Figure 12: Distribution of rural housing allocations
MOD 12.5- Housing Allocations at Netherfield

1. These representations (TCPS Representations No. 5) relate to Rother District Council's proposed modification to the distribution of rural housing allocations as set out in Modified Figure 12 (MOD 12.5). These representations should also be read in conjunction with TCPS Representations nos. 2 - 4, which made the case that housing provision in villages could be modified to provide at least 1,672 dwellings and that Figure 12 should be deleted or the proposed housing allocation figures should be for illustrative purposes only in order to avoid prejudicing consideration of all potential housing sites as part of the forthcoming site allocations/neighbourhood planning process. In particular, paragraph 4 of TCPS Representations No. 4 indicates that there are examples where the Council's updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) is open to challenge as individual site potential cannot be properly assessed or open to scrutiny without the detailed site allocations process being undertaken as Part 2 of the Local Plan.

2. These representations (i.e. TCPS Representations No. 5) provide an example of potential housing land at Netherfield, which has up to now, been discounted in both the March 2010 and June 2013 versions of the Council's SHLAA. These representations relate to site no. NE2 in both versions of the SHLAA (see relevant SHLAA extracts contained in appendix 1).

3. In 2010, the Council considered the land to be poorly related to the existing built up area boundary and that other sites in Netherfield were preferable whilst in the 2013 update, the Council have added concerns about landscape views into and out of the site and potential ecology issues.

4. The Council's Rural Settlement Study (see extract contained in appendix 2) sets out the 'function' of Netherfield (which includes an assessment of local facilities and services) and its proximity to the nearby town of Battle, which is "within a five minute drive-time". The analysis indicates that there is a need for affordable housing and that there may be potential for allocation of up to 15 dwellings by 2026. Thus, although a relatively small rural settlement, it has a good range of local facilities for its size (which includes primary school and bus services) and effectively forms a satellite settlement for the higher order town of Battle (which has secondary schools, a mainline railway station, good range of retail facilities and employment provision).

5. The land the subject of site NE2 in both versions of the Council's SHLAA is not 'poorly related to the existing built up area boundary', as it is located immediately adjacent to it as shown by the annotated version of the Local Plan Inset Map no. 24 contained in appendix 3. Public views into the site are almost entirely screened by existing development and by the local topography. While to the north there is an area of ancient woodland, this is some distance away from the site and would not be adversely affected by any development proposals. Furthermore, any ecological impact could be satisfactorily mitigated on site.

6. Drawing no. 4376/1/A (contained in appendix 4) illustrates how the site might be developed to provide around 66, two, three and four bedroom dwellings including 40% (26 - 27 units) affordable accommodation. Other elements of the illustrative layout show;

i. A potential expansion of the playing field serving Netherfield C of E Primary School (which is located immediately adjacent to the site to the west) in exchange for a footpath/cycle link to the village school and shop/post office;

ii. The expansion of the village recreation ground which is located immediately to the east of the site, together with the provision of additional public car parking;

iii. The provision of amenity landscape buffers to the rear of properties that front onto Netherfield Road to the south of the site;

iv. The retention and reinforcement of existing woodland within the northern part of the site to include the retention and expansion of an existing watercourse to create a wetland habitat or expanded pond;

v. Additional woodland planting to provide a substantial landscape buffer between the potential housing area and the ancient woodland located further to the north of the site.

7. Appendix 5 contains a Transport and Sustainability Appraisal, which demonstrates how suitable access can be achieved and the alternative modes of transport available. The development of the land would not only provide potential for expanding the school playing field, but also the housing development itself would help sustain the school numbers and ensure its continued viability as a community asset. The existing school role figures indicate that there is currently projected spare capacity (see the figures contained in appendix 6).

8. lt is fully appreciated that it is not the role of the Core Strategy to identify individual housing sites, as this will be the purpose and function of a Site Allocations Plan (or Neighbourhood Plan) in due course. The point is however, that this land clearly has potential to provide a wide range of community benefits including affordable housing and a further assessment of its potential as part of the site allocations/neighbourhood planning process should not be prejudiced by either the updated SHLAA assessment (which is not a policy document) or as importantly, the housing allocation figures currently contained in Modified Figure 12 of the Core Strategy. Furthermore, the modified housing allocation figures should not prejudice a proper assessment of alternative sites at Netherfield at the later site allocations/neighbourhood planning stage.

9. At present, modified Table 12 indicates that Netherfield has potential for
48 dwellings on 'New Sites' (column 4). This appears to relates to SHLAA (2013) sites NE1, NE5A and NE11, but as also indicated in the SHLAA assessment (contained in appendix 1 attached) this land also has various constraints listed including the availability of a suitable means of access. No doubt this land will be the subject of further investigation at the site allocations/neighbourhood planning stage, but this land should also be examined in the context of the considerable public benefit that could arise if the land the subject of NE2 were to be developed instead. Sites NE1, NE5A and NE11 (if actually available and deliverable) would not offer the range of community benefits as identified by the illustrative layout contained in appendix 4 attached and this was not available to the Council at the time it produced either its original SHLAA in March 2010 or its updated SHLAA in June 2013.
Supplementary information submitted with the representation can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20687