Policy RA3: Development in the Countryside

Whilst in principle most of this is ok, this needs to cover all farming ground and farms whether they fall in the context of a village or not. Defra surely only looked at the overall farming situation and did not diffentiate bewteen in a village or not. This could penalise a farm considered to be in a village from expanding/changing/modernising/diversifying if they are not included in the policy from the council.

The K&ESR is a major tourist attraction, economic generator and public transport provider that not only wishes to improve its existing facilities but also extend the existing railway from Bodiam to Robertsbridge to provide a direct link with main line rail services. Support Policy RA3 (ii) which provides support for suitable tourism opportunities in the countryside.

Each village should be invited to select an area to build the houses that areas need in the villages, plus some on farms to create new farm enterprises.

CPRE Sussex welcomes and supports Policy RA3 on the General Strategy for the Countryside, particularly the following criterion:

(v) ensuring that all development in the countryside is of an appropriate scale, will not adversely impact on the on the landscape character or natural resources of the countryside and, wherever practicable, support sensitive land management.

Southern Water is unable to support the Core Strategy as sound because Policy RA3 fails to recognise water and wastewater infrastructure as acceptable forms of development in the countryside. This approach is unduly restrictive and could prevent delivery of necessary infrastructure. This is contrary to paragraph 27 (iv) of PPS1 which requires the provision of essential infrastructure to be taken into account to deliver sustainable development.

Southern Water fully appreciates the planning authority's wish to control development in the countryside. However, it is important that policies do not unduly restrict provision of essential water supply and wastewater infrastructure. Policy RA3 should recognise that essential utility development is acceptable in the countryside if it is required to serve new and existing development.

The relative importance of historic farm buildings in Rother District is overstated in the PSCS, as they are no different from similar historic farm buildings found elsewhere in the County, region and country as a whole. There is no national or regional policy that resists the conversion of such buildings for residential use and the proposed local Rother requirement for priority to be given to conversion for affordable housing only is wholly misconceived on a number of grounds.

The costs of converting traditional farm buildings (and in particular listed buildings) would not be viable for use as affordable housing. There is no evidence that registered social housing providers would be willing to take on such schemes or willing to finance or maintain such housing, as is invariably such buildings are likely to relate to individual properties in relatively isolated rural locations away from main settlements and services.

Part (iii) (b) of Policy RA3 and part (i) of Policy RA4 are not consistent with any national planning guidance contained in PPS3, PPS4 or PPS7 and is inconsistent with the emerging National Planning Framework Document (see paragraph 113). There are no policies in the South East Plan (which remains part of the Statutory Development Plan) to justify such a tight control over potential residential use of rural buildings. Indeed, the highly restricted nature of the policy flies in the face of Government announcements relating to the potential relaxation of controls regarding the re-use of commercial buildings (see for example the recent consultation on proposals to amend the Use Classes Order in this respect and also the March 2011 HM Treasury report "The Plan for Growth", paragraphs 1.34, 2.22 - 2.23 and page 49). These elements of draft Policies RA3 and RA4 should therefore, be deleted or substantially revised in relation to open market residential re-use of rural buildings.

Delete "normally" and limit to circumstances where land is allocated for growth and shown on the proposals map.

Growth in the countryside that is not small scale should be identified on the proposals map as a site allocation.

The policy is unsound as "normally" is not quantifiable. There is no indication within the policy to indicate what circumstances could justify growth in the countryside which is not small scale. Departures "from the norm" could be occasional rather than exceptional.

Policy RA3: Development in the Countryside
Proposals for development in the countryside will be determined on the basis of:
(iii) allowing the creation of new dwellings in extremely limited circumstances,
including:
(a) agricultural dwellings in accordance with PPS7 Annex A;
(b) the conversion of traditional historic farm buildings in accordance with Policy RA4;
(c) the one-to-one replacement of an existing dwelling of similar landscape impact; or
(d) as a 'rural exception site' to meet an identified local affordable housing need as elaborated upon in Chapter 15 - Local Housing Needs;
(iv) ensuring that extensions to existing buildings and their residential curtilages, and other ancillary development such as outbuildings, fences, enclosures, lighting and signage, would maintain and not compromise the character of the countryside and landscape;
(v) ensuring that all development in the countryside is of an appropriate scale, will not adversely impact on the on the landscape character or natural resources of the countryside and, wherever practicable, support sensitive land management.
Any new dwelling, extension, conversion in the countryside (as mentioned in iii and iv) has the potential to impact on protected species, sites or habitats and provide an opportunity for biodiversity gain, therefore all these proposals should be referred to and considered in accordance to the last bullet point (v) found in Policy RA4 together with our comments on additional text which are set out below.
Bullet (v) needs to be more explicit about natural resource, either define this in the supporting text or in the policy, we are assuming this covers designated sites but is unclear.