Policy RA4: Traditional Historic Farm Buildings

Support policy for historic farm buildings and the approach promoted by English Heritage

It is not justified to support the conversion of historic farm buildings for affordable housing at the same time as including Policy RA1(vi) which speaks about new development being sited in close proximity to key facilities and in locations accessible via a range of transport options. Farm buildings are usually remote from key facilities and public transport.

Whilst in general, I do wholehartedly support the fact that historic farm buildings are to be protected, however, this does not go far enough. In the present climate, many farmhouses etc are being sold to people not connected with agriculture (as they are the only people with enough money to but these properties). These buildings need to be protected from this type of person who will in effect make the buildings redundant from their original purpose, not because they are unfit, but because they will let the land for grazing and the buildings will no longer have a use.

Beckley PC considers paragraph (i)(c), which suggests barns etc. be first considered for affordable housing, is not sound since:
>they are often in isolated locations, perhaps as much as a mile from a main road/bus route; which is unsuitable for those with a 'local housing need'
>historic farm buildings are usually within a farmstead and often substantial period structures, therefore of a size and scale inappropriate for affordable housing
>it is unrealistic to expect a 'Registered Provider' to adopt ancient buildings, which are always listed, and so come with the attendant issues and expense of proper care and maintenance.

Such buildings are not suitable for affordable housing. There will be little infrastructure, transport and could be a good distance from hubs (doctors, shops etc.)

CPRE Sussex welcomes and strongly supports Policy RA4 on Traditional Historic Farm Buildings.

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.

Policy RA4: Traditional Historic Farm Buildings
Traditional historic farm buildings will be retained in effective and appropriate use, and proposals for their reuse and/or subsequent alteration should:
(iv) Ensure proper protection of existing wildlife and habitats.
We are assuming that existing wildlife refers to protected species that may be present in the building or using the site, therefore we would suggest either including protected species in the bullet point or in the supporting text, and this bullet should not only cover their protection but enhancement of species and supporting habitats.