MOD 12.5

Modification to Core Strategy

Flood risk
The village at Robertsbridge lies at the confluence of the eastern River Rother with the Darwell Petty Sewer. Upstream of Robertsbridge at Etchingham another main river, the River Dudwell joins the Rother valley. In addition there are numerous minor tributaries, which connect with the Rother system upstream.

The eastern Rother rises at Rotherfield and comprises mainly of a clay-based catchment area, which in turn gives rise to high run off during heavy or prolonged rainfall. Robertsbridge is the only major community in Rother District a large part of whose housing stock lies in and around the flood plain. After the serious flood in 2000, which caused expense and misery to 100 properties in Robertsbridge, flood defences were erected. The modelling was based on the existing properties and gave protection for a 1:100 year flood. All flood defences built after this time are built to a 1:200 year flood. Any increase in housing, particularly on green field sites will exacerbate such risks.

Not only have properties been affected by river flooding, but also by surface water flooding. The areas selected for possible development aren't in danger of fluvial flooding but the important thing to remember is that the increased rate of surface water run-off needs to be addressed to avoid problems elsewhere. Since the flood defences have been in place, there have been two flash floods in Robertsbridge with properties some distance from the flood plain being flooded. The clay base gives rise to springs, which if built over can move. A number of properties have been flooded by surface water since the flood defences were operational.

The engineering solutions to this generally involve holding/ storing water and slowing down the rate of run-off to emulate a greenfield situation; this may include the use of attenuation basins, swales and hydro brakes; recent regulations have now introduced the concept of Sustainable urban Drainage Solutions (SuDS) which should be incorporated into the design of any development if possible. Both types of system require space to work and this will limit the amount of houses that can be built in the designated areas.

The Environment Agency's Flood Management Plan (Dec 2009) states that 'surface water flooding due to overloaded drainage is already a problem' (p 13)

Character of the village
Between 1991 and 1998, 166 new dwellings were built in Robertsbridge. As a percentage of population at that time, this represented the highest growth for any rural village or town. Since then there has been 59 new permissions.

It is acknowledged that Robertsbridge has a number of key services unlike many of the rural villages. Also there has been little development since the recession. However, this should not mean that Robertsbridge is ripe for development, particularly if phasing is unacceptable to developers.

Given the life of the new Local Plan, the initial proposal for 119 would be sustainable if there were other community gains. In particular, there is the need for specific accommodation for the elderly and the two Housing Needs Studies identified both this need and the need for affordable homes for young families. However, even with 119 new dwellings, particularly built over a shorter period than 15 years, would create unacceptable traffic and parking issues in a village already experiencing considerable difficulties. Every road exiting the village at present is uncontrolled one way owing to parked vehicles.

Work with Parish and District Councillor:
To achieve consensus on the 119 dwellings a considerable amount of work was done in conjunction with RDC officers, our District Councillor and Parish Councillors. There was reluctant acceptance that sites could be identified to accommodate the 119 without losing the character of the village. However, the increased number will necessitate the loss of potentially two or three greenfield sites. This would have an extremely negative impact, as the numbers cannot be accommodated without building large estates.

Sustainability: Already, without any new dwellings there are a number of pressures and inadequacies in services: already mentioned is the lack of affordable housing and sheltered accommodation for the elderly, the pressure of traffic and parking issues and flood risk; however other issues are already making a negative impact on the village: the doctors' surgery has long been unfit for purpose, the two dentists do not have access for disabled, the pre-school is already over-subscribed, the train service to London is only every hour, there is a demand for employment sites.

Huge impact on traffic/parking and look of the village. A brownfield site at the mill is much more likely to benefit the village. The proposals are insensitive and have not come out of proper consultation with the residents. The main beneficiary will be a developer. What social housing will be included - this is not mentioned?

MOD 12.5 Not legally compliant.
RDC has not consulted with Robertsbridge villagers. The number of houses proposed is unsustainable and would lead to increased road congestion and more localised flooding due to increased run off.
Development of this size would have to be built on greenfield sites and productive agricultural land. Both of these are part of the rural charm and identity of Robertsbridge. Also building on such sites contradicts RDC own policies: RA3/RA4.

MOD 12.5 Not sound
There has been no involvement with Robertsbridge residents regarding the number of proposed new houses.
There has been no individual sustainability appraisal for Robertsbridge - so how has this figure arisen?

