The relative importance of historic farm buildings in Rother District is overstated in the PSCS, as they are no different from similar historic farm buildings found elsewhere in the County, region and country as a whole. There is no national or regional policy that resists the conversion of such buildings for residential use and the proposed local Rother requirement for priority to be given to conversion for affordable housing only is wholly misconceived on a number of grounds.

The costs of converting traditional farm buildings (and in particular listed buildings) would not be viable for use as affordable housing. There is no evidence that registered social housing providers would be willing to take on such schemes or willing to finance or maintain such housing, as is invariably such buildings are likely to relate to individual properties in relatively isolated rural locations away from main settlements and services.

Part (iii) (b) of Policy RA3 and part (i) of Policy RA4 are not consistent with any national planning guidance contained in PPS3, PPS4 or PPS7 and is inconsistent with the emerging National Planning Framework Document (see paragraph 113). There are no policies in the South East Plan (which remains part of the Statutory Development Plan) to justify such a tight control over potential residential use of rural buildings. Indeed, the highly restricted nature of the policy flies in the face of Government announcements relating to the potential relaxation of controls regarding the re-use of commercial buildings (see for example the recent consultation on proposals to amend the Use Classes Order in this respect and also the March 2011 HM Treasury report "The Plan for Growth", paragraphs 1.34, 2.22 - 2.23 and page 49). These elements of draft Policies RA3 and RA4 should therefore, be deleted or substantially revised in relation to open market residential re-use of rural buildings.