• HOUSING: The evidence based studies on Housing do not examine the various sectors of housing which make up the overall requirement. The UK has an ageing population and catering for the increasing needs of this growing sector is an essential component of any planning housing policy. There is a wide range of housing need for those who are broadly over 50 yrs of age.

• Many of the sub-sectors are quite specialist and new sectors are continuously evolving. An example of this is the increasing tendency for semi-retirement. For those taking part-time or reduced time employment, leisure and tourism ambitions are often achieved through dividing living between two residences. This has been traditionally manifest through ownership of caravans or mobile homes for weekend and holiday use.

• However, there is now an emerging market for more traditional homes for use on a part-time basis. Sometimes this means occupation during the week but not at weekends and during off-peak seasons where owners choose to avoid holiday crowds. If encouraged, this trend could help to provide a better balance to the peak period pressure on infrastructure and services.

• In this connection, the housing policies need fully to recognise and cater for a range of housing sector types as a specialist and rapidly expanding broader sector for an ageing population. These will include for a range of need including for the following:

• Holiday homes (including caravans, mobile homes and time-share homes),
• 'Life-style' homes' including second homes,
• Sheltered housing,
• Retirement homes,
• Care-homes and,
• Nursing homes.

• As with the overall national trend, at Rother there is a well established and growing demand for specialist housing to cater for older residents (not necessarily the retired). These include those from the indigenous population, as well as those who have resorted to Rother for many years as holiday-makers and new-comers.

• Government policy now gives much greater recognition to meeting the needs of the elderly and is committed to changing the culture of planning to make it "more responsive, positive and proactive". This statement is within the Planning and Compulsory Purchase Act 2004, which explains what is required at a regional and local policy-making level. Diversity and equality are at the heart of this agenda.

• The Government is also committed to creating strong, vibrant and sustainable communities and to promoting community cohesion in both urban and rural areas. These are important elements of delivering sustainable development, which the Government defines as the principle purpose of the planning system.

• Planning Policy Statement 1 (PPS1 2005) states that planning for sustainable development means 'meeting the diverse needs of all people in existing and future communities, promoting personal well being, social cohesion and inclusion and creating equal opportunity for all citizens'.

• It goes on to state that: 'Development plans should promote development that creates socially inclusive communities, including suitable mixes of housing. Plan policies should:

• ensure that the impact of development on the social fabric of communities is considered and taken into account;
• seek to reduce social inequalities;
• address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities;
• take into account the needs of all the community, including particular requirements relating to age, (my underlining) sex, ethnic background, religion, disability or income;
• deliver safe, healthy and attractive places to live; and
• support the promotion of health and wellbeing by making provision for physical activity.'

• Planning Policy Guidance Note 3: Housing (PPG3) is clear in its requirements that:

"Local authorities should plan to meet the requirements of the whole community, including those with 'special needs'. Amongst the 'specific groups' whose needs should be assessed and planned for are 'the elderly'." (My underlining)

• There are several other Government policy documents which have addressed the needs of older people. For example, Quality and Choice for Older People's Housing (DETR 2001) says:

"The increasingly older population poses a challenge for social policy generally and housing policy specifically."

• More recently the Green Paper "Opportunity Age" (Department of Health 2005) sets out the key principles of the Government's strategic approach towards older people, including:

• promoting their well-being and independence and providing them with choice and accessibility;
• tackling discrimination against older people;
• ensuring that local authorities take a lead role in planning for the ageing of their community

• The lack of any reference to this specialised housing sector in the evidence-based supporting documents, results in the CS paragraphs 5.7 - 5.12 also making no mention of providing for this sector.

• It is our view that specific recognition of this housing sector should be made in this section of the CS and that aims and objectives should plan for its expansion directing development to appropriate areas. We believe that this should include provision for the expansion and re-development of Housing, Chalets, Caravan and mobile home parks where these cater for those who are retired, semi-retired and elderly.

• We reiterate our concern that new policy should provide for a flexible response to emerging and as yet, unidentified market sectors. This is particularly important in order to secure an enhanced and buoyant tourist and leisure-based economy for Rother for the lifetime of the Development Framework and beyond.

• EMPLOYMENT: The preferred spatial strategy makes no mention of the promotion and growth of tourism and leisure industry within rural and coastal settlements such as Camber. Although Camber is specifically recognised as having an established and particular tourism niche by virtue of its natural assets; the way in which the changing patterns of tourist and visitor ambition is to be accommodated is not examined or catered for.

• As already stated, Draft PPS4 requires Local Planning Authorities to support and encourage business expansion where it is sustainable and can be balanced with environmental factors. This expressly includes those within rural areas.

• In paragraph 32, PPS4 states:

"In rural areas, recognising that accessibility - whether by private transport, public transport, walking and cycling - is a key consideration, local planning authorities should:

• Recognise that a site may be an acceptable location for development even though it may not be readily accessible by public transport;

• Support small-scale economic development where it provides the most sustainable option in villages that are remote from, and have poor transport links with, local service centres."

• At Camber, the long-established holiday parks are businesses which contribute significantly to the local economy. Indeed, they are the principle reason for the growth of the settlement itself. Specifically the Pontins Holiday Park employs 250 people (most local) with a significant multiplier for locally-based secondary employment.

• This ranks the holiday park as one of the District's major employers. We find it odd that the policy documents fail fully to recognise the value of the tourism and leisure industry as a driver to economic prosperity that plays a pivotal role in the overall Spatial Development Strategy. That this role should be encouraged to expand and achieve its full potential is without question what is required in draft PPS4