Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28087

Received: 23/07/2024

Respondent: Kingacre Estates

Agent: Nexus Planning

Paragraph 5.8 of the Draft LP confirms that the most appropriate spatial development options to take forward as
Rother’s proposed development strategy is a combination of the following options:
a. Brownfield intensification and redevelopment within sustainable settlements (Option reference SDO6);
b. Bexhill greenfield growth on the northern and western edges of the built-up area of Bexhill to create new
compact, connected communities (SDO3A);
c. Hastings Fringes urban growth (SDO5);
d. Radial settlement network connected to Bexhill and Hastings (SDO2);
e. Village clusters centred around Rye and Battle (SDO1); and
f. Sustainable settlement growth (SDO4) with longer term, a focus on the A21 Corridor (SDO10).
6. The Spatial Strategy further confirms that the Council will meet the local need for all forms of housing, jobs,
facilities and services by strengthening Rother’s pattern of development through a landscape -led spatial
development strategy that focuses on the ‘Live Well Locally’ concept.
7. The Development Strategy Background Paper (April 2024) describes option SDO1 (Village Clusters) as a cluster of
villages that are connected with each other to form a sustainable community. One of the clusters identified is
centred around Rye and includes the village of Broad Oak.

Section 2 of the Framework considers achieving sustainable development. Paragraph 7 states that:
“The purpose of the planning system is to contribute to the achievement of sustainable development,
including the provision of homes, commercial development, and supporting infrastructure in a sustainable
manner.”
9. Paragraph 11 discusses the presumption in favour of sustainable development and states that:
“For plan-making this means that:
a. all plans should promote a sustainable pattern of development that seeks to: meet the development needs
of their area; align growth and infrastructure; improve the environment; mitigate climate change (including
by making effective use of land in urban areas) and adapt to its effects;
b. strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses.”
10. Kingacre Estates supports the Council in seeking to address the sustainable longer term strategy for villages in
rural locations. It is key to address the need for housing within the rural areas in line with spatial objective 4 of
the Draft LP. However, this needs a strategic approach which directs residential development to those villages in
close proximity to nearby towns, such as Broad Oak, where sustainable transport options, including bus stops
(providing regular services to Robertsbridge, Westfield, Peasmarsh, Mountfield and Battle), and services and
facilities such as a primary school, convenience store, bakery and public house are all available. Broad Oak is
demonstrably a sustainable location for development.
11. It is clear that in its spatial strategy, the Council has had regard to encouraging development in locations with
strong access to key services and facilities, and sustainable travel connections, which accords with paragraphs 7
and 11 of the Framework, as well as spatial objectives 1, 7 and 9 of the Draft LP.
12. The Housing and Economic Needs Assessment (February 2024) confirms that the Standard Method calculation
results in a minimum Local Housing Need (LHN) figure of 737 dwellings per annum (dpa), which equates to 7,370
dwellings over the Plan Period. As set out elsewhere in our representations, Kingacre Estates considers that for
the Draft LP to more effectively achieve spatial objective 4, it should explore opportunities to exceed the
minimum LHN figure in setting its housing requirement, to more effectively address the issue of affordability
within the rural areas and ensure a reliable delivery of housing to meet local needs.
Rye and the Eastern Settlement Cluster – Distribution and Growth Opportunities
13. The Vision for Rye and the Eastern Settlements Cluster within the Draft LP sets out that the eastern cluster of
settlements will be better connected by sustainable transport infrastructure, with Rye acting as a key transport
hub, and local economies will continue to grow, respecting the historic development pattern of r ural
communities over time. The strengthened connections to Rye as a sustainable market town, will allow for
sensitive development in adjoining villages.
14. Figure 28 of the Draft LP identifies the proposed development sites for the Rye and Eastern Settlements Cluster
development strategy. This includes the identification of the Site for 12 units and it is something that we strongly
support.
15. The Council’s Sustainability Appraisal (April 2024) presents an assessment of the available sites in the district for
development, and this has informed the Council’s overall spatial strategy. It is worth noting that against the 20
Sustainability Appraisal Objectives, the Site scored highest out of the seven sites located within Broad Oak.
16. The Site is assessed within the Council’s Draft HELAA (reference: BRE003) and identified to be suitable, available
and achievable for development. We wholly agree. It is worth noting that the HELAA states that the Site’s
anticipated timescale for development is ‘unknown’ but Kingacre Estates would like to take this opportunity to
confirm that subject to appropriate consideration at the development management stage (and in any emerging site allocation policy) which acknowledges what has happened on the ground in the years since the Site was
originally allocated, the Site can come forward without delay i.e. within a 5 year timeframe.
17. Kingacre Estates supports the Council in directing strategic development towards sustainable locations within the
rural areas, particularly Broad Oak, and considers that the Site is a suitable location for development as identified
by the Council through its previous allocation of the Site and, more recently, within the HELAA and the
Sustainability Appraisal. Kingacre Estates urges the Council to roll forward its existing allocation at Broad Oak as a
minimum before looking towards new allocations, in order to best support spatial objectives 1, 2, 3, 4, 7 and 9 of
the Draft LP

