MOD 7.7

Insert Paragraph 7.36 refers to the SHLAA Review undertaken in 2013. The Councils review is both limited and flawed.

The Council rightly qualify its SHLAA by its limitation to available information (no update of landscape assessment since 2008/9 and no landscape capacity study) "and for the most part, draws on local knowledge of Town & Parish representatives" (para 12 Summary of Sustainable Housing Growth July 2013) but acknowledge that all sites require further investigations. In practice little to no addition evidence has been provided to justify the arbitrary capacity restrictions to settlements such as Robertbridge. This town is the largest of the Rural Settlements with excellent transport links, facilities and employment. It is therefore capable of accommodating greater housing numbers beyond the 100 units proposed when compared to Battle(500). Both settlements fall within AONB. On a pure population comparison between these two settlements Robertsbridge should be capable of delivering around 200 additional dwellings subject to an appropriate landscape capacity assessment.

The Council previously in 2010 prepared their first SHLAA which rejected Land at Bishops Lane, Robertsbridge as a suitable housing site due to landscape and access constraints. At the last Examination the Council confirmed its intention to review it SHLAA which it did in 2013.It accepted at the Inquiry following submissions from our landscape consultant reports in 2007 and 2010(David Huskisson Assoc)that a review of the landscape capacity of the sustainable settlements would be undertaken. This has not been done and no evidence has been submitted to justify the Councils latest assessment of this site or others within the SHLAA. The Inspectors letter to the Council on the 7th May 2013 states that it is important to recognise that the NPPF requires authorities to meet the full objectively assessed needs for housing."Conflict with other policies in the Framework is not a reason to reduce the starting point of the full objectively assessed need". The Council cite on several occasions as a constraint the AONB. Paragraph 115 of the NPPF indicates that great weight should be given to conserving landscape and scenic beauty in AONBs. It does not, however, include a presumption against development in an AONB and paragraph 19 and 28 seeks to support a prosperous rural economy.

The SHLAA review appears to meet only the housing figure set out in the Modification Plan and not the capacity of the District as a whole.

Further submitted documents to support this representation can be accessed using the following links:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

This Main Modification is unsound because it is ineffective. The amended Core Strategy and in particular this Modification [ quote ref number] do not sufficiently emphasise two important criteria for the planning of housing developments:

(c) the development should avoid damaging the quality of the countryside immediately surrounding the curtilage of a town. This criterion is frequently highlighted in the 2013 Strategic Housing Land Availability Assessment (SHLAA and applies in particular to Battle ;

(d) the development should avoid placing additional pressure on town facilities such as car parks, roads and shops, unless there are specific remedies for that additional pressure. Battle is an example of a town with traffic and parking congestion as well as insufficient space for additional supermarkets. Expansion of housing at its periphery will either produce unremedied problems; or the remedies if implemented will adversely alter the character of the town.

Distribution of Rural Housing Allocations and the 2013 SHLAA update Proposed Modifications nos. MOD 12.5 and 7.7

1. These representations (TCPS Representations No. 4) should be read in conjunction with TCPS Representations nos. 2 and 3 relating to proposed modification 12.1, 12.2, 12.4 and 12.5. In these representations, the case is made for scope to increase housing land supply in villages beyond the 1,670 additional dwellings referred to in modified Policy RA1(v) (MOD 12.4) and the breakdown given in modified Figure 12 (MOD 12.5), in order to provide a potentially greater contribution to the overall supply of housing during the Plan period.

2. Furthermore, the revised number of dwellings referred to in modified Figure 12 should not be regarded as a ceiling or upper limit on the capacity of each settlement listed, as this potential will need to be reviewed and fully assessed as part of the subsequent site allocations/neighbourhood planning process. In other words, the individual village housing numbers referred to in Figure 12 should not prejudice the potential for additional land to come forward in these settlements subject to this being suitable, available and deliverable at a later stage of the plan making process.

3. lt is clear from the SHLAA update (June 2013) that the Council is now placing greater emphasis on the importance of meeting assessed need notwithstanding this, there remains scope for increasing housing supply above the proposed modified figure of 5,700 dwellings referred to in amended Policy OSS1 (MOD 7.12).

4. While the Council has recently undertaken a review of its SHLAA and this has influenced the revised housing figures put forward, there has been no opportunity for any developer or landowner to assess the Council's revised SHLAA findings and conclusions reached for each site considered (capable of accommodating 6 dwellings or more). There are a number of examples where the Council's revised SHLAA is open to challenge and individual site potential cannot be properly assessed until the site allocations (neighbourhood plan) process has been undertaken.