Focused Amendments to the Proposed Submission Core Strategy
Representation ID: 21255
Respondent: Millwood Designer Homes Ltd.
Agent: Kember Loudon Williams Ltd
It is our view that the Core Strategy as amended is not positively planned and is not justified as the most appropriate strategy, as it has been informed by a SA document that is flawed in its assumptions.
The plan fails to be effective as it does not seek to adequately combat deprivation in Rye.
The focused amendments have resulted in a plan that is not consistent with national policy and therefore must be considered to be 'unsound'.
Thank you for the opportunity to comment on these focused amendments to the Rother Core Strategy.
These comments are submitted on behalf of Millwood Designer Homes and supplement our previous comments (References 21102, 21103 and 21104) submitted during the consultation in August 2011.
Our comments specifically relate to the to the focused amendments and whether;
i) they are legally compliant with the Town and County Planning (Local Planning) (England Regulations) 2012; and
ii) they meet the test of 'soundness' as set out in the National Planning Policy Framework.
Our comments specifically relate to amendment FA4, albeit the thrust of the comments relate to wider concerns that we have with the Core Strategy.
It is our view that the amendments that have been made are insufficient to bring the Core Strategy in line with national planning policy. The submission draft therefore cannot be legally compliant or sound.
Paragraph 182 of the National Planning Policy Framework (NPPF) sets out the Government's tests of soundness for Local Plans, with emphasis being placed on positively prepared plans.
The Submission Core Strategy (Para 10.3) highlights the pockets of social deprivation, child poverty and high unemployment in Rye, yet few measures are proposed within the DPD that would have any tangible impact on improving these conditions. Instead, greater weight is placed on preserving the historic character of the towns setting, which we consider to be a negative rather than positive approach.
Paragraph 10.4 further stresses that the local economy in Rye suffers from high seasonal unemployment. This highlights that employment provision at the Port of Rye and Rye Harbour Road Industrial Estate are wholly inadequate for tackling the level of deprivation that exist.
It remains our view that a much higher scale of development is required to improve the economic performance of Rye and to make it more attractive for inward investment.
In order to drive regeneration in these deprived areas there is a need for an increase in the amount of new housing, employment and recreational opportunities to serve Rye. This development can, and should be, located on the periphery of the town and therefore the Core Strategy should explore deliverable opportunities such as the development of land south of Rock Channel to meet essential development needs.
Development of this nature would help combat deprivation whilst preserving and enhancing the town's current strengths. However, policy RY1 as drafted is a narrow policy that restricts growth to limited opportunities within Rye town centre and fails to ensure that the town can sustainably grow.
The strategy also fails to acknowledge that Rye can play an important role in housing delivery, which could compensate for some loss of development if the Bexhill to Hastings Link Road is delayed or cancelled.
Finally, I would stress concern regarding the Sustainability Appraisal (SA) that justified the decision to reduced housing levels.
The SA has failed to acknowledge the benefits that would result from the option of higher levels of housing. In relation to the Council's SA objectives, the benefit of additional housing has been unfairly disregarded in relation to:
* Increased financial contribution towards new/improved school and higher education facilities (objective 5);
* Greater economic competitiveness through additional income/expenditure of residents (objective 6);
* Increased opportunity to provide new community facilities that could benefit cultural and leisure activities (objective 8).
The SA has also been unfairly critical in regards to the option of a higher level of housing, highlighting adverse impacts in relation to flood risk (objective 12), impact on biodiversity (objective 14), increased waste (Objective 16) and impact on landscape/townscape (objective 15). These are all issues that could potentially be overcome through appropriate design and reasonable mitigation measures, which has not been acknowledged or taken into consideration.
It is our view that the failure to recognize indisputable benefits and the unfair assessment of other elements has result in a SA that has been manipulated to justify lower levels of development.
Taking all of the above into consideration it is our view that the Core Strategy as amended is not positively planned and is not justified as the most appropriate strategy, as it has been informed by a SA document that is flawed in its assumptions.
Finally, the plan fails to be effective as it does not seek to adequately combat deprivation in Rye.
Taking all of the above into consideration we do not feel that the focused amendments have resulted in a plan that is consistent with national policy and therefore must be considered to be 'unsound'.