Comment

Representation ID: 28088

Received: 23/07/2024

Respondent: Kingacre Estates

Agent: Nexus Planning

Paragraph 5.8 of the Draft LP confirms that the most appropriate spatial development options to take forward as
Rother’s proposed development strategy is a combination of the following options:
a. Brownfield intensification and redevelopment within sustainable settlements (Option reference SDO6);
b. Bexhill greenfield growth on the northern and western edges of the built-up area of Bexhill to create new
compact, connected communities (SDO3A);
c. Hastings Fringes urban growth (SDO5);
d. Radial settlement network connected to Bexhill and Hastings (SDO2);
e. Village clusters centred around Rye and Battle (SDO1); and
f. Sustainable settlement growth (SDO4) with longer term, a focus on the A21 Corridor (SDO10).
6. The Development Strategy Background Paper (April 2024) describes option SDO1 (Village Clusters) as a cluster of
villages that are connected with each other to form a sustainable community. One of the clusters identified is
centred around Rye and includes the village of Broad Oak.
7. The Vision for Rye and the Eastern Settlement Cluster sets out that:
“The eastern cluster of settlements will be better connected by sustainable transport infrastructure, with Rye
acting as a key transport hub, and local economies will continue to grow, respecting the historic development pattern of rural communities over time. The strengthened connections to Rye as a sustainable market town,
will allow for sensitive development in adjoining villages.”
8. Section 2 of the Framework considers achieving sustainable development. Paragraph 7 states that:
“The purpose of the planning system is to contribute to the achievement of sustainable development,
including the provision of homes, commercial development, and supporting infrastructure in a sustainable
manner.”
9. Paragraph 11 discusses the presumption in favour of sustainable development and states that:
“For plan-making this means that:
a. all plans should promote a sustainable pattern of development that seeks to: meet the development needs
of their area; align growth and infrastructure; improve the environment; mitigate climate change (including
by making effective use of land in urban areas) and adapt to its effects;
b. strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses.”
10. Kingacre Estates supports the Council in seeking to address the sustainable longer term strategy for villages in
rural locations. It is key to address the need for housing within the rural areas in line with spatial objective 4 of
the Draft LP, however, this needs a strategic approach which directs residential development to those villages in
close proximity to nearby towns, such as Broad Oak, where sustainable transport options, including bus stops
(providing regular services to Robertsbridge, Westfield, Peasmarsh, Mountfield and Battle), and services and
facilities, such as a primary school, convenience store, bakery and public house are all available. Broad Oak is
demonstrably a sustainable location for development.
11. It is clear that in its spatial strategy, the Council has had regard to encouraging development in locations with
strong access to key services and facilities, and sustainable travel connections, which accords with paragraphs 7
and 11 of the Framework, as well as spatial objectives 1, 7 and 9 of the Draft LP.
12. The Council’s Sustainability Appraisal presents an assessment of the available sites in the district for
development, and this has informed the Council’s overall spatial strategy. It is worth noting that the Site is
identified as an available site and scored highest, out of the seven sites located within Broad Oak, against the 20
Sustainability Appraisal Objectives.
13. The Site is within the settlement boundary of Broad Oak and comprises a suitable location for sensitive
development, in line with the Council’s vision for the eastern settlement cluster. This is emphasised through its
residential allocation within the current DaSALP, where the Site was found to be a preferable location for
development.
14. The Site is rightly identified in Figure 28 as a Site currently allocated in the DaSALP. The Site is suitable,
deliverable and developable and we recommend the Council retains existing, currently undeveloped allocations
within the emerging Local Plan, as a minimum before looking at alternatives sites, making sure that the
development management process, and any emerging policy allocations, respond positively to any changes in
circumstance on the ground that have taken place since site allocations were originally made, thereby ensuring
that existing unbuilt allocations remain deliverable in full.
15. Kingacre Estates supports the Council in directing strategic development towards sustainable locations within
the rural areas, particularly Broad Oak, and considers that the Site is a suitable location for development.
Kingacre Estates urges the Council to rollover the existing allocation of the Site in order to support spatial
objectives 1, 4, 7 and 9 of the Draft LP

