Policy RA1: Villages

Point ii) Provide 10,00sqm employment space in accordance with the proposed Rural settlement hierarachy set out previously.

Point v) Increase the rural housing fiure to 2300 in accordance with SE Plan and the District historic housing provision over the next 20yrs.Also to distribute these housing in accordance with the Rural Sustainable Hierarachy giving greater proportion to those sustainable settlements like Robertsbridge.Amend Fig 12 to deliver this objective.

Item (ii) of the Policy should be revised to state that the encouragement of sustainable economic growth in the villages will firstly 'focus' mainly on the 2 Rural Service Centres, in particular Robertsbridge, because of its good connectivity, and secondly at appropriate levels in the smaller villages.

Item (v) of the Policy should be revised to increase the housing allocation for the villages from 1,000 to 1,250 in line with Representations Croudace have made elsewhere in relation to the Core Strategy consultation.

The RVR Robertsbridge to Bodiam re-connection project will preserve and restore the historic structures and features of a Rural Light Railway.

The omission of farm shops, garden centres etc which are part of the rural economy is not justified.

* RA1(v) proposes some 950-1,000 additional dwellings in villages over 2011-2028. In Para 12.13 the residual requirement is for additional allocations of 308-358 dwellings over the same period. The designation of Catsfield as a local service village is supported, as is its notation on the key diagram, as a settlement with development potential.

* The proposed new housing development for Catsfield is shown as a range in Fig 12 from 0 (low) to 30 (high) units. For Beckley / Four Oaks, it is from 10-10!. It is argued elsewhere that the rural housing allocation should be raised:

1) To bring the overall District target into line with the Regional Plan;

2) As a contingency in the event that the Link Road and associated development does not proceed; and

3) In addition, the Catsfield allocation is low for a designated settlement. Its allocation does not reflect the settlement's capacity for growth.

* There are 9 settlements in Fig 12 which are shown as having development potential on the key diagram but where there may be no development at all. It is recommended that instead, for all settlements, Fig 12 refers to providing 'up to x units'

My objection is two-fold:
1. I do not believe it is necessary to have a range of housing requirements for each village in Figure 12.
2. I believe the figures should be described as "up to" a certain level and for that level to be tested at the Site Allocation Stage in terms of the availability of further information in viability and sustainability factors.
3. I believe the Ticehurst housing figures are low.

No comment

Policy BA1(iv) relating to the enablement of new local employment opportunities by providing 10,000 sq.m. of employment floorspace refers to Marley Lane as one of the options for expansion for Battle. Technically the Marley Lane site sits within the Sedlescombe Parish boundary although as it is situated on the Battle side of the A21 there may well be an argument for it to be more formally subsumed into the Battle Town Council area. The A21 pesents both a physical and intellectual barrier with the Marley Lane site remaining remote from Sedlescombe Village.

Policy RA1(ii) supports the encouragement of high quality and sustainable economic growth in rural areas, Sedlescombe being one of those listed in Figure 10 as needing new employment floorspace. It would seem appropriate for any new employment floorspace for Sedlescombe to be located more conveniently to the village and its housing particularly as Appendix 5 of the Rural Settlements Study shows a ratio of 0.46 of in:out commuting for Sedlescombe and a need for local employment. There are sites that might be appropriate for this, e.g. on the current footprint of the unused buildings at the Pestalozzi Village, perhaps offering opportunities for small businesses focused on crafts related to the High Weald's agricultural heritage. This could also support policy CO4(ii) in providing accessible employment opportunities for young people.

We take issue with the soundness of the policy RA1 concerning distribution of housing numbers in villages figure 12.
With all this criteria in mind we fail to see how Northiam has the second highest housing allocation of 100 dwellings, second only to Robertsbridge, who have:-

 A main road access (A21)
 A main line station
 Many shops, business and employment opportunities
 A well serviced public transport network

There is a need for villages to have a community hub be it a new build or rebuild, where one can have a shop, pub, place of worship, CAB, young people's meeting place, coffee house for older people to meet to include to include activities, again under a Community Land Trust plan, this is to include accommodation for at least one family.

It is noted that Rother Valley has revised their housing projections to take into account the recession and the move to revoke Regional Spatial Strategies.

