Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27584

Received: 23/07/2024

Respondent: Southern Housing

While we support most of the broad aims of this policy, the number of criteria, repetition and detail makes the policy confusing and may make it difficult to deliver policy-compliant schemes. For example, point ii) is entitled Car Parking Layout, but instead focuses on parking management plans and street design. As the other criteria provide greater detail regarding parking layout expectations and servicing, RDC should consider incorporating the requirements into other criteria, or renaming this point to Parking Management Plans.

Also, given the emphasis on reducing carbon and tackling climate change, a bolder approach could potentially be taken to encourage car-free developments in sustainable locations (e.g. Bexhill-on-Sea and Rye town centres). While we note the supporting text at paragraph 4.74 references car-free development, RDC should consider adding this to the policy wording. This policy should also be subject to further consultation with ESCC to ensure car-free development is still considered acceptable in appropriate locations.

Comment

Representation ID: 27585

Received: 23/07/2024

Respondent: Southern Housing

While we support most of the broad aims of this policy, the number of criteria, repetition and detail makes the policy confusing and may make it difficult to deliver policy-compliant schemes. For example, point ii) is entitled Car Parking Layout, but instead focuses on parking management plans and street design. As the other criteria provide greater detail regarding parking layout expectations and servicing, RDC should consider incorporating the requirements into other criteria, or renaming this point to Parking Management Plans.

Also, given the emphasis on reducing carbon and tackling climate change, a bolder approach could potentially be taken to encourage car-free developments in sustainable locations (e.g. Bexhill-on-Sea and Rye town centres). While we note the supporting text at paragraph 4.74 references car-free development, RDC should consider adding this to the policy wording. This policy should also be subject to further consultation with ESCC to ensure car-free development is still considered acceptable in appropriate locations.

Comment

Representation ID: 27586

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of Communal ‘Remote’ Car Parking. This approach is already seen in some large housing schemes and can work well subject to good site layout and design. For these to work well, we consider natural surveillance essential in accordance with Secured by Design best practice. We also welcome the point regarding servicing, refuse and emergency vehicles access as this can often have a significant impact on design.

Comment

Representation ID: 27587

Received: 23/07/2024

Respondent: Southern Housing

The approach appears to be based on testing through the Development Strategy Background Paper and the sustainability appraisal process, which is positive. However, the text in the “Preferred Spatial Development Options” (pages 109-110) isn’t particularly clear, as there isn’t any explanation regarding the Spatial Development Options. However, the “Strategy Wording” box in the next section is much clearer and in line with that on page 71 of the Development Strategy Background Paper.

Comment

Representation ID: 27588

Received: 23/07/2024

Respondent: Southern Housing

The approach appears to be based on testing through the Development Strategy Background Paper and the sustainability appraisal process, which is positive. However, the text in the “Preferred Spatial Development Options” (pages 109-110) isn’t particularly clear, as there isn’t any explanation regarding the Spatial Development Options. However, the “Strategy Wording” box in the next section is much clearer and in line with that on page 71 of the Development Strategy Background Paper.

Comment

Representation ID: 27589

Received: 23/07/2024

Respondent: Southern Housing

The approach appears to be based on testing through the Development Strategy Background Paper and the sustainability appraisal process, which is positive. However, the text in the “Preferred Spatial Development Options” (pages 109-110) isn’t particularly clear, as there isn’t any explanation regarding the Spatial Development Options. However, the “Strategy Wording” box in the next section is much clearer and in line with that on page 71 of the Development Strategy Background Paper.

Comment

Representation ID: 27590

Received: 23/07/2024

Respondent: Southern Housing

We support the spatial development strategy in principle as it brings together the research and conclusions from the Development Strategy Background Paper. RDC should consider placing greater emphasis on collaborative working with neighbouring authorities and with ESCC. While we note the Development Strategy Background Paper includes a section regarding the duty to co-operate at 6.8 and some others references to working with ESCC (paragraph 5.14), there is little reference to this in the draft plan. Given the strategy involves a combination of options, it’s important that ESCC has input regarding the transport impacts and service provision. We also consider close working with HBC necessary to ensure the approach remains deliverable. This is especially important as the strategy involves development within the Hastings Fringes area, which will place a strain on the infrastructure and services of both Hastings and Rother.

We also support the note at the end of the strategy (marked with an*), which states the housing and employment targets will be minimum figures. The purpose of a local plan should be to deliver sustainable development rather than restrict positive growth. The supporting text appears to focus more on employment and economic development than housing. RDC should consider introducing more discussion regarding housing to highlight its importance, particularly its role in stimulating employment and economic growth.

Comment

Representation ID: 27591

Received: 23/07/2024

Respondent: Southern Housing

The approach appears to be based on testing through the Development Strategy Background Paper and the sustainability appraisal process, which is positive. However, the text in the “Preferred Spatial Development Options” (pages 109-110) isn’t particularly clear, as there isn’t any explanation regarding the Spatial Development Options. However, the “Strategy Wording” box in the next section is much clearer and in line with that on page 71 of the Development Strategy Background Paper.

We support the spatial development strategy in principle as it brings together the research and conclusions from the Development Strategy Background Paper. RDC should consider placing greater emphasis on collaborative working with neighbouring authorities and with ESCC. While we note the Development Strategy Background Paper includes a section regarding the duty to co-operate at 6.8 and some others references to working with ESCC (paragraph 5.14), there is little reference to this in the draft plan. Given the strategy involves a combination of options, it’s important that ESCC has input regarding the transport impacts and service provision. We also consider close working with HBC necessary to ensure the approach remains deliverable. This is especially important as the strategy involves development within the Hastings Fringes area, which will place a strain on the infrastructure and services of both Hastings and Rother.

We also support the note at the end of the strategy (marked with an*), which states the housing and employment targets will be minimum figures. The purpose of a local plan should be to deliver sustainable development rather than restrict positive growth. The supporting text appears to focus more on employment and economic development than housing. RDC should consider introducing more discussion regarding housing to highlight its importance, particularly its role in stimulating employment and economic growth.

Comment

Representation ID: 27592

Received: 23/07/2024

Respondent: Southern Housing

It’s positive to see the housing and employment floor space figures are indicated as a minimum. This should help ensure Bexhill sees adequate growth during the plan period. The need to ensure accessibility by car alongside a range of sustainable options is also positive given the rural nature of some parts of the district. As mentioned in the response to Q48, there may also be an opportunity to reference car-free development, as Bexhill is the location where this is most likely to be achievable.

Comment

Representation ID: 27593

Received: 23/07/2024

Respondent: Southern Housing

These locations have been identified and tested through the Development Strategy Background Paper and sustainability appraisal. Subject to further testing and engagement with neighbouring authorities (see responses to Q51 and Q54), we consider them to be appropriate locations for new development.