Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21553

Received: 27/09/2013

Respondent: Mr & Miss Parker

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The methodology for increasing housing numbers in villages is flawed/unsound/unrelated to policy considerations.

The NPPF states (para 54)that in rural areas lpa's should plan housing development to reflect local needs. No local needs analysis was undertaken.

The village housing numbers conflict with national policy as it seeks to impose a prescriptive amount of development which is unrelated to the needs in order to bind the villages to these levels of growth.

The proposed housing allocation (Catsfield)is unsound. The existing size was assessed in 2008 as 133 households. The level of growth proposed over the plan (64)is too high and disproportionate.

Full text:

The proposal to increase housing numbers in the villages conflicts with the NPPF and with the spatial and strategic policy objectives of the district which are unmodified.

The methodology leading to the increase in housing numbers in the villages is fundamentally flawed and unsound and wholly unrelated to policy considerations. The decision to increase housing numbers in the villages is driven exclusively by the objective of spreading the district-wide 5700 unit number.

The NPPF states at paragraph 54 that in rural areas local planning authorities should plan housing development to reflect local needs. The Local Plan Strategy spatial and strategic policy conforms with this NPPF policy. This policy has not been modified. The level of growth and the location of growth must be policy-led. Only if the level of development proposed in any village was unreflective of its local needs could a modification to its individual allocation have been justified. However, no local needs based analysis was undertaken or affected the modifications decision.

Further, the modification to village housing numbers conflicts with national policy on localism and neighbourhood planning as the Council seeks to impose a prescriptive amount of development on individual villages which is unrelated to the villages' needs in order to bind the villages at the Neighbourhood Planning stage to these levels of growth. This means a village would be compelled to provide for an amount of housing development unrelated to its local needs, in conflict with NPPF paragraph 54 and with Local Plan strategic policy, were it to comply with NPPF paragraph 184 on the amount of development. This illustrates why the modifications are unsound.

With specific regard to Catsfield, there is an additional policy reason why the proposed housing allocation is unsound. The existing settlement size was assessed in 2008 in the village settlements study as 133 households meaning it is a small village in Rother District. Plainly, the level of growth proposed for Catsfield over the plan period - 64 dwellings - is far too high and wholly disproportionate to the size of the existing settlement. An important caveat to the identification of Catsfield as a "local service" village was provided at paragraph 12.15 of the Local Plan Strategy and this text has not been deleted. This text led to the original allocation of the 7-37 range for Catsfield in Figure 12, allowing Catsfield to plan within this range for the number of dwellings required to meet its local needs, insofar as this is proportionate to its existing size and character. It is not possible for the Council to renegue upon this undertaking now, given the settlement hierarchy was consulted upon with this important caveat in place and relied upon, and in any case the undertaking is retained unmodified.