Paragraph 12:18 states that it is assumed existing local plan allocations (if deliverable) will form part of the housing trajectory for future development and will be developed in the early stages of the plan. This is reinforced by policy RA1: Villages. Section (v) states that housing provision in villages will be located in accordance with Figure 12 (which includes housing allocations). This approach is strongly supported as Local Plan allocations have been subject to detailed consideration and consultation through the Local Plan process.

Section (ii) of the Policy advocates the encouragement of high quality sustainable economic growth by the identification of sites for local job opportunities, particularly focussing on villages identified in figure 10. This policy is strongly supported.

Proposed policy RA1: Villages does not set out enough dwellings for the plan period 2011-2028 as the base figures do not reflect emerging national planning policy. In short, more housing is needed to serve the District and more housing, in excess of 1,000 dwellings, needs to be released on a scale which will not harm the Area of Outstanding Natural Beauty. There are sites close to the middle of the larger villages which can be released without harm to this national setting. The figures in Figure 12 need to be increased substantially.

This representation is prepared on behalf of Peer Group Plc and relates to land to the rear of 'Wardsdown House', Flimwell. Whilst it is acknowledged that site specific allocations will be dealt with through the Site Allocations Development Plan Document, a brochure document providing details of the site in terms of context, ecological issues, potential access and a landscape analysis, has been submitted to inform these representations and provide the Council with background information regarding the site.

The reasons why the respondent finds the Submission Document to be unsound are explored below, however the principle reason is:

* That the document is not justified in that it is not the most appropriate strategy when considered against reasonable alternatives;

For the purposes of distributing the housing development requirement of between 3,700 and 4,100 between 2011 and 2028, the Borough Council has divided the Core Strategy into 5 development areas; Bexhill, Hastings fringes, Battle, Rye and the villages. Villages are to take between 950 and 1,000 dwellings in the 2011-2028 period. This distribution hierarchy complies with national planning policy and is broadly supported.

Various studies (e.g. the draft Rother Rural Areas Strategy 2008) have addressed the issue of how the 1,000 or so dwellings for the village categories should be distributed. The option chosen within the Core Strategy is to concentrate firstly on the rural service centres of Ticehurst and Robertsbridge, and secondly on 7 local service centres. Whilst this is the approach taken in the Core Strategy, the document concedes at paragraph 12.15 that the approach it has taken is not absolute;

"the preferred spatial development option for the villages remains 'to primarily focus on the service centres', whilst taking into account other factors. Other factors include local needs, accessibility, environmental factors, local opportunities and whether growth levels are proportionate to settlement size over the course of the plan period. Thus, the service led 'rural function of settlements' (see Table 11.1) is not the sole criteria governing the spatial pattern of development. Moreover, a village's role can be fluid over time and some villages may still enjoy a reasonable level of facilities, although falling just outside the criteria to be defined a 'service village."

The Core Strategy goes on to make a very specific number allocation of units to each individual village, albeit steering clear of making specific site allocations. The only allocation to Flimwell is for 25 dwellings which relates to existing allocations on previously developed land contained within the Rother Local Plan. This plan was adopted in 2006 bus is based on earlier work back as far as January 2001 when the initial Deposit Plan was published.

It is the respondent's view that by stating that development in the rural areas should follow a table which allocates Flimwell only 25 units, and all in existing allocations dating back over 20 years, the Core Strategy is potentially overly restrictive. It is therefore not justified since the Council's strategy is not considered to be the most appropriate and the respondent's proposal provides a reasonable and deliverable alternative.

