MOD 12.5

The Councils revised Figure 12 Distribution of Rural Housing continues to lack the evidence base or appropriate analysis of the Rural Hierarchy of the Rural Area and hence continues to fail in its obligation to distribute the housing numbers capable of meeting the Districts overall housing needs.

The Rural Areas objectives (Para 12.6 Local Plan) sets out to "promote thriving rural communities"; to be demographically balanced and socially inclusive, particularly in terms of access to housing " and support sustainable local employment opportunities and the economic viability of rural communities"

Robertsbridge is classified by the Rural Settlement Study as a Rural Service Centre. It is the largest settlement in the "Rural Area",it has a mainline station,a secondary school and immediate access onto the main A21 trunk road. This has to be compared to Ticehurst and Northiam villages which have no station and no secondary school yet now has proposed a further increase in new housing from the deposit Plan of 58% and 105% respectively. The Council appear to have applied an across the board increase in housing to various villages without the proper Landscape and Sustainability appraisals.

Due to the unique characteristic of Robertsbridge and its location in the northern part of the District the settlement should be recognised as a new Sub-Area Structure. This would produce greater information and accuracy upon housing affordability and need in this area. This new Sub-Area would rightly highlight the role of this settlement strategically and identify a greater housing need and establish its economic role and potential in the District.

The Councils Spatial Development Options highlighted in the Rural Settlement Study gave a clear steer, directing development towards service centres e.g. Robertsbridge. This objective continues not to be properly investigated by the Council.

The Councils SHLAA review(2013)continues to rely upon evidence that is out of date or inappropriate i.e. landscape assessments made on SHLAA sites are based upon a study inappropriate to assess the capacity of various settlements to accommodate further housing. The Landscape studies undertaken in 2008/9 were so broad that the assessment of individual sites could not be properly considered. The study's analysis was often quite sweeping and often contrary views were expressed with no explicit justification.

With particular reference to the landscape assessment of Robertsbridge the landscape zones appeared to be arbitrarily defined with little obvious rationale and given the importance of the AONB lacked basic details, such as contours and landforms which do not appear to have played any part in the definitions of the zones. Given that over 80% of Rother falls within the AONB any landscape assessment should include a consideration of capacity especially if the Council wishes to meet its District housing need.

A Rural Settlement Study should properly set out the basis for a sustainable housing distribution hierarchy based upon services and facilities available and the role of individual settlements within the Rural Area.

The Council should also update and review its Housing Needs Survey(2005) and rightly identify Robertsbridge as a new Sub Area Structure with its immediate rural hinterland i.e. Salehurst, Hurst Green and Burwash (this may of course include other settlements across the Tunbridge Wells border).

Subject to a proper Landscape Capacity Assessment Robertsbridge is clearly a sustainable settlement occupying a strategic location in the northern part of the District with excellent accessibility to varying modes of transport(A21 and mainline station) offering great potential for economic growth. The Council currently do not have the evidence available that would suggest only a further 100 new dwellings would be justified over the next 15 years i.e. 10pa

When you compare this figure against that proposed for Battle (a settlement also in the AONB)of 500 this represents a 10% increase on its current population. A similar 10% increase for Robertbridge would yield a figure of 234 new homes over the plan period. The submitted SHLAA sites suggest this figure could be achieved without significant harm to the village setting in the AONB.

Further supporting evidence submitted can be accessed here:
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

155 additional houses in Robertsbridge would prejudice the individual character of the village. Building on agricultural land in full sight of the road will destroy valuable green views. Building should be on brownfield sites, not green, and brownfield exists in the village. Additional risk of flooding due to non-absorbant surfaces. Increased congestion and pollution since the road system is already congested.

Proposals relating to Robertsbridge

1. MAIN MODIFICATION IS UNSOUND

1.1 Modifications fail to meet Sustainability Appraisal criterion 6.7.7 to retain the distinctive character and qualities, in the light of the unique historic nature of the village architecture, and its rural setting which would be damaged by green field development.

1.2 Modifications fail to meet SA Objective 12 to minimise risk of flooding, additional runoff from developed sites within the new flood defences could cause flooding of properties at low end of village, such as my own.

