Summary
1. Our concerns in respect of the Spatial Vision are essentially threefold:
(1) There is a 'disconnect' between the aspiration in the Vision to enhance
access to jobs and services in the rural areas (such as Northiam) and the
policies included elsewhere in the Plan, which would serve to frustrate that
objective, and which render the Vision ineffective/undeliverable;
(2) There is a lack of clarity in the Spatial Vision as to the Council's objective
for new housing, which will render the Vision/Core Strategy ineffective;
(3) The Vision offers no clear direction for the Villages, which will render it
ineffective.
Representations
2. The vision refers to an aspiration that by 2028 "economic and social well-being
has been facilitated by better access to jobs and services, in both urban and rural
areas", but there is no explanation in the Vision as to how this is to be achieved,
nor is there any clear mechanism set by policies elsewhere in the Core Strategy
as to how this element of the Vision is to be achieved.
3. So for example, the Core Strategy contains a policy CO1 which seeks to promote the availability of Community Facilities. The supporting text refers to "maximising opportunities to access community facilities" and the particular importance of community facilities in the rural areas. But since as a rule there is little or no public funding to deliver new or enhanced community facilities, there is no means by which the aspirations of this policy or its equivalent statement in the Strategic
Vision can actually be achieved. Our objection to CO1 in respect of this aspect is
therefore the same as our objection to the Spatial Vision - how is the policy to be
delivered?
4. Delivering and sustaining services in rural areas is dependent upon ensuring that
there are vibrant communities to sustain those services. The Core Strategy itself
identifies the demographic 'time bomb' that the District faces, with generally an
aging population, a characteristic often accentuated in the rural areas. Services
will not be maintained by positive statements in plans, and there is a need for the
Core Strategy to include more pro-active measures to encouraged balanced and
mixed growth in the rural areas to support sustainable communities. New
development is often the catalyst to enhancing existing services and indeed
restoring lost village services, and our clients proposals for Northiam are a case in
point (see our separate submissions to Chapter 12 of the Core Strategy).
5. The Draft National Planning Policy Framework outlines the Government's
commitment to sustainable economic growth. With specific regard to rural
economies planning policies should take a positive approach to new
development1.
6. It should also be noted that the NPPF states that in rural areas LPAs should
consider whether allowing some market housing would facilitate the provision of
additional affordable housing to meet local needs2.
7. Although we do not disagree with the objective of encouraging better access to
jobs and services in the rural areas as part of the Spatial Vision, the Core
Strategy overall offers no practical means to achieve this, and therefore the
Spatial Vision will be ineffective and undeliverable.
8. The Vision makes no explicit recognition of the substantive need to deliver new
housing to meet local needs. The 5th paragraph refers to "Development and
change has contributed significantly to meeting local needs", but it is unclear as to
what "local needs" this particular paragraph is referring to, and there is no mention of meeting the need for housing (for all sections of the community) anywhere else in the Vision.
9. If paragraph 5 is intended to refer to or encompass meeting housing needs, then it is in any event extremely unclear as to what the Vision actually entails. The first part of the paragraph refers to "meeting local needs and aspirations", but the two are not necessarily the same thing, and in many cases the aspirations of some sections of the community can be very different to the needs of other sections of the community.
10. This paragraph goes on to state that meeting "local needs" will take account of
both "the district's circumstances, as well as to regional and sub-regional
imperatives". Again, on the face of it, this sentence is potentially contradictory in
nature, but essentially the problem is that the Vision is offering no clarity as to
what the Core Strategy is trying to achieve in terms of addressing 'local needs',
and therefore the result will be that the Core Strategy will be ineffectual and
undeliverable, because it has no clear Vision.
11. Finally, the Vision offers no clear direction for the Villages - it refers in the second to last paragraph to the character and diversity of villages being retained, but there is no differentiation between settlements types, and no real explanation as to what is meant by evolving "organically" - evolving in what way?