Rother Local Plan 2020-2040 (Regulation 18)

1. Question 51 on page 111 of Draft Local Plan.

Our views on Development Strategy.

1.1 The Development Strategy should comply with the new Labour Government manifesto commitment for mandatory housing targets that will deliver 300,000 new homes per year over 5 years = 1.5 million new homes, based on revisions to the NPPF.

1.2 This could be achieved by adoption of the Standard Method. The HELDA report accepted that there were no exceptional circumstances for not using the Standard Method in Rother, which would result in a local housing need of 737 homes per year plus a 20% buffer. But it is inconsistent in also considering household formation would justify a significantly reduced level of growth.

1.3 The justification for this approach is that the HELDA report identifies Rother population growth declining from +12% in 1980-1990, to +6% in 2000 - 2010, and +3% in 2010-2020. The Development Strategy needs to reverse this declining trend to boost housing supply, to comply with the NPPF. An attainable level was achieved in the 1980-1990s.

1.4 There is a specific local housing need for older people with the HELDA report noting that Rother has the 2nd highest median age, after North Norfolk, in England. The forecast increase in population aged 75+ is +82%. The local level of services needed to support this rural population will require an increase in the younger population aged 0-65 years.

1.5 Practically the only Development Strategy that would reverse the decline of population aged 0-65 years, would be by using the Standard Method, as shown in the HELDA report.

1.6 Both the Vale of White Horse and South Oxfordshire Districts have Green Belt and National Landscape( AONB) constraints. But both Districts have adopted Local Plans that increased house completions from c.200 homes per year to c.800-1,000 homes per year. This has led to local services being improved and an increase in younger population aged 0-65 years.

2. Questions 68-70 on the vision for Northern Rother.

2.1 The vision takes insufficient account of the proximity to a large range of services in Heathfield, c.3 kms to the north west of the District boundary.

2.2 The Draft Local Plan accepts that Burwash, Burwash Common and Burwash Weald are linked ridge-topped villages along the A265.
The NPPF supports development in linked villages where services in one village are supported by the population in linked villages. The Development Strategy does not reflect that these are linked villages with a population of c.3,000 population.

2.3 The three linked villages should be assessed together, rather than separately.
A larger scale of development could then be justified in keeping with the character of three linked villages with a population of c.3,000 people.

2.4 The HEMA report should have considered that land at Linkway, Vicarage Road, Burwash Common was suitable for development, because development constraints could be resolved in a detailed planning application, and the site is more closely related to the existing built up area on A265 and Vicarage Road/Vicarage Lane.

1. Question 51 on page 111 of Draft Local Plan.

Our views on Development Strategy.

1.1 The Development Strategy should comply with the new Labour Government manifesto commitment for mandatory housing targets that will deliver 300,000 new homes per year over 5 years = 1.5 million new homes, based on revisions to the NPPF.

1.2 This could be achieved by adoption of the Standard Method. The HELDA report accepted that there were no exceptional circumstances for not using the Standard Method in Rother, which would result in a local housing need of 737 homes per year plus a 20% buffer. But it is inconsistent in also considering household formation would justify a significantly reduced level of growth.

1.3 The justification for this approach is that the HELDA report identifies Rother population growth declining from +12% in 1980-1990, to +6% in 2000 - 2010, and +3% in 2010-2020. The Development Strategy needs to reverse this declining trend to boost housing supply, to comply with the NPPF. An attainable level was achieved in the 1980-1990s.

1.4 There is a specific local housing need for older people with the HELDA report noting that Rother has the 2nd highest median age, after North Norfolk, in England. The forecast increase in population aged 75+ is +82%. The local level of services needed to support this rural population will require an increase in the younger population aged 0-65 years.

1.5 Practically the only Development Strategy that would reverse the decline of population aged 0-65 years, would be by using the Standard Method, as shown in the HELDA report.

1.6 Both the Vale of White Horse and South Oxfordshire Districts have Green Belt and National Landscape( AONB) constraints. But both Districts have adopted Local Plans that increased house completions from c.200 homes per year to c.800-1,000 homes per year. This has led to local services being improved and an increase in younger population aged 0-65 years.

2. Questions 68-70 on the vision for Northern Rother.

2.1 The vision takes insufficient account of the proximity to a large range of services in Heathfield, c.3 kms to the north west of the District boundary.

2.2 The Draft Local Plan accepts that Burwash, Burwash Common and Burwash Weald are linked ridge-topped villages along the A265.
The NPPF supports development in linked villages where services in one village are supported by the population in linked villages. The Development Strategy does not reflect that these are linked villages with a population of c.3,000 population.

2.3 The three linked villages should be assessed together, rather than separately.
A larger scale of development could then be justified in keeping with the character of three linked villages with a population of c.3,000 people.

2.4 The HEMA report should have considered that land at Linkway, Vicarage Road, Burwash Common was suitable for development, because development constraints could be resolved in a detailed planning application, and the site is more closely related to the existing built up area on A265 and Vicarage Road/Vicarage Lane.