2. MAIN MODIFICATION IS NOT LEGALLY COMPLIANT

2.1 Proposals do not conform to Sustainable Community Strategy for Rother to protect our natural environment, because of the loss of green field sites, and the impact of additional traffic in the village and increase risk of accidents. The High Street and Station Road have inadequate pavements causing high risk to pedestrians. The new heritage railway will also increase traffic.

2.2 Consultation on modifications carried out by planning authority has been inadequate in that I was only made aware of these proposals by concerned local residents and the Parish Council newsletter. In view of the extent of the proposals (16% increase in total households in the village), I would expect a letter of notification direct from the planning authority to all local households.

Main Modification Unsound
The extra houses planned for Robertsbridge would be visible and detract from the rural aspect and charm of the village. Building on fields will mean less absorption of water and more danger of flooding. Flood defences were built to cater for the existing number of houses in the village. Will existing sewage facilities be sufficient?
There is already parking congestion in the village and there will be more congestion and danger to pedestrians crossing the road, particularly by the school.
Main Modification Not Legally Compliant
It is a strategic priority to protect the natural environment. Extra building does not.

Replacement Figure 12 is supported because it is based on an increased overall housing requirement of 'at least' 5,700 additional dwellings in the district in the period 2011 to 2028 derived from the SHMA Update: Housing Needs Assessment (June 2013, which is supported. Further, the increased figure for the villages of 1,670 additional dwellings is also supported as it acknowledges that the villages have greater capacity to absorb additional development than the draft plan has previously recognised. In addition, the increased development in the larger Rural Service Centres (such as Robertsbridge) will contribute to the vitality, viability and sustainability of those settlements.

Main Modification unsound.
The large percentage increase in proposed houses is not compatible with the RDC Sustainability Appraisal because of destruction of greenfield sites and lage increase in already severe traffic congestion.
Maim Modification not legally compliant
Not compliant with the Sustainable Community Strategy which envisions reducing impact of traffic. Housing increase will add to already major congestion in the High St, Station Road, Brightling rd which results largely from vehicle parking. More houses will require either large free car park close to station or widening of existing roads which will conflict with Sustainability Appraisal and Strategy.

I believe the main modification is unsound. I have lived most of my 56 years in Robertsbridge following my parents and grandparents in previous generations.The outstanding natural beauty of the village is severely threatened by increased housing development. The past 20 years has seen over 200 new homes increasing the size of the village by 20%+. The increase in new building will further challenge the village flood defense already breached in 2000.The new flood defense is unlikely to hold back large quantities of water. I do not believe the number of houses planned for Robertsbridge is "legally compliant" because it does not comply with the Sustainable Community Strategy for Rother. The removal of beautiful green field sites and the inevitable increase in traffic will have a devastating impact on the community.

Main modification unsound.
An increase of a further 36 houses will A)Severely diminish the essential rural character of Robertsbridge. B) Increase the risk of the flood prevention measures being overwhelmed, increase traffic flow and the danger of accidents involving the young and the elderly. C)Exceed the capacities of Doctors, Dentists, Schools, Fresh water supply and Sewage disposal.

I consider that the proposed additional 36 new housing units in Robertsbridge would create the following problems::
1. Further deterioration of this historic village's rural charm
2. Increased danger for road traffic accidents, particularly in child education and retail locations
3. Even greater difficulties for vehicle parking amongst general public and rail commuters
4. Increased difficulties in community policing
5. Additional stress on control of sewage/grey water outfall and flood defences

1. Villagers have not been involved.
2. No notification to individuals from County Council.
3. On enquiring for representation forms found limited knowledge and forms. Rother Local Plan Core Strategy Form states " representation forms can be found on website but also available from Community Help Points and can be sent if required"
They were ill equipped to deal with this.

155 is too many houses to be built in the village.
1. Traffic congestion/parking
2. Drainage - already George Hill has its problems with water
3. Flooding: Always a chance
4. Sewage: A possible problem area
5. Loss of greenfields
6. Loss of identity as a village.

