Summary
1. Our representations to Policy RA1 are in part covered in our representations to
OSS1, in terms of the overall scale of housing to be provided in the rural parts of
the District, and in respect of the lack of clarity/consistency regarding the
application of the settlement hierarchy in Figure 9.
2. In addition, as part of these submissions, we consider the appropriateness or
otherwise of the specific provisions of Table 12, and whether its provisions are
adequately justified or contain an appropriate level of flexibility in the absence of a specific justification.
3. We also consider the practicalities of the delivery of community facilities in rural
areas.
4. We illustrate our arguments by reference to our client's interest in land on the east side of Northiam and the feedback our clients received from meeting the local
Parish Council Member.
Representations
5. Our representations on the overall scale of housing provision for the rural areas
are set out in our submissions to Policy OSS1. In short, and irrespective of the
overall level of housing provision for the District, the available evidence seems to
support the retention of the higher rate of growth for the rural areas set out in
previous iterations of the Core Strategy, and there is no substantive case that we
have seen that explains why, in this iteration of the Core Strategy, the scale of
growth in the rural areas is reduced.
6. We have also set out in our submissions to Policy OSS1 our concern that the
settlement hierarchy presented in Table 9 is not carried through in to Core
Strategy policy, with neither OSS1 nor RA1 providing a mechanism by which the
settlement hierarchy can effectively be enacted.
7. We have also noted in our submissions to OSS1 that Table 12 does not actually
reflect the settlement hierarchy in Table 9 that closely.
8. We are also concerned that there is an apparent absence of evidence to support the very detailed figures included within Appendix 12, and no clear rationale as to why, for example, any particular village is identified to have new allocations of 10, 15, 20, 25 etc or some other scale of new development.
9. We would assume that the actual scale of development at any particular village
would be determined as a result of a site allocations process (or perhaps a
Neighbourhood Plan?), with the principle role of the Core Strategy being to dictate
the basis of the distribution based on the overall settlement hierarchy (i.e. Figure
9), rather than to make allocations for specific villages.
In the light of all of the above, it would seem that Table 12 is adding a substantial
element of apparently unjustified policy, is failing to implement the identified
settlement hierarchy, and is potentially constraining otherwise acceptable growth
in the rural areas, all of which suggests that one possible remedy for the Core
Strategy to overcome these issues may be to simply delete Table 12, and for RA1
to cross-refer at part (v) to Table 9 in the alternative.
11. If Table 12 is to be retained, then we have significant concerns regarding the use of "min" and "max" notations against the ranges of development given. At this
stage, and in advance of any consideration of site specific opportunities, it would
be entirely inappropriate for the Core Strategy to set maximum development
figures. In the alternative, these references could be deleted in favour of a more
generic "indicative scale".
12. In our representations to the Strategic Vision, we queried how enhanced services would be delivered in the rural areas, in the current climate of funding. In many cases, it is through new development that rural services are retained and new services provided. In order to provide an effective policy to actually stimulate the provision of rural services in a pro-active manner, we consider that criterion (iv) of RA1 needs to be amended to include an additional clause at the end, stating that the provision of new or enhanced rural services delivered in conjunction with new development will be supported and encouraged.
13. Our clients have an interest in land on the eastern side of Northiam, one of the
Key Service Villages identified in Figure 9, and referred to in the Draft Rural
Settlements Study as having "all of the characteristics of a viable and sustainable
community". In the previous iteration of the Core Strategy, the number of new
allocations was proposed at 10-50 units, compared to the current draft of the Core
Strategy which send 15-35. There is no substantive evidence to say that 35 units
is suitable, but that 40, 45, or 50 new units is not, and the current draft of the Core Strategy is setting an artificial limit without any justification, and without reference to national policy designed to encourage the delivery of new homes in sustainable locations.
14. Our client's proposals for their land interest could potentially deliver the entirety of that allocation, whilst at the same time making provision for enhanced community facilities, enhanced recreation provision, much needed affordable housing, and meeting a local market need for new housing. It is wholly inappropriate for the Core Strategy to be pre-empting such site specific considerations by setting arbitrary development maximums.
15. It is only through new development such as proposed by my clients for Northiam that rural communities can be sustained, and the objectives of the Spatial Vision achieved, and it is essential therefore that, within the overall framework of the quantum of dwellings to be provided within the rural areas, and the settlement hierarchy set out in Figure 9, the Core Strategy should not be fettering site specific development proposals.
16. Further to discussions with the local Parish Council Member for Northiam, the
land in our client's control (on the eastern side of Northiam) offers the opportunity
to assist Northiam become a more mixed and balanced community. New housing including much needed affordable housing, will provide greater opportunities to
keep younger people in the village. Further, land on the east of Northiam also
has the potential to accommodate other community benefits such as public open
space. It is understood that the local community of Northiam would welcome a
new community shop to help the prosperity of the village. Persimmon Homes will
continue with their dialogue with the local community to see whether a new
neighbourhood could be brought forward to meet existing needs of the village of
Northiam.