Insert Paragraph 7.36 refers to the SHLAA Review undertaken in 2013. The Councils review is both limited and flawed.

The Council rightly qualify its SHLAA by its limitation to available information (no update of landscape assessment since 2008/9 and no landscape capacity study) "and for the most part, draws on local knowledge of Town & Parish representatives" (para 12 Summary of Sustainable Housing Growth July 2013) but acknowledge that all sites require further investigations. In practice little to no addition evidence has been provided to justify the arbitrary capacity restrictions to settlements such as Robertbridge. This town is the largest of the Rural Settlements with excellent transport links, facilities and employment. It is therefore capable of accommodating greater housing numbers beyond the 100 units proposed when compared to Battle(500). Both settlements fall within AONB. On a pure population comparison between these two settlements Robertsbridge should be capable of delivering around 200 additional dwellings subject to an appropriate landscape capacity assessment.

The Council previously in 2010 prepared their first SHLAA which rejected Land at Bishops Lane, Robertsbridge as a suitable housing site due to landscape and access constraints. At the last Examination the Council confirmed its intention to review it SHLAA which it did in 2013.It accepted at the Inquiry following submissions from our landscape consultant reports in 2007 and 2010(David Huskisson Assoc)that a review of the landscape capacity of the sustainable settlements would be undertaken. This has not been done and no evidence has been submitted to justify the Councils latest assessment of this site or others within the SHLAA. The Inspectors letter to the Council on the 7th May 2013 states that it is important to recognise that the NPPF requires authorities to meet the full objectively assessed needs for housing."Conflict with other policies in the Framework is not a reason to reduce the starting point of the full objectively assessed need". The Council cite on several occasions as a constraint the AONB. Paragraph 115 of the NPPF indicates that great weight should be given to conserving landscape and scenic beauty in AONBs. It does not, however, include a presumption against development in an AONB and paragraph 19 and 28 seeks to support a prosperous rural economy.

The SHLAA review appears to meet only the housing figure set out in the Modification Plan and not the capacity of the District as a whole.

Further submitted documents to support this representation can be accessed using the following links:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567