The proposed building of 155 more houses in Roberstbridge will
1. Undermine the character of village
2. More hardstanding will create more water problems
3. It is already a flood area
4. Sewers will be overloaded
5. Traffic congestion would occur
6. Parking is already a problem
7. Loss of green areas

The chart showing various housing figures broken down into parishes is not easily understood.
1. The footnotes are much too small to read and some are not required if the additional text is inserted after Fig 12 as proposed.
2. The "All completions" column has been changed from "All completions 2006-2011" to "All net completions in plan period 01/04/2011 to 31/03/2013". The previous Plan was dated 2006, should the fitures for completions remain as from 2006?. Is it justified to add the word "net" to this column?
3. The current commitments column heading has been changed from the previous heading "Commitments 2011 to 2028 (allocations and permissions)" to simply "Current Commitments". The content of the column has also been changed to current commitments as at April 2013. The heading needs to clearly show what is being shown.
4. Proposed new Core Strategy sites are shown as having to be within or immediately abutting a village while the current commitments and net completion columns are shown for development across the parish. Like is not being compared with like.
5. The number allocated for Sedlescombe at 35 is not justified because it is too high a percentage increased from the 25 previously shown (the previous figure included 8 new affordable homes at East View Terrace and 35 does not. This is therefore actually a 106% increase from 17 to 35. Compare this with the total increase for all the villages ie from 1,000 to 1,670. A 67% increase for Sedlescombe would be 27 or 28 additional properties.

2) There is no proven need for additional housing. The Council's allocation of housing numbers appears to be flawed and without basis.

3) Brownfield sites are being ignored in favour of greenfield sites. This is also in direct contravention of Rother's stated policy.

PROPOSAL UNSOUND.

The rural charm of Robertsbridge will be diminished where new houses are built on high visibility, farmed, greenfield sites in an Area of Outstanding Natural Beauty and congestion will increase further, with a greater risk of road accidents. If 155 new houses are built (an increase of 36 on the previous proposal of 119), there will have been an increase of over 40% in the number of houses and population in Robertsbridge since 1991. The proposed figure therefore fails the key test in para 6.7.7 of RDC's July 2013 Sustainability Appraisal.

The building of further houses would increase the potential risk of flooding in Robertsbridge through lower absorption rates and more rapid run-off.The proposal does not therefore meet the requirements of Objective 12 for Rural Villages set out in the July 2013 Sustainability Appraisal. There were bad floods in the village in 2000 and although new defences were built, these were geared to a 100 year event, whereas the current practice is to protect against a 200 year event.

PROPOSAL NOT LEGALLY COMPLIANT.

The Sustainable Community Strategy for Rother identifies that it is a priority to protect our natural environments, including farmed, greenfield sites (Chptr 1) and identifies a vision of reducing "the impact of traffic on people and places". There are already traffic jams in Robertsbridge. The proposals are not consistent with these policies.

A further vision identified in this document, is to ensure that people are confident of their safety and increasing the potential risk of flooding is not consistent with this.

Mod 12.5: MAIN MODIFICATION NOT LEGALLY COMPLIANT(Robertsbridge):
The sustainability report for the rural areas does not give enough detail to prove that the level of housing planned for Robertsbridge is sustainable.
The Sustainable Community Strategy for Rother identifies that it is a strategic priority to protect our natural environment, the building of houses on greenfield and productive agricultural land does not comply with this.
There has been no consultation from RDC with the villagers regarding the proposed number of houses.

MAIN MODIFICATION NOT SOUND (Robertsbridge):
The number of houses allocated for Robertsbridge is too high and unsustainable.
It will increase the risk of flooding, increase already congested roads and will be detrimental to the quality of life of the villagers. I submit as evidence photographs of flooding.
Robertsbridge has already had over 200 new houses in the last 25 years with no improvement to services and infrastructure.
In a letter received from Nick Boles (housing minister), I understand that the NPPF states that development should primarily take place on brownfield sites, Robertsbridge has one such major site and future development should be restricted to what can be built in this area. To build on greenfield sites and productive agricultural fields would detract from the rural charm and individual character of the village and would be against RDC policies RA3 and RA4 - what is the point of having policies if they are not taken into account by at least RDC when planning. This does not give confidence in RDC's planning process.
There has been no consultation with the villagers with regard to the number, and little attempt to make them aware that this process is taking place. I submit as evidence the freedom of information request which shows that an advert was place in the Battle Observer for 1 week on 9th August. Approximately 120 copies of this paper are sold in the village each week. This is not a sufficient attempt by RDC to contact villagers.