The Merits of the Respondent's Proposals

The respondent wishes to draw the Council's attention to the following matters in respect of Flimwell:

i) Flimwell is in the parish of Ticehurst which is one of the two rural service centres in Rother District. The two villages are almost connected as a result of unplanned ribbon development in the 20th Century - the western edge of Flimwell being only 1.5km from the village centre in Ticehurst. The Core Strategy places the highest priority on allocating land according to where rural services are most prevalent. The respondent considers that Flimwell's proximity to Ticehurst, when compared to various other villages in the District, means that to some extent it shares the benefits of the services available in Ticehurst and therefore makes it more sustainable than many of the other villages listed.

ii) The draft Rural Areas Strategy mentions that Flimwell performs well on accessibility criteria due to its location on the A21 trunk road, and that therefore the distribution of development within the parish of Ticehurst might be an issue to revisit when site-specific allocations are made in a future development plan document. Flimwell also has an hourly bus service to Ticehurst itself, then Wadhurst Station and onto Tunbridge Wells centre, adding to the sustainability credentials of the site.

iii) Furthermore, there is a possibility that the A21 Trunk Road will bypass Flimwell, which is one of only three villages not bypassed between Tonbridge and Hastings. The bypass route is safeguarded and construction would alter the setting of the village, bringing land east of the present A21 into the village envelope and also enabling a more focussed village centre to be created.

The broad options for the Core Strategy have been satisfactorily subject to sustainability appraisal at suitable stages in their evolution, however the Core Strategy goes beyond this to effectively freeze development in certain villages at current levels. It is considered that this would unreasonably constrain the possibilities for development at Flimwell during the Plan period. It is submitted that the sustainability evidence currently available is not conclusive at this site level of detail and that land to the rear of 'Wardsdown House', Flimwell, should be allocated for a small scale housing development.

This representation is prepared on behalf of Peer Group Plc and relates to land to the rear of 'Wardsdown House', Flimwell. Whilst it is acknowledged that site specific allocations will be dealt with through the Site Allocations Development Plan Document, a brochure document providing details of the site in terms of context, ecological issues, potential access and a landscape analysis, has been submitted to inform these representations and provide the Council with background information regarding the site.

The reasons why the respondent finds the Submission Document to be unsound are explored below, however the principle reason is:

* That the document is not justified in that it is not the most appropriate strategy when considered against reasonable alternatives;

For the purposes of distributing the housing development requirement of between 3,700 and 4,100 between 2011 and 2028, the Borough Council has divided the Core Strategy into 5 development areas; Bexhill, Hastings fringes, Battle, Rye and the villages. Villages are to take between 950 and 1,000 dwellings in the 2011-2028 period. This distribution hierarchy complies with national planning policy and is broadly supported.

Various studies (e.g. the draft Rother Rural Areas Strategy 2008) have addressed the issue of how the 1,000 or so dwellings for the village categories should be distributed. The option chosen within the Core Strategy is to concentrate firstly on the rural service centres of Ticehurst and Robertsbridge, and secondly on 7 local service centres. Whilst this is the approach taken in the Core Strategy, the document concedes at paragraph 12.15 that the approach it has taken is not absolute;

"the preferred spatial development option for the villages remains 'to primarily focus on the service centres', whilst taking into account other factors. Other factors include local needs, accessibility, environmental factors, local opportunities and whether growth levels are proportionate to settlement size over the course of the plan period. Thus, the service led 'rural function of settlements' (see Table 11.1) is not the sole criteria governing the spatial pattern of development. Moreover, a village's role can be fluid over time and some villages may still enjoy a reasonable level of facilities, although falling just outside the criteria to be defined a 'service village."

The Core Strategy goes on to make a very specific number allocation of units to each individual village, albeit steering clear of making specific site allocations. The only allocation to Flimwell is for 25 dwellings which relates to existing allocations on previously developed land contained within the Rother Local Plan. This plan was adopted in 2006 bus is based on earlier work back as far as January 2001 when the initial Deposit Plan was published.

It is the respondent's view that by stating that development in the rural areas should follow a table which allocates Flimwell only 25 units, and all in existing allocations dating back over 20 years, the Core Strategy is potentially overly restrictive. It is therefore not justified since the Council's strategy is not considered to be the most appropriate and the respondent's proposal provides a reasonable and deliverable alternative.

