Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21323

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils revised Fig.12 continues to lack the evidence base/appropriate analysis of the Rural Hierarchy and continues to fail to meet overall housing needs.

The Council apply an across the board increase in housing without the proper Landscape/Sustainability appraisals.

The Councils SHLAA review(2013)continues to rely upon evidence that is out of date/inappropriate. Analysis was often quite sweeping/often contrary/with no justification.

The Council should review its Housing Needs Survey(2005) and identify Robertsbridge as a new Sub Area.

The Council do not have evidence that would suggest only 100 new dwellings would be justified over the next 15 years i.e. 10pa

Full text:

The Councils revised Figure 12 Distribution of Rural Housing continues to lack the evidence base or appropriate analysis of the Rural Hierarchy of the Rural Area and hence continues to fail in its obligation to distribute the housing numbers capable of meeting the Districts overall housing needs.

The Rural Areas objectives (Para 12.6 Local Plan) sets out to "promote thriving rural communities"; to be demographically balanced and socially inclusive, particularly in terms of access to housing " and support sustainable local employment opportunities and the economic viability of rural communities"

Robertsbridge is classified by the Rural Settlement Study as a Rural Service Centre. It is the largest settlement in the "Rural Area",it has a mainline station,a secondary school and immediate access onto the main A21 trunk road. This has to be compared to Ticehurst and Northiam villages which have no station and no secondary school yet now has proposed a further increase in new housing from the deposit Plan of 58% and 105% respectively. The Council appear to have applied an across the board increase in housing to various villages without the proper Landscape and Sustainability appraisals.

Due to the unique characteristic of Robertsbridge and its location in the northern part of the District the settlement should be recognised as a new Sub-Area Structure. This would produce greater information and accuracy upon housing affordability and need in this area. This new Sub-Area would rightly highlight the role of this settlement strategically and identify a greater housing need and establish its economic role and potential in the District.

The Councils Spatial Development Options highlighted in the Rural Settlement Study gave a clear steer, directing development towards service centres e.g. Robertsbridge. This objective continues not to be properly investigated by the Council.

The Councils SHLAA review(2013)continues to rely upon evidence that is out of date or inappropriate i.e. landscape assessments made on SHLAA sites are based upon a study inappropriate to assess the capacity of various settlements to accommodate further housing. The Landscape studies undertaken in 2008/9 were so broad that the assessment of individual sites could not be properly considered. The study's analysis was often quite sweeping and often contrary views were expressed with no explicit justification.

With particular reference to the landscape assessment of Robertsbridge the landscape zones appeared to be arbitrarily defined with little obvious rationale and given the importance of the AONB lacked basic details, such as contours and landforms which do not appear to have played any part in the definitions of the zones. Given that over 80% of Rother falls within the AONB any landscape assessment should include a consideration of capacity especially if the Council wishes to meet its District housing need.

A Rural Settlement Study should properly set out the basis for a sustainable housing distribution hierarchy based upon services and facilities available and the role of individual settlements within the Rural Area.

The Council should also update and review its Housing Needs Survey(2005) and rightly identify Robertsbridge as a new Sub Area Structure with its immediate rural hinterland i.e. Salehurst, Hurst Green and Burwash (this may of course include other settlements across the Tunbridge Wells border).

Subject to a proper Landscape Capacity Assessment Robertsbridge is clearly a sustainable settlement occupying a strategic location in the northern part of the District with excellent accessibility to varying modes of transport(A21 and mainline station) offering great potential for economic growth. The Council currently do not have the evidence available that would suggest only a further 100 new dwellings would be justified over the next 15 years i.e. 10pa

When you compare this figure against that proposed for Battle (a settlement also in the AONB)of 500 this represents a 10% increase on its current population. A similar 10% increase for Robertbridge would yield a figure of 234 new homes over the plan period. The submitted SHLAA sites suggest this figure could be achieved without significant harm to the village setting in the AONB.

Further supporting evidence submitted can be accessed here:
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