My Company has been instructed to act for Mr. and Mrs Whittaker, the owners of
Egmont Farm, Coppards Lane, Northiam regarding the submission of representations
on your draft local plan. They consider that their land should be allocated for residential development and that, moreover, there is substantial justification for this. I have visited their site, considered the contents of the draft local plan and set out my representations below.

Site location and description.
Egmont Farm is situated on the northern edge of the built up area of Northiam. It lies within a triangle of roads formed by the A28, the A268 and, to the south, Coppards Lane. The site comprises my clients house together with outbuildings that are used in connection with Mrs. Whittaker's equestrian business. The eastern part of the site contains stabling, together with an area of around 1 .2 ha. ( 3 acres ) that is used for the grazing of horses. The overall area of the site is 2ha.

There are dwellings along Coppards Lane to the south, together with industrial
premises at the eastern end of that road. These form part of the built-up area of
Northiam which extends in a southerly direction. To the north of my clients site there is a house and outbuildings.

Justification for the allocation of Egmont Farm for residential development.
It is considered that additional land needs to be identified at Northiam for residential
development. The draft plan shows that only one site for six dwellings is proposed for allocation, despite the fact that the Council describes Northiam as being 'one of the larger villages in the District and supports a wide range of services and facilities"
(paragraph 15.61.) Its justification for proposing the allocation of this one site for only six dwellings appears to be that just six dwellings are needed for the Council to meet its requirement as set out in the Core Strategy. However, that document states that the Council's overall provision for the plan period is at least (my emphasis) 5,700 dwellings. It is therefore clear that the Council has no intention of doing anything other than providing the bare minimum of housing -and at a time when there is a local, regional and national need for housing provision to be increased.

The Council has based its calculation on the need for just six dwellings on its opinion
that 52 dwellings will be provided on land at Goddens Gill. Nevertheless, this stance is fundamentally flawed. The facts of the matter are that permission here was granted for 52 dwellings in 2007, under application reference RR120061231 1/P. However, that permission was never implemented.

A further planning application, reference RR/201 0/1634/P was then submitted in 2010 as a replacement for the 2007 permission. That proposal comprised 32 dwellings for the elderly, one manager's flat and 19 affordable sheltered units. A condition attached to that permission (condition no.1) required the development to be started within three years, namely by 11th April 2014.

As that permission has now expired, the question must be asked as to whether the site is genuinely available and developable. Given that no development has taken place over the past ten years -and despite the very good market conditions since 2011- it is surprising that nothing has happened. In these circumstances the Council is surely wrong to rely on a twice-expired permission to comprise a major element of its housing land supply in Northiam. Against this background, therefore, it is contended that one or more additional allocations are required.

The Council has previously issued a "call for sites" and considered the sixteen
responses ( as listed in the Appendix to the draft Local Plan) that it received for land
at Northiam. Of these, it rejected fifteen for reasons such as poor access, impact on
the Conservation Area, loss of employment land as well as impact on the AONB. It is
considered that this last reason is difficult to justify, given that Northiam itself, like most of the District, lies within the AONB. It is thus a standard criticism that can be applied to all sites currently outside the built-up area of the village. Moreover, at a planning appeal in 2016 regarding land at Ticehurst, the Council acknowledged that, in order to meet its housing requirements, it would need to allocate land from within the AONB. In these circumstances, the location of a site within the AONB in itself does not constitute grounds for rejection.

The land at Egmont Farm was not submitted in response to the earlier call for sites.
This is therefore the first opportunity for the Council to consider it. At this stage in the process a specific area for development or amount of housing and any other detail, is not yet being submitted. It is considered that this can be subject to more detailed consideration involving the Parish Council and other appropriate organisations, as well as the District Council. Instead, and in these circumstances, it is requested that the Council carefully considers this opportunity in light of its location and limited visual impact on the surrounding area. Having rejected all but one of the sites previously put forward for consideration it is felt that the land at Egmont Farm should be allocated. The Council should also be aware of the fact that, in order to provide affordable housing, the 1066 Housing Association promoted part of this site for development in the year 2000. Although that proposal was supported by the County Council, it did not find favour with the Parish Council and therefore was not progressed. This nevertheless shows that two major organisations supported the principle of residential development on this land.

Response to Question 78.
In light of the arguments and information as set out above, my clients do not agree with the preferred site for development at Northiam. Instead, the land at Egmont Farm should be allocated for residential and associated development.

A plan of the site can be found here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28034