The Merits of the Respondent's Proposals

The respondent wishes to draw the Council's attention to the following matters in respect of Flimwell:

i) Flimwell is in the parish of Ticehurst which is one of the two rural service centres in Rother District. The two villages are almost connected as a result of unplanned ribbon development in the 20th Century - the western edge of Flimwell being only 1.5km from the village centre in Ticehurst. The Core Strategy places the highest priority on allocating land according to where rural services are most prevalent. The respondent considers that Flimwell's proximity to Ticehurst, when compared to various other villages in the District, means that to some extent it shares the benefits of the services available in Ticehurst and therefore makes it more sustainable than many of the other villages listed.

ii) The draft Rural Areas Strategy mentions that Flimwell performs well on accessibility criteria due to its location on the A21 trunk road, and that therefore the distribution of development within the parish of Ticehurst might be an issue to revisit when site-specific allocations are made in a future development plan document. Flimwell also has an hourly bus service to Ticehurst itself, then Wadhurst Station and onto Tunbridge Wells centre, adding to the sustainability credentials of the site.

iii) Furthermore, there is a possibility that the A21 Trunk Road will bypass Flimwell, which is one of only three villages not bypassed between Tonbridge and Hastings. The bypass route is safeguarded and construction would alter the setting of the village, bringing land east of the present A21 into the village envelope and also enabling a more focussed village centre to be created.

The broad options for the Core Strategy have been satisfactorily subject to sustainability appraisal at suitable stages in their evolution, however the Core Strategy goes beyond this to effectively freeze development in certain villages at current levels. It is considered that this would unreasonably constrain the possibilities for development at Flimwell during the Plan period. It is submitted that the sustainability evidence currently available is not conclusive at this site level of detail and that land to the rear of 'Wardsdown House', Flimwell, should be allocated for a small scale housing development.

Spatial Development Option
At paragraph 12.15 the Core Strategy confirms that the preferred spatial development option for the villages remains 'to primarily focus on the service centres', whilst taking into account other factors such as local needs, accessibility, environmental factors, local opportunities and whether growth levels are proportionate to settlement size over the course of the plan period.

In so far as this would provide support for new development in Ticehurst the approach is supported.

At paragraph 12.73 the Core Strategy recognises that opportunities to secure sensitive infilling and redevelopment within the development boundaries of Villages is limited and confirms that sites for development in and around villages will be identified through the Site Allocations DPD, which we have already made extensive representations on with regard to Banky Field. This approach is also supported and this element of the policy justified.

Housing Distribution
In order to meet housing needs and ensure the continued vitality of villages, Policy RA1 sets a housing provision of 950-1,000 additional dwellings (comprising both existing commitments and new allocations) in the villages of the district across the plan period.

Of this requirement, housing provision is specifically apportioned to Ticehurst as a rural service centre and a target of 35-55 new dwellings to help meet the overall target for the village area of the district. The planned provision for additional housing development in Ticehurst over the plan period is firmly supported, however Ticehurst is identified in the SHLAA as providing a deliverable supply of housing above the level set out in the policy. Banky Field itself is capable of providing at least 60 residential units. Ticehurst is well located in terms of transport networks and presents a range of services which denote its designation as a rural service centre. It is therefore considered that the village is fully capable of sustaining a higher level of housing development without prejudicing any environmental characteristics or amenity. An increase in supply at appropriate locations such as this would directly accord with the presumption in favour of sustainable development set out by Central Government and would contribute to the much needed sustainable economic growth for the district.

Employment Provision
Paragraph 12.22 refers to employment development in rural areas and states that the occupancy rate of business space in the rural areas is comparatively high. The Strategy and Land Review (ELR) compiled as background evidence to the Core Strategy suggests there is a need for new employment floorspace within Rother's rural areas with at least 10,000 sqm additional business floorspace required in rural localities, preferably within or at least well related to existing village development boundaries. New employment provision is identified as being most appropriately delivered in the form of sensitive expansion of existing area or as part of new mixed development sites.

Ticehurst is identified at Paragraph 12.24 as being a village in particular need of employment opportunities and as such, the need for appropriate levels of new housing as addressed above is clear in order to deliver sustainable growth to compliment employment growth.

Open Space and Sports Facilities Provision.
At Paragraph 12.33 the Core strategy refers to Open Space needs in rural areas and particularly refers to the Open Space, Sport & Recreation Study (2007) which suggests that in rural areas there is a shortage of children's play areas and amenity green space. In the west of the district's rural areas there is said to be a more localised deficit of outdoor sports facilities and allotments. Furthermore the Rural Settlements Strategy identifies Ticehurst specifically as requiring more outdoor sports facilities.