Further supporting evidence was submitted alongside the representation and can be accessed using the following links:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20593
http://www.rother.gov.uk/CHttpHandler.ashx?id=20594

Burwash Common
'Linkway Field' (RA2)
The term 'further ribbon development west of the village into an area of rural character' is misleading as it makes it sound as though any development would extend into virgin territory whereas to the west of the field along, the A265, are existing dwellings which are part of the village of Burwash Common, so rather than extending the village limits any development would be incorporated in to the village boundary.

Unaware of any site visit being carried out.
This site would be capable of exceeding 6 dwellings and should be re-considered and included in the village development boundary.

I feel the number of new proposed houses for Robertsbridge is not justified as we already have a large number of properties on the open market, which have been on the market for a considerable time, building new houses is unjustified and unnecessary. We will also lose the wonderful 'rural' feeling which is why we live here, if we wanted busy we would move to Hastings!

MODIFICATION UNSOUND (ROBERTSBRIDGE).

If 155 new homes are built in Robertsbridge (an increase of 36 on the previous proposal of 119), there will have been an increase of over 40% in both the number of homes and the population since 1991.

The rural charm of Robertsbridge will be diminished where new homes are built on high visability,actively farmed, greenfield land in an Area of Outstanding Natural Beauty.

In addition, traffic congestion and queues in shops and for services such as the Post Office will increase further, with road accidents being more likely.These problems will be compounded by the reopening of the steam railway line to Tenterden in due course.

The proposed figure of 155 therefore fails the key test in paragraph 6.7.7 of Rother District Council's Sustainability Appraisal published in July 2013, because it does not reflect "the vision to retain...individual character and qualities, as well as support local services and community life".

The building of further homes would also increase the potential risk of flooding in Robertsbridge, because there would be less ground to absorb water and it would run off hard surfaces faster than would be the case with land.

Although flood defences were built following the very bad floods in 2000, these were only built to protect against a 100 year event, whereas the current standard is a 200 year event.

The proposal to build so many more homes in Robertsbridge does not therefore meet the requirements of Objective 12 set out in Rother District Council's Sustainability Appraisal published in July 2013, "to minimise the risk of flooding and resulting detriment to people's property".

MODIFICATION NOT LEGALLY COMPLIANT(ROBERTSBRIDGE).

In Chapter 1 of the Sustainable Community Strategy for Rother, the protection of our natural environments, including actively farmed, greenfield land within the Area of Outstanding Natural Beauty is correctly identified as a priority, but the proposal to build so many new homes in Robertsbridge is not consistent with this.

The Sustainable Community Strategy for Rother also commendably identifies a vision of reducing "the impact of traffic on people and places". The proposal to build so many new homes in Robertsbridge is not consistent with this.

Finally, this document also rightly identifies a vision to ensure that people are confident of their safety, but increasing the potential risk of flooding is not consistent with this either.

Photgraphic supporting evidence was submitted alongside the representations and can be found using the following links:

http://www.rother.gov.uk/CHttpHandler.ashx?id=20606
http://www.rother.gov.uk/CHttpHandler.ashx?id=20607
http://www.rother.gov.uk/CHttpHandler.ashx?id=20608
http://www.rother.gov.uk/CHttpHandler.ashx?id=20609
http://www.rother.gov.uk/CHttpHandler.ashx?id=20610
http://www.rother.gov.uk/CHttpHandler.ashx?id=20611

Main modification unsound: Robertsbridge.
I believe the higher number of houses is unsound because
1 it does not meet Rother's sustainability appraisal aim that, "The key test for growth is te villages is whether it reflectsthe vision to refect their distinctive,individual character and qualities ". To increase the size of the village in this way would alter the character- Since the bypass was built, cars have parked on the high street, supporting access to local businesses. This means the street is effectively one way, acting as a traffic calming measure and enabling people to cross the road easily. More people and more cars would make it difficult to retain this, which is so important in making the High Street a place to meet people as well as shop.
2. The sustainabiity appraisal alsorefers to minimising the risk of flooding- more ghouses will increase not minimise the risk of flooding.

