Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27614

Received: 23/07/2024

Respondent: Southern Housing

As the development boundaries relate to what are considered to be “sustainable” settlements, the principle of all kinds of development should be acceptable within these areas. It may therefore be beneficial to make this clear within the policy wording.

We note that paragraph 5.118 states: “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.”. While we note the aims of this policy, we consider there to be a disparity between this and the current wording of draft Policy HOU13 (New Dwellings in the Countryside). The draft policy has the potential to make it difficult for the Council to resist back land development (please see response to Q140).

We welcome the intention to undertake a further review of development boundaries (paragraph 5.119). It’s important to ensure development is located in the most appropriate locations and the boundaries encompass suitable locations to deliver the level of growth identified in the strategy.

Comment

Representation ID: 27615

Received: 23/07/2024

Respondent: Southern Housing

As the development boundaries relate to what are considered to be “sustainable” settlements, the principle of all kinds of development should be acceptable within these areas. It may therefore be beneficial to make this clear within the policy wording.

We note that paragraph 5.118 states: “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.”. While we note the aims of this policy, we consider there to be a disparity between this and the current wording of draft Policy HOU13 (New Dwellings in the Countryside). The draft policy has the potential to make it difficult for the Council to resist back land development (please see response to Q140).

We welcome the intention to undertake a further review of development boundaries (paragraph 5.119). It’s important to ensure development is located in the most appropriate locations and the boundaries encompass suitable locations to deliver the level of growth identified in the strategy.

Comment

Representation ID: 27616

Received: 23/07/2024

Respondent: Southern Housing

It may be beneficial to specify the relevant use classes of the uses the policy is aimed at protecting. As drafted, the policy states “This includes a community facility, public house, local shops, tourist accommodation or attractions and an employment use.” The wording therefore doesn’t appear to cover retail and other Class E type uses. References to the use classes may make the policy more precise, for example “This includes uses falling within Classes C1, E, F1, F2, public houses and other sui generis type uses involving elements of the aforementioned use classes.”

Comment

Representation ID: 27617

Received: 23/07/2024

Respondent: Southern Housing

We support this policy including the 20% requirement as it is evidence-based. Given the information set out in the Council’s Housing Land Supply Position Statement (December 2023), the HELAA and the points made in earlier chapters regarding constraints to delivery, it is important to ensure small sites are encouraged to help meet housing need. However, clarification is required as to whether the 20% target includes the 39 dwellings per annum windfall allowance.

Comment

Representation ID: 27618

Received: 23/07/2024

Respondent: Southern Housing

We support this policy including the 20% requirement as it is evidence-based. Given the information set out in the Council’s Housing Land Supply Position Statement (December 2023), the HELAA and the points made in earlier chapters regarding constraints to delivery, it is important to ensure small sites are encouraged to help meet housing need. However, clarification is required as to whether the 20% target includes the 39 dwellings per annum windfall allowance.

Comment

Representation ID: 27619

Received: 23/07/2024

Respondent: Southern Housing

We support this policy including the 20% requirement as it is evidence-based. Given the information set out in the Council’s Housing Land Supply Position Statement (December 2023), the HELAA and the points made in earlier chapters regarding constraints to delivery, it is important to ensure small sites are encouraged to help meet housing need. However, clarification is required as to whether the 20% target includes the 39 dwellings per annum windfall allowance.

Comment

Representation ID: 27620

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and the need to stop the coalescence of settlements etc. While this is the case, the strategic Green Gap boundaries should be reviewed to ensure they remain appropriate and fit for purpose. The supporting text should be updated to include reference to the review/evidence to support the policy. The supporting text (paragraph 5.134) also indicates the policy will still allow for agricultural buildings, conversions and replacement buildings. RDC should also consider including reference to this in the policy wording to ensure clarity.

Comment

Representation ID: 27621

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and the need to stop the coalescence of settlements etc. While this is the case, the strategic Green Gap boundaries should be reviewed to ensure they remain appropriate and fit for purpose. The supporting text should be updated to include reference to the review/evidence to support the policy. The supporting text (paragraph 5.134) also indicates the policy will still allow for agricultural buildings, conversions and replacement buildings. RDC should also consider including reference to this in the policy wording to ensure clarity.

Comment

Representation ID: 27622

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and welcome the fact it is based on evidence in the HEDNA. RDC should consider allowing flexibility regarding the mix where schemes are being delivered as 100% affordable housing. This should help encourage the delivery of affordable housing across Rother.

Comment

Representation ID: 27623

Received: 23/07/2024

Respondent: Southern Housing

We support the principle of this policy and welcome the fact it is based on evidence in the HEDNA. RDC should consider allowing flexibility regarding the mix where schemes are being delivered as 100% affordable housing. This should help encourage the delivery of affordable housing across Rother.