In order to address the needs of rural villages in this respect, Policy RA1 provides specific support for community, recreational and educational facilities that provide social and community benefits to villages.

The scale of land at Banky Field which is within one ownership provides significant scope for open space and play area provision alongside housing development whilst its proximity to Ticehurst Primary school provides the opportunity to secure improved open space provision for the school in the form of an additional sports pitch or similar as an extension to the school grounds. In short the site provides significant potential to secuire improved recreation and sports facilities that would be of benefit to the entire community in the village.

CPRE Sussex welcomes and strongly supports Policy RA1 on meeting the needs of rural villages, particularly the following criteria:

(i) Protection of the locally distinctive character of villages, historic buildings and settings, with the design of any new development being expected to include appropriate high quality response to local context and landscape;

(iii) Ensuring thriving and viable rural communities, by retention of, and support for, local shops and public houses in villages;

We suggest that for RSCs in particular you replace Policy RA1 (iii) with a far more positive proposal to support and sustain businesses within the RSCs. You have failed to be specific on what support would actually mean; we believe it should be positive in the sense of business rate support and should provide a protective planning framework to ensure that the high street areas are not diminished by allowing change of use applications to other than business use, unless very strict economic tests are passed.

Our suggestion would be that for RSCs at least there should be a policy which protects premises whose uses are currently employment and service generating, by resisting proposals to change the use unless the change of use or redevelopment provides suitable replacement or service generating employment opportunities. The only exception would be if there are demonstrably overwhelming economic reasons which indicate the current use is unsustainable.

We also suggest that encouragement should be given to any new build permission for live/work units, which recognise the fact that within Robertsbridge for example, there are at least forty businesses that operate out of people's houses and there needs to be a recognition in the strategy that provision of such accommodation is needed to create sustainable and vibrant RSCs.

1 Therefore there should be a separate policy for RSCs recognising their important rôle over and above the LSVs. The Policy RA1 is adequate for LSVs but not sufficiently robust for RSCs if they are to achieve what one assumes Rother planners would wish - that they retain and indeed expand their already vital employment base, that they continue to provide an adequate range of retail facilities including public houses and restaurants, and support a growing emphasis on rural tourism. This is quite apart from any desire on the strategy's part to place additional housing in the RSCs. Policy RA1 (v) rather bizarrely suggests that in order "to ensure the continued vitality of villages" (which include RSCs) there should be provision for additional dwellings. This could only happen if the sustainable infrastructure is maintained and enhanced, particularly in RSCs, so that "vitality" can be "continued" in villages.