Conclusion
16. Kingacre Estates welcomes the Council’s engagement in the plan-making process and supports the approach
taken by the Draft LP in seeking to deliver strategic development within sustainable settlements in the rural
areas.
17. Land to the south of the Broad Oak Public House aligns with the Vision for Rye and the Eastern Settlement
Cluster and the spatial objectives of the Draft LP as it would:
a. Deliver a residential development within a suitable and sustainable location within the rural area (in
accordance with Draft LP spatial objectives 1, 4 and 7);
b. Ensure development is accessible and located within close proximity to sustainable transport (in
accordance with spatial objectives 1, 7 and 9);
c. Provide housing to meet local needs and affordability issues (in accordance with spatial objective 4); and
d. Address the short-term housing needs of Broad Oak through its capacity to come forward quickly and
provide a meaningful contribution towards delivering the housing needs of the district (in accordance with
spatial objectives 4)

Comment

Representation ID: 28089

Received: 23/07/2024

Respondent: Kingacre Estates

Agent: Nexus Planning

Paragraph 5.8 of the Draft LP confirms that the most appropriate spatial development options to take forward as
Rother’s proposed development strategy is a combination of the following options:
a. Brownfield intensification and redevelopment within sustainable settlements (Option reference SDO6);
b. Bexhill greenfield growth on the northern and western edges of the built-up area of Bexhill to create new
compact, connected communities (SDO3A);
c. Hastings Fringes urban growth (SDO5);
d. Radial settlement network connected to Bexhill and Hastings (SDO2);
e. Village clusters centred around Rye and Battle (SDO1); and
f. Sustainable settlement growth (SDO4) with longer term, a focus on the A21 Corridor (SDO10).
6. The Development Strategy Background Paper (April 2024) describes option SDO1 (Village Clusters) as a cluster of
villages that are connected with each other to form a sustainable community. One of the clusters identified is
centred around Rye and includes the village of Broad Oak.
7. The Vision for Rye and the Eastern Settlement Cluster sets out that:
“The eastern cluster of settlements will be better connected by sustainable transport infrastructure, with Rye
acting as a key transport hub, and local economies will continue to grow, respecting the historic development pattern of rural communities over time. The strengthened connections to Rye as a sustainable market town,
will allow for sensitive development in adjoining villages.”
8. Section 2 of the Framework considers achieving sustainable development. Paragraph 7 states that:
“The purpose of the planning system is to contribute to the achievement of sustainable development,
including the provision of homes, commercial development, and supporting infrastructure in a sustainable
manner.”
9. Paragraph 11 discusses the presumption in favour of sustainable development and states that:
“For plan-making this means that:
a. all plans should promote a sustainable pattern of development that seeks to: meet the development needs
of their area; align growth and infrastructure; improve the environment; mitigate climate change (including
by making effective use of land in urban areas) and adapt to its effects;
b. strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses.”
10. Kingacre Estates support the Council in seeking to address the sustainable longer term strategy for villages in
rural locations. It is key to address the need for housing within the rural areas in line with spatial objective 4 of
the Draft LP. However, this needs a strategic approach which directs residential development to those villages in
close proximity to nearby towns, such as Broad Oak, where sustainable transport options, including bus stops
(providing regular services to Robertsbridge, Westfield, Peasmarsh, Mountfield and Battle), and services and
facilities such as a primary school, convenience store, bakery and public house are all available. Broad Oak is
demonstrably a sustainable location for development.
11. It is clear that in its spatial strategy, the Council has had regard to encouraging development in locations with
strong access to key services and facilities and sustainable travel connections, which accords with paragraphs 7
and 11 of the Framework, as well as spatial objectives 1, 7 and 9 of the Draft LP.
12. The Housing and Economic Needs Assessment (February 2024) confirms that the Standard Method calculation
results in a minimum Local Housing Need (LHN) figure of 737 dwellings per annum (dpa), which equates to 7,370
dwellings over the Plan Period. As set out elsewhere in our representations, Kingacre Estates considers that for
the Draft LP to effectively achieve spatial objective 4, it should explore opportunities to exceed the minimum
LHN figure in setting its housing requirement, to more effectively address the issue of affordability within the
rural areas and ensure a reliable delivery of housing to meet local needs.
Rye and the Eastern Settlement Cluster – Distribution and Growth Opportunities
13. The Vision for Rye and the Eastern Settlements Cluster within the Draft LP states that the eastern cluster of
settlements will be better connected by sustainable transport infrastructure, with Rye acting as a key transport
hub, and local economies will continue to grow, respecting the historic development pattern of rural
communities over time. The strengthened connections to Rye as a sustainable market town, will allow for
sensitive development in adjoining villages.
14. Figure 25 of the Draft LP illustrates the potential development strategy for Rye and the eastern settlements
cluster. Specifically, relating to Broad Oak, this sets out the following:
a. identified level of housing growth – 52 dwellings;
b. potential additional level of housing growth – 11 dwellings; and
c. total potential housing growth – 63 dwellings

