Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27604

Received: 23/07/2024

Respondent: Southern Housing

We support the 30-year vision in principle, as it’s based on the Transport for the South-East Strategic Investment Plan and for the reasons set out in our response to Q68.

Comment

Representation ID: 27605

Received: 23/07/2024

Respondent: Southern Housing

We support the approach in principle. We note the supporting text at paragraph 5.82 states there are areas of countryside within the other sub-areas. RDC should, therefore, consider amalgamating the points within the Vision for the Countryside with the other visions and/or ensuring there are cross-references between each. It is also important to ensure the views of those who live and work in rural areas are captured when preparing the local plan. Consideration should therefore be given to targeted consultation meetings in these areas (e.g. organised via Parish Councils) to ensure these communities engage in the plan making process.

Comment

Representation ID: 27606

Received: 23/07/2024

Respondent: Southern Housing

We support the approach in principle. We note the supporting text at paragraph 5.82 states there are areas of countryside within the other sub-areas. RDC should, therefore, consider amalgamating the points within the Vision for the Countryside with the other visions and/or ensuring there are cross-references between each. It is also important to ensure the views of those who live and work in rural areas are captured when preparing the local plan. Consideration should therefore be given to targeted consultation meetings in these areas (e.g. organised via Parish Councils) to ensure these communities engage in the plan making process.

Comment

Representation ID: 27607

Received: 23/07/2024

Respondent: Southern Housing

The policy is based on evidence prepared jointly with ESCC, which we welcome.

Comment

Representation ID: 27608

Received: 23/07/2024

Respondent: Southern Housing

Paragraph 5.99 references paragraph 5.96. We believe this should be a reference to paragraph 5.97. With regard to housing, the maximum potential growth identified in figures 34, 35 and 36 falls below the 733 homes per annum required in accordance with the national standard calculation. On that basis we consider it appropriate to aim for the higher range figure to ensure the maximum amount of growth can be achieved. Failure to meet identified local need during the plan period will deprive Rother of the development it needs and lead to significant unmet need at the start of the next local plan period. Recent research by the Consortium of Associations in the South East (CASE - of which Southern Housing is a member) shows Rother could see a net undersupply of between 2,910 and 3,720 affordable homes over the next decade.

However, we acknowledge that the Housing and Economic Land Availability Assessment (HELAA) (April 2024) includes a commitment (paragraph 7.9) to undertake a review following the current Regulation 18 consultation. This review is welcomed as it shows RDC’s commitment to ensure opportunities are taken to meet local need. If following this review, it is still not possible to identify suitable sites, the focus should be on greater collaborative working with neighbouring authorities to ensure this unmet need is addressed. Please see also our response to Q116 on affordable housing.

Comment

Representation ID: 27609

Received: 23/07/2024

Respondent: Southern Housing

As we mentioned in our response to Q76, failure to deliver will lead to unmet need in the next plan period. The risk of relying on greater delivery later in the plan period is this target isn’t achieved. The supporting text at paragraph 5.102 indicates local delivery rates are sensitive to economic conditions etc. If economic instability is experienced later in the plan period, it’s unlikely the level of delivery will increase. This approach should therefore only be taken forward if it can be supported by very robust evidence. We note the intention is to undertake viability testing and further market analysis (5.103), which we welcome. Please see also our response to Q116 on affordable housing.

Comment

Representation ID: 27610

Received: 23/07/2024

Respondent: Southern Housing

We agree with the aims of this policy in principle. As this is a review of Policy OSS4 in the current Core Strategy, the loss of criterion v) (relating to housing density) should be justified. The current version of the NPPF (December 2023), includes guidance on density (paragraphs 128 – 130) and the draft Plan includes Policy LWL1: Compact Development. The need for appropriate densities therefore remains a key issue at both the national and local level. In light of this, RDC should consider retaining a similar point in the current policy. Point iii) could also be strengthened to encourage the delivery of high-quality design, for example: “Demonstrates a strong understanding of the local context and that all opportunities have been taken to deliver high-quality design that respects and does not detract from the character and appearance of the locality”. This approach will be in line with Chapter 12 of the NPPF and ensure the need for good design is seen as a priority.

Comment

Representation ID: 27611

Received: 23/07/2024

Respondent: Southern Housing

We agree with the aims of this policy in principle. As this is a review of Policy OSS4 in the current Core Strategy, the loss of criterion v) (relating to housing density) should be justified. The current version of the NPPF (December 2023), includes guidance on density (paragraphs 128 – 130) and the draft Plan includes Policy LWL1: Compact Development. The need for appropriate densities therefore remains a key issue at both the national and local level. In light of this, RDC should consider retaining a similar point in the current policy. Point iii) could also be strengthened to encourage the delivery of high-quality design, for example: “Demonstrates a strong understanding of the local context and that all opportunities have been taken to deliver high-quality design that respects and does not detract from the character and appearance of the locality”. This approach will be in line with Chapter 12 of the NPPF and ensure the need for good design is seen as a priority.

Comment

Representation ID: 27612

Received: 23/07/2024

Respondent: Southern Housing

We support the approach in principle. With regard to the third paragraph, for large-scale schemes, it may be appropriate to bring forward a hybrid application comprising outline or the wider site and full planning for part of the scheme/the first phase. This can be a way of delivering a comprehensive scheme for a site whilst speeding up delivery in the shorter term. It may therefore be beneficial to include the example of a hybrid application as one of the “circumstances” where development of part of a site may be acceptable.

Comment

Representation ID: 27613

Received: 23/07/2024

Respondent: Southern Housing

We support the approach in principle. With regard to the third paragraph, for large-scale schemes, it may be appropriate to bring forward a hybrid application comprising outline or the wider site and full planning for part of the scheme/the first phase. This can be a way of delivering a comprehensive scheme for a site whilst speeding up delivery in the shorter term. It may therefore be beneficial to include the example of a hybrid application as one of the “circumstances” where development of part of a site may be acceptable.