Summary
1. Our representations to Policy RA1 are in part covered in our representations to
OSS1, in terms of the overall scale of housing to be provided in the rural parts of
the District, and in respect of the lack of clarity/consistency regarding the
application of the settlement hierarchy in Figure 9.
2. In addition, as part of these submissions, we consider the appropriateness or
otherwise of the specific provisions of Table 12, and whether its provisions are
adequately justified or contain an appropriate level of flexibility in the absence of a specific justification.
3. We also consider the practicalities of the delivery of community facilities in rural
areas.
4. We illustrate our arguments by reference to our client's interest in land on the east side of Northiam and the feedback our clients received from meeting the local
Parish Council Member.
Representations
5. Our representations on the overall scale of housing provision for the rural areas
are set out in our submissions to Policy OSS1. In short, and irrespective of the
overall level of housing provision for the District, the available evidence seems to
support the retention of the higher rate of growth for the rural areas set out in
previous iterations of the Core Strategy, and there is no substantive case that we
have seen that explains why, in this iteration of the Core Strategy, the scale of
growth in the rural areas is reduced.
6. We have also set out in our submissions to Policy OSS1 our concern that the
settlement hierarchy presented in Table 9 is not carried through in to Core
Strategy policy, with neither OSS1 nor RA1 providing a mechanism by which the
settlement hierarchy can effectively be enacted.
7. We have also noted in our submissions to OSS1 that Table 12 does not actually
reflect the settlement hierarchy in Table 9 that closely.
8. We are also concerned that there is an apparent absence of evidence to support the very detailed figures included within Appendix 12, and no clear rationale as to why, for example, any particular village is identified to have new allocations of 10, 15, 20, 25 etc or some other scale of new development.
9. We would assume that the actual scale of development at any particular village
would be determined as a result of a site allocations process (or perhaps a
Neighbourhood Plan?), with the principle role of the Core Strategy being to dictate
the basis of the distribution based on the overall settlement hierarchy (i.e. Figure
9), rather than to make allocations for specific villages.
In the light of all of the above, it would seem that Table 12 is adding a substantial
element of apparently unjustified policy, is failing to implement the identified
settlement hierarchy, and is potentially constraining otherwise acceptable growth
in the rural areas, all of which suggests that one possible remedy for the Core
Strategy to overcome these issues may be to simply delete Table 12, and for RA1
to cross-refer at part (v) to Table 9 in the alternative.
11. If Table 12 is to be retained, then we have significant concerns regarding the use of "min" and "max" notations against the ranges of development given. At this
stage, and in advance of any consideration of site specific opportunities, it would
be entirely inappropriate for the Core Strategy to set maximum development
figures. In the alternative, these references could be deleted in favour of a more
generic "indicative scale".
12. In our representations to the Strategic Vision, we queried how enhanced services would be delivered in the rural areas, in the current climate of funding. In many cases, it is through new development that rural services are retained and new services provided. In order to provide an effective policy to actually stimulate the provision of rural services in a pro-active manner, we consider that criterion (iv) of RA1 needs to be amended to include an additional clause at the end, stating that the provision of new or enhanced rural services delivered in conjunction with new development will be supported and encouraged.
13. Our clients have an interest in land on the eastern side of Northiam, one of the
Key Service Villages identified in Figure 9, and referred to in the Draft Rural
Settlements Study as having "all of the characteristics of a viable and sustainable
community". In the previous iteration of the Core Strategy, the number of new
allocations was proposed at 10-50 units, compared to the current draft of the Core
Strategy which send 15-35. There is no substantive evidence to say that 35 units
is suitable, but that 40, 45, or 50 new units is not, and the current draft of the Core Strategy is setting an artificial limit without any justification, and without reference to national policy designed to encourage the delivery of new homes in sustainable locations.
14. Our client's proposals for their land interest could potentially deliver the entirety of that allocation, whilst at the same time making provision for enhanced community facilities, enhanced recreation provision, much needed affordable housing, and meeting a local market need for new housing. It is wholly inappropriate for the Core Strategy to be pre-empting such site specific considerations by setting arbitrary development maximums.
15. It is only through new development such as proposed by my clients for Northiam that rural communities can be sustained, and the objectives of the Spatial Vision achieved, and it is essential therefore that, within the overall framework of the quantum of dwellings to be provided within the rural areas, and the settlement hierarchy set out in Figure 9, the Core Strategy should not be fettering site specific development proposals.
16. Further to discussions with the local Parish Council Member for Northiam, the
land in our client's control (on the eastern side of Northiam) offers the opportunity
to assist Northiam become a more mixed and balanced community. New housing including much needed affordable housing, will provide greater opportunities to
keep younger people in the village. Further, land on the east of Northiam also
has the potential to accommodate other community benefits such as public open
space. It is understood that the local community of Northiam would welcome a
new community shop to help the prosperity of the village. Persimmon Homes will
continue with their dialogue with the local community to see whether a new
neighbourhood could be brought forward to meet existing needs of the village of
Northiam.

Figure 12 (page 81) and Appendix 3 suggests that in years 10 - 15 of the Plan period (2023 - 2028) some 18% of the total housing supply in villages will come from small windfall sites (amounting to 118 dwellings). Given the considerable uncertainty of housing from this form of supply, the overall housing requirement in villages should be increased to provide a contingency against such windfall housing failing to materialise. If supply from this source were to materialise, then through annual monitoring, the release of allocated housing sites could then be held back for later release.