The Council’s Sustainability Appraisal (April 2024) presents an assessment of the available sites in the district for
development, and this has informed the Council’s overall spatial strategy. It is worth noting that the Site is
identified as an available site and scored highest, out of the seven sites located within Broad Oak, against the 20
Sustainability Appraisal Objectives.
16. Kingacre Estates supports the Council in directing strategic development towards sustainable locations within
the rural areas, particularly Broad Oak. To further support the Council’s Spatial Strategy and housing delivery,
and to more effectively achieve spatial objective 4, the Draft LP could explore opportunities to exceed the
minimum LHN figure in setting its housing requirement. This would more effectively address the issue of
affordability within rural areas and ensure a reliable delivery of housing to meet local needs. As identified above,
Broad Oak is a sustainable location within the rural area and Kingacre Estates would suggest that the Council
looks to deliver 63 dwellings as an absolute minimum over the Plan Period.
17. Of course, as an absolute minimum, the Council must roll forward existing, currently undeveloped allocations,
given that these have already been determined to be sustainable and appropriate through the examination
process for the DaSALP (confirmed again in the Sustainability Appraisal accompanying the current consultation).
This is essential in any event but will best support spatial objectives 1, 2, 3, 4, 7 and 9 of the Draft LP.
Conclusion
18. Kingacre Estates supports the approach taken by the Draft LP in seeking to deliver strategic development at
sustainable settlements in the rural areas. Land to the south of Broad Oak Public House aligns with this strategy
and the spatial objectives of the Draft LP as it would:
a. Deliver a residential development within a sustainable location within the rural area (in accordance with
Draft LP spatial objectives 1, 4 and 7);
b. Ensure development is accessible and located within close proximity to sustainable transport (in
accordance with spatial objectives 1, 7 and 9);
c. Provide housing to meet local needs and address affordability issues (in accordance with spatial objective
4);
d. Address the short-term housing needs of Broad Oak as it can come forward quickly and provide a
meaningful contribution towards delivering the housing needs of the district (in accordance with spatial
objectives 4); and
e. Provide an opportunity to deliver a high-quality attractive new development within Broad Oak, which
protects and enhances valued and high-quality landscapes (in accordance with spatial objectives 2 and 3).
19. However, Kingacre Estates consider that in order to support the Draft LP’s vision and objectives even further, the
Council should explore opportunities to exceed the minimum LHN figure.
20. To ensure that suitable and available sites are brought forward, the Council should roll forward unbuilt existing
allocations as a minimum, and then look to explore new appropriate allocations