The infrastructure of Robertsbridge village would not support the building of an additional 155 houses - the number of houses should be reduced to the minimum.

3.1 Road Congestion.
3.1 Flash floods - no absorbency for rain coming into valley
7.11 Building such a large additional number of houses would change the character of the village for the worse.
7.23 The building of so many new houses especially on greenfield sites, would spoil the natural beauty of the village.

7.3 Communication with the residents of Robertsbridge was/is inadequate.
Each householder I feel should have been democratically consulted before decisions were made.

7.3 Property values will fall and quality of life will be affected by increased traffic congestion and loss of natural beauty in the environment.

MOD12.5 MAIN MODIFICATION NOT LEGALLY COMPLIANT:
The sustainability report for the rural areas is not sufficiently detailed enough to prove that the level of housing proposed for Robertsbridge is sustainable.

MAIN MODIFICATION NOT SOUND:
The number of houses proposed for Robertsbridge is not sustainable due to the increased risk of flooding from additional run-off, traffic congestion & parking. The NPPF states that brownfield sites must be used as a priority. The number of houses proposed should be reduced to be accomodated on the brownfield site in the village. To build on greenfield and agricultural land is against RDC policies RA3 and RA4 and would detract from the rural charm and idendtity of the village. There has been no consultation from RDC with the village people and therefore a majority of the residents do not know what is going on. Robertsbridge has already accomodated over 200 new homes in the last 25 years, with no improvement to the ifrastructure.

1. 5-2.9. There would be further congestion with more vehicles in the village
2. NPFF - Point 103. The proposed development must exacerbate the flood risk.
3. NPFF - Point 80. With the development proposed this village would be more like a town as we've already had a 40% increase of the number of houses in the last 10 years. More houses would spoil for ever its rural 'character'.
4. NPFF - Point 109. More houses in an 'area of outstanding beauty' would be both damaging and irresponsible.

1. 6-7.7 Robertsbridge would not be able to keep its individual rural character. NPFF Point no. 80. 'Encroachment' and 'loss of character'. There is already a 40% increase in the last 10 years. NPFF Point no. 50. Why more?
2. 5.2.9. Cars/traffic already causing congestion. Parking is difficult.
3. NPPF Point 103. Already a 'flood risk'. Why aggravate the situation?
4. 5.2.1. Where lie the 'benefits'? 5.2.9. More jobs where? So who would buy new/affordable housing? People from London?
5. NPPF. Planning has not been a 'collective business'. There has been little or no consultation with the villages!
6. NPPF Point 55. Can we ensure new buildings would be in keeping with village - Point 66 - they would certainly affect the community! (infrastructure?)
7. NPPF Point 79. Do we really have 'green belt protection'?
8. NPPF Point 109. Robertsbridge and area is an 'area of outstanding beauty' - why spoil it with more houses!

The infrastructure of Robertsbridge village would not support the building of an additional 155 houses - the number of houses should be reduced to the minimum.

3.1 Road Congestion.
3.1 Flash floods - no absorbency for rain coming into valley
7.11 Building such a large additional number of houses would change the character of the village for the worse.
7.23 The building of so many new houses especially on greenfield sites, would spoil the natural beauty of the village.

An additional 155 houses would seriously increase the present traffic congestion in Robertsbridge (MOD 2.1).
The growth of 155 houses will destroy the rural character of the village which hitherto has been preserved with some care (MOD 7.6).
The present infrastructure would be inadequate to support the increase (MOD 7.13).

Housing Allocation for Catsfield:
Para 54 of NPPF states that the plan should be responsive to local circumstances and local need.
Village plan prepared in 2009 following a survey of residents concluded that there was no ?? demand for housing in Catsfield.
The proposal to increase the housing allocation from 0-30 to a fixed 47 does not reflect the need and is disproportionate for a settlement of 133 dwellings.

Taylor Wimpey supports the increase in the number of dwellings to be allocated on new sites in Hurst Green from between 20 and 40 up to 75

The increase in the proposed new dwellings in Catsfield from 0-30 to 47 is not legally compliant or sound with national or RDC Policies. The development is not proportionate to the village (there are at present 133 dwellings and and increase of 64 would significantly change the village and is not reflective of local needs.