1.7 form factor figure has been chosen.

Given our response on LWL5 (Q39), we believe RDC should consider reducing the number of criteria and then amalgamating both policies (LWL5 and LWL6) to cover distinctive design and placemaking.

Comment

Representation ID: 27579

Received: 23/07/2024

Respondent: Southern Housing

The policy includes part (A), which sets out a list of criteria, and part (B), which aims for major housing schemes to have a form factor of 1.7. Part (A) includes eight criteria for assessing new development covering a range of matters. The supporting text only appears to focus on (A)(ii) Orientation and (B). The other criteria are not discussed or evidenced in any way. The supporting text introduces form factor (paragraphs 4.54-4.55) and references the Climate Emergency Guide, but doesn’t explain why the 1.7 form factor figure has been chosen.

Given our response on LWL5 (Q39), we believe RDC should consider reducing the number of criteria and then amalgamating both policies (LWL5 and LWL6) to cover distinctive design and placemaking.

Comment

Representation ID: 27580

Received: 23/07/2024

Respondent: Southern Housing

We support the general approach, but, as stated in the response to Q42, we believe additional justification is necessary.

Comment

Representation ID: 27581

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy and the general approach to creating well designed streets. However, while paragraph 5.63 references schemes of more than 50 dwellings or 500sqm of non-residential floor space, it’s important to ensure routes within sites are suitable for the traffic the use generates. For example, it is likely to be difficult to accommodate the requirements of point (A)(i) when designing a new industrial development. It would also be helpful if RDC provided justification for the 50 dwellings/500sqm of non-residential floorspace thresholds.

Comment

Representation ID: 27582

Received: 23/07/2024

Respondent: Southern Housing

We support the aims of this policy and the general approach to creating well designed streets. However, while paragraph 5.63 references schemes of more than 50 dwellings or 500sqm of non-residential floor space, it’s important to ensure routes within sites are suitable for the traffic the use generates. For example, it is likely to be difficult to accommodate the requirements of point (A)(i) when designing a new industrial development. It would also be helpful if RDC provided justification for the 50 dwellings/500sqm of non-residential floorspace thresholds.

Comment

Representation ID: 27583

Received: 23/07/2024

Respondent: Southern Housing

The 10 Healthy Streets Indicators are a recognised evidence-based standard used in other parts of the country. We’re therefore supportive of the approach in principle, but the implementation of the policy will have cost implications and require input from multiple organisations to ensure all points are achieved. RDC will need to consider how to foster collaborative working with ESCC to ensure the aims are achievable and whether targets need to be adapted to suit local circumstances.