The Councils INSERT suggests that the assessment of the SHLAA review 2013 responds to "the need to maximise opportunities for sustainable growth" It also states that this proposed level of growth is supported by the most recent Sustainability Appraisal(SA)but highlights the increasing negative impacts of development on the character of both settlements and wider countryside. This last statement however lacks the evidence to substantiate such a claim as NO new landscape capacity assessment has been undertaken to establish at what point and at what level of housing does further housing allocations significantly impact on individual settlements.

As an example the previous SA (Nov 2008) considered a Scale of Growth under Option 2 SE Plan requirements +25% (350pa)which in general is comparable with the Councils current SA on Option B3 of the Councils target of 5700(335pa)in that the SA objective 15 " Protect and enhance the high quality natural and built environment..in particular the protection of the AONB assessed both these levels of development as neutral.
However, Option B4 of the current 2013 SA, which would meet the Councils housing needs(6180) under the same objective 15 test now suggests that an additional 480 dwellings(28pa) would lead to an (x)category assessment for the plan over the medium and long term i.e. "option appears to conflict with the objective and MAY (my emphasis) result in MINOR adverse effects" There is NO evidence to assess the landscape impacts of these options and therefore the SA assessment is not robust or justified.

The assessment of other objectives compared in the current SA suggest a lack of explanation between the differing negative marks set against Option B4 compared with those of B3 with many comments remaining the same even though B4 had more x,s against objectives 6,9,10,11.

Further supporting evidence submitted 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