MOD 12.2

The Councils INSERT suggests that the assessment of the SHLAA review 2013 responds to "the need to maximise opportunities for sustainable growth" It also states that this proposed level of growth is supported by the most recent Sustainability Appraisal(SA)but highlights the increasing negative impacts of development on the character of both settlements and wider countryside. This last statement however lacks the evidence to substantiate such a claim as NO new landscape capacity assessment has been undertaken to establish at what point and at what level of housing does further housing allocations significantly impact on individual settlements.

As an example the previous SA (Nov 2008) considered a Scale of Growth under Option 2 SE Plan requirements +25% (350pa)which in general is comparable with the Councils current SA on Option B3 of the Councils target of 5700(335pa)in that the SA objective 15 " Protect and enhance the high quality natural and built environment..in particular the protection of the AONB assessed both these levels of development as neutral.
However, Option B4 of the current 2013 SA, which would meet the Councils housing needs(6180) under the same objective 15 test now suggests that an additional 480 dwellings(28pa) would lead to an (x)category assessment for the plan over the medium and long term i.e. "option appears to conflict with the objective and MAY (my emphasis) result in MINOR adverse effects" There is NO evidence to assess the landscape impacts of these options and therefore the SA assessment is not robust or justified.

The assessment of other objectives compared in the current SA suggest a lack of explanation between the differing negative marks set against Option B4 compared with those of B3 with many comments remaining the same even though B4 had more x,s against objectives 6,9,10,11.

Further supporting evidence submitted 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

Replacement paragraph 12.14 is supported because it acknowledges that the villages, especially the larger Rural Service Centres (such as Robertsbridge) have greater capacity to absorb additional development than the draft plan has previously recognised.

Mod 12.2: MAIN MODIFICATION NOT LEGALLY COMPLIANT:
This paragraph is a contradiction in terms - how can the sustainability report support the level of growth whilst highlighting the increasing negative impacts of development on the character of both individual villages and of the wider countryside.

MAIN MODIFICATION NOT SOUND:
The sustainability report does not support the levels of development.
Each village where substantial development is sugeested should have its own report as all villages will have different issues

Mod 12.2 Para 12.14
The deleted paragraph reflects the reality that the rural areas have taken the greater share of development. It was always agreed that this trend was to be reversed by concentrating new development in the coastal strip.
To replace this fact with the proposal that a higher level of housing in rural areas is responding to need is demonstrably untrue. The so-called 'need' has been imposed on Rother District Council. Maximising sustainable growth in rural areas contradicts the ability to prevent negative impacts on the character of individual villages and inevitably means the loss of open countryside.

This modification within the SA has been called into question as the numbers of houses Robertsbridge is due to accommodate is far higher than any rural area. This is because it has been dubbed "a service centre or hub". In fact the SA makes options available to councils and government rather than wholesale increased house building. This modification is only part in keeping with the SA and should be redrafted to include other points mentioned in the SA.

It is contrary to NPPF point 17 which states "be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. Plans should be kept up-to-date, and be based on joint working and co-operation to address larger than local issues. They should provide a practical framework within which decisions on planning applications can be made with a high degree of predictability and efficiency";

There have been no meaningful engagements with the rural communities on such issues and because the modification is not practical as it has no business use included in new build figures, this should be redrafted or deleted.

The additional text is unsound and unjustified.

Firstly, the text states the modified village housing numbers are unrelated to the individual settlement needs. The objective is to maximise housing growth in the villages to contribute to the district-wide housing figure of 5700 new houses. This objective conflicts with the NPPF paragraph 54 and with Rother's draft Strategy, which remains unmodified.

Secondly, the entire process is flawed as the modified numbers are led by the provisional identification of potential "development sites" in villages. The correct procedure is to assess the need for new dwellings in individual villages to meet their local housing needs, in consultation with the villages, and then to seek to identify sites in the villages to meet their identified local needs through the neighbourhood planning and/or site allocations process.

Thirdly, the paragraph refers to the negative impact on village policy objectives identified in the SA of the modifications, therefore the observation the increased housing numbers are assessed as sustainable is perverse.

This modification pushes more development towards the villages which are in AONB rather than seeking development on the coast where there is infrastructure to cope with additional development. Villages are not equipped to cope with the impact of 'maximised' opportunities for development and NPPF paras 114, 115, 116 and 120 do not support this approach. It also does not sit with MOD 7.11.

Rural Areas - Housing in Villages
Proposed Modification Nos. MOD -12.1, 12.2 and 12.4

1. These representations (TCPS Representations No. 2), relate to proposed modification numbers MOD 12.1, 12.2 and 12.4 and should be read in conjunction with representations (TCPS Representations no. 1) made in relation to proposed modification numbers 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15, which make the case that the Plan's housing requirement should be increased from "at least 5,700 dwellings" to "at least 6,200 dwellings': This would then also require consequential changes to paragraph 12.13 (Modification 12.1).

2. The Council's revised housing figure now acknowledges that there is more scope than previously considered for meeting the assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (as well as potentially on the Hastings fringes), there is also a need to increase the provision in (and adjoining) rural settlements so as to make an important contribution to the assessed need. MOD 12.4 proposes to amend Part (v) of Policy RA1 to increase the housing requirement in villages from 950 - 1,000 dwellings (as set out in the Proposed Submission Version of the Plan) to 1,670 dwellings.

3. Modified paragraph 7.41 (MOD 7.11) states 'the housing provision seeks to maximise the contribution that villages can make to sustainable growth without prejudicing their individual character and amenities, as well as those of their shared, for the most part High Weald AONB setting". In terms of the housing figures proposed however, modified paragraph 7.30 (MOD 7.6) states "the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out; hence the requirement is expressed as a minimum for the purpose of Plan making. These will be further assessed as part of site a/locations/neighbourhood planning processes".

4. Thus, notwithstanding the proposed modified figure of "1,670 additional dwellings" now inserted into Policy RA1(v) (MOD 12.4), there may well be scope to increase supply within and around villages once potential sites come forward as part of the subsequent site allocations/neighbourhood planning stage. Indeed, the revised (June 2013) SHLAA estimates that some 6,180 dwellings can be accommodated on potentially suitable, available and deliverable housing sites within the District, and there may well therefore, be scope to increase the potential for adding to housing in and around villages over and above 1,670 additional dwellings as part of a site allocations process.