Reason for replying: Local resident and landowner directed affected by the development.

Full representation:

While I welcome BRO1 in general, I believe that requirements iii. and v. should be amended. My reasons for believing this are as follows.

I believe that the scale of the proposed 15 metre buffer zone adjacent to the Ancient Woodland seems excessive, although I welcome the provision of a buffer zone of indigenous species in general. Given that the Ancient Woodland in question has been recently coppiced and is already bounded by a footpath and existing trees (which should be retained), I question whether a buffer zone extending to 15 metres is necessary.

In relation to section iii. and the provision of allotments on the site, especially in the proposed area, there are several issues which would make this undesirable and potentially a retrograde step.

One issue is that there are horticultural reasons why the area identified for allotments would be a poor location for their provision. These reasons are primarily that the area of land in question is characterised by a thin layer of poor quality topsoil above a deep layer of Wealden clay and by being predominantly in shadow for most of the day due to the surrounding trees (the retention of which for screening purposes is suggested in BRO1). As a result this area constitutes a poor horticultural area for growing plants and it is likely that better quality land for allotments could be found elsewhere within the village.

It is also worth noting that there are now alternative, sustainable technologies for horticulture - such as wall gardens and hydroponics/aquaponics - which may be preferable as a more space-efficient and sustainable alternative to provision the traditional lateral sprawl of allotments

Another issue is whether the allocation of this area for allotments would represent the best use of the land in terms of the considerations identified within local planning policies contained in the adopted Core Strategy.

Policy RA1 section (ii) highlights that the encouragement of high quality economic growth and the provision of local job opportunities should be particularly focused on a number of specifically identified villages. Broad Oak is one of the villages identified for this policy. Section (ii) further states that this should, in part, be achieved by provision of opportunities for employment being sought alongside new housing in mixed-use developments. The need to provide rural employment opportunities is also identified in policy RA2 section (v).

In light of these policies I would question why potential provision of employment opportunities has apparently not been considered in the development of BRO1 and suggest that, given the scale of proposed development, this site would represent the best opportunity for the provision of such opportunities within Broad Oak and that this should be considered a higher priority for this site than the provision of allotments given that allotments could more easily be provided elsewhere within the village than employment opportunities could.

It is also worth noting that the importance of the requirement for the provision of employment opportunities within Broad Oak is reiterated within the approved Rural Settlements Study which states, in relation to Brede parish, that "Very low job provision and high reliance on car suggests
need for employment development if housing growth in the parish. However, it is important to note that Broad Oak has the more significant service role in the Parish and may therefore be the preferable location for new employment."

Another issue is that the provision of allotments on the site could also limit the potential for provision of ammenity greenspace on the site - a requirement for which is also identified for Broad Oak within policy AGS 2. This also highlights Broad Oak as the only settlement in East Rother without amenity greenspace provision.

I therefore believe that the provision of allotments on on site BO16 would not be desriable and I would suggest that consideration be given as to whether there are better potential uses for the site other than allotment provision as part of its development. For instance, it might be preferable to use part of the site for local employment provision and to use pooled contributions from all developments in Broad Oak to potentially fund allotments and/or other greenspace or community amenities elsewhere in the village - possibly on a dedicated site.