My Company has been instructed to act for Mr. John Matthews, who owns and operates Orchard Farm, London Road, Hurst Green TN19 7QS. It is considered that my client's land should be allocated for residential development in your draft local plan. Indeed, since, being a brownfield site, then it is just the sort of land that the Council should be looking to develop in order to meet its requirements.

I have considered the contents of the draft local plan and set out my representations below.

Site location and description

Orchard Farm is situated on the eastern side of the A21, a short distance north of its junction with the A229. It comprises a farm shop and nursery business, together with a café, cold store and other commercial uses. Overall, the floorspace of these buildings - which are single storey-is approximately 900sq. metres. There is a large car park at the front of the buildings, with an extensive frontage onto the A21. The land adjacent to the buildings is used for open storage. The site has an overall area of around 1.2ha.

Justification for the allocation of Orchard Farm for residential development

It is clear from the draft D&AS that the Council's overall requirement for the plan period is at least (my emphasis) 5,700 dwellings. Unfortunately, it appears that the Council has no intention of doing anything other than providing the bare minimum of housing - and this is at a time when there is a local, regional and national need for housing provision to be increased.

The details of this site were submitted in response to your earlier "call for sites". Despite the fact that it comprises a brownfield site, you decided not to allocate it on the grounds that it was in an unsustainable location. This decision ignored the fact that Hurst Green had been identified in your Core Strategy as a Local Service Village, due to its good array of services. The site itself is a relatively short distance away from the village and lies on the A21 - which is well-served by public transport.

The site has also been subject to pre-application discussions. However, at that time, the economics of running the business and the lack of interest in the site from other commercial operators was simply ignored. In these circumstances I need to inform you that my client wishes to put forward an alternative suggestion for development.

In order to retain commercial activity on the site, it is now proposed that one alternative would be to develop only half of the site for residential development, and continue to operate the existing business from the remaining part of the site. This would hopefully improve the viability of the business - and provide some much-needed housing on the other part of this brownfield site.

Alternatively, you could always allocate the whole site for residential use. However, the proposal above would meet with your preference for retaining commercial premises in the countryside.

I would therefore ask that you seriously consider both proposals.

At this stage, my client has not produced a draft layout. Nevertheless, on the basis of the site area, it is suggested that around 20 dwellings could be provided on the whole site, or around 10-12 on half of the site.
It is a fact that you need to allocate greenfield land from within the AONB in order to meet your housing requirements. In these circumstances, it would surely be appropriate to make use of brownfield sites, rather than rely solely on undeveloped land. In answer to Question 71 in the draft D&AS, it is submitted that the land at Orchard Farm should also be allocated for development. After all, the Council does not have a five year supply of land for housing, whilst it also needs to demonstrate that it is proposing to do more than simply meet its minimum housing requirements.

In these circumstances, it is requested that my client's site be allocated.

A plan of the site is attached. If you require any further information, then please contact me.

Additional supporting information was supplied which can be viewed here:

https://www.rother.gov.uk/icm/mediaaccess.cfm?CFID=6400feb4-9dda-4a01-841e-09d99cf4611e&CFTOKEN=0&file=pdf/a/7/Orchard_Farm__Hurst_Green_Location_plan_16_February_2017.pdf