The range of 950 - 1,000 additional dwellings in villages (paragraph 12.13 and part (v) of the Policy) or the 975 dwelling mid-point (Appendix 3) implies a substantial reduction in the level of housing supply in rural settlements compared to the 20 year period between 1987 - 2007 when 2,300 dwellings were constructed (paragraph 12.14). This housing development has been achieved with little obvious detriment to villages or their rural settings and has been important in order to sustain village shops, public transport and community services as well as providing for housing choice and market-led affordable housing. There is insufficient justification given in the PSCS to support the claim (in paragraph 12.14) that the past rate of housing development "is an unsustainable trend", particularly in view of the high level of housing need within rural areas and the importance of rural settlements generally in contribution to overall housing supply in the District.

Broad development areas in Bexhill, Hastings Fringe, Battle, Rye and surrounding villages are identified within the Core Strategy. The scale of development in Bexhill is dependent on the delivery of the BHLR. In the event that the link road is not constructed we support the policies that set out that the level of development at Bexhill will be reduced.

We are pleased to note that proposals within the broad development areas include plans to improve sustainable transport links within and between urban centres. We welcome this approach as it could help reduce development impact on the SRN and is therefore welcomed.

Criterion iv of policy RA1 refers to the need to protect and enhance social infrastructure. This includes education although the goal of this criterion is to promote social and community provision. My client considers that education is an essential element of any community and particularly in Sedlescombe. The wording of criterion iv does not sufficiently reflect the importance of this provision and potentially could prevent the provision of such facilities being granted sufficient weight in the decision making process.

As a former local resident and a member of the family that provided the land that the local school was built on my client is passionate about the continued preservation and enhancement of Sedlescombe Primary School. The Council's own Rural Settlements Study (2008) identified that even without any new housing in the village the school will soon be close to capacity. My client is aware that both the school and the LEA have identified the need for the school to develop a seventh classroom in the future. We are also aware that the existing pre-school within the village is oversubscribed and unable to operate five days a week or offer a full range of pre-school provision because of operational restrictions in its current location. We have included letters from both operators outlining their needs. My client is currently involved in detailed discussions with both the primary school and the pre-school to identify opportunities to enhance provision for both operators at his site. The potential for this is identified on the attached masterplan.

Given the needs of these existing education services in the village and the intention of policy RA1 to identify up to 58 new homes in Sedlescombe in the plan period we consider that the policy should actively promote additional educational facilities in the village. We consider that the failure to proactively plan for this in policy RA1 would result in insufficient education facilities in the village in the future, ultimately impacting upon its vitality and viability. We therefore consider the absence of this to render the policy ineffective in its ability to protect the needs of rural communities and therefore unsound.

Our suggested remedy is as follows:

* Delete reference to education within criterion iv.
* Amend the title above paragraph 12.34 to include reference to education facilities to more accurately reflect the text in this paragraph.
* Introduce a new criterion within policy RA1 to explain how the Council intends to plan for educational uses. We suggest the following text:

"Encourage educational facilities that either enhance existing provision or provide new facilities to address an educational need/demand in a village and/or assist in preserving or enhancing the vitality and viability of the village. In doing so the Council will have regard to the employment opportunities that new or improved educational facilities may create;"

Policy RA1 criterion v

We are encouraged to see in criterion v the reference to being flexible on the exact housing numbers that will be delivered in villages, which is inevitable given the fact that the Council has yet to commence its Site Allocations DPD. This flexibility is especially significant given our concerns about the figures set out in Figure 12 and our client's emerging proposal that could deliver more than the anticipated figures for Sedlescombe as a whole. We therefore support this approach.

As a small parish council we do not feel that we are qualified to know whether the document is legally compliant or not but would like to the male the following general observations:

1. It is important to protect the environment and countryside especially SSSI's, AONB and ancient woodlands
2. It is important to have affordable housing - local housing for local people.
3. It is important to create employment for local people if our villages are to survive
4. We are of the opinion that the Scats site at Robertsbridge is ideal for affordable housing/industrial (close to A21).

In principle Ticehurst Parish Council approves of the draft plan. It is accepted that Ticehurst Parish is a rural service centre and the Council is keen to maintain and reinstate the retail character of the village centre. It is further accepted that it is necessary to maintain the viability of the village through limited growth and somewhat reluctantly accept the target of 45-65 properties - however, it is important that as a Service Centre, if targets are not achieved elsewhere in the District, that Ticehurst Parish is not deemed as being able to take more.