Majority of Catsfield residents do not wish major developments in Catsfield. In 2009 Catsfield produced a Local Action Plan, which stated that the majority did not want extra development, only normal in-filling. This Action Plan lasts until 2014.
Catsfield does not have the infrastructure for large development eg. School already full, possible drainage problems, no gas supply, bus service probably to be cut. It is also possible that large developments could cause major flooding problems, as sites specified are subject to underground springs.
The main road is totally unsuited for more traffic, because already during peak periods the road is one gigantic traffic jam causing many vehicle accidents and a nightmare for pedestrians, especially children, to cross, despite there being a pedestrian crossing.
One planning application for two houses was refused because additional ground was required which would encroach on an AONB and an SSI. Although we are not allowed to mention specific council planning sites, one of these is specified.

Majority of Catsfield residents do not wish major developments in Catsfield. In 2009 Catsfield produced a Local Action Plan, which stated that the majority did not want extra development, only normal in-filling. This Action Plan lasts until 2014.
Catsfield does not have the infrastructure for large development eg. School already full, possible drainage problems, no gas supply, bus service probably to be cut. It is also possible that large developments could cause major flooding problems, as sites specified are subject to underground springs.
The main road is totally unsuited for more traffic, because already during peak periods the road is one gigantic traffic jam causing many vehicle accidents and a nightmare for pedestrians, especially children, to cross, despite there being a pedestrian crossing.
One planning application for two houses was refused because additional ground was required which would encroach on an AONB and an SSI. Although we are not allowed to mention specific council planning sites, one of these is specified.

Majority of Catsfield residents do not wish major developments in Catsfield. In 2009 Catsfield produced a Local Action Plan, which stated that the majority did not want extra development, only normal in-filling. This Action Plan lasts until 2014.
Catsfield does not have the infrastructure for large development eg. School already full, possible drainage problems, no gas supply, bus service probably to be cut. It is also possible that large developments could cause major flooding problems, as sites specified are subject to underground springs.
The main road is totally unsuited for more traffic, because already during peak periods the road is one gigantic traffic jam causing many vehicle accidents and a nightmare for pedestrians, especially children, to cross, despite there being a pedestrian crossing.
One planning application for two houses was refused because additional ground was required which would encroach on an AONB and an SSI. Although we are not allowed to mention specific council planning sites, one of these is specified.

Robertsbridge:
MM not compliant with sustainable community strategy of reducing traffic impact. Parking provision for train travellers is totally inadequate, Station and Lower Brightling roads are in effect one way, restricting access for heavy vehicles to Darvell and buses to school. George Hill and High Street also heavily congested by parking for trains. 36 more houses, unacceptable impact.
MM unsound because sustainability appraisal refers to key test of maintaining village character. Additional 36 houses will increase traffic congestion through additional parking, neither major new car parks nor road widening will satisfy sustainability appraisal.

New houses for Robertsbridge is not legally compliant on greenfield sites as sustainable community strategy for Rother states it is a priority to protect our natural environments (Chapter 1 E.S. Strategic Partnership. Pride of Place). Development of additional housing will increase traffic where streets are at present congested and reduced to single file traffic due to street parking. Particularly reducing access on Station Road/Brightling Road to Station and Doctors Surgery. Northbridge Street/George Hill for A21. George Hill/Station Road/Brightling Road for both schools.
New roads. Drives and building roofs will increase water run-off. Thus increasing flooding/flash flooding risk which Robertsbridge is already prone to (E.S. Strategic Partnership. Pride of Place. Wealden.) I was unaware of any consultation with the public for increased houses in Robertsbridge.

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).

No evidence of objective assessment for the need of more housing in Robertsbridge (MOD 7.10).
155 new houses in Robertsbridge is incompatible with my vision of a village (MOD 7.3).
There has been no objective assessment of the potential for further flooding after the hardstanding of 155 further houses and garages have been built, i.e. run-off (MOD 7.7).

The proposed increase of 155 houses to be built in Robertsbridge is wrong because of:
- irreversible loss of open countryside and agricultural land;
- conflict with 6.7.7. Sustainability Appraisal for rural charm of our area;
- risk due to more hardstanding, of increase in flooding;
- not compliant with the community strategy for Rother;
- adding to congestion on roads already unable to cope with traffic flow.

Main Modification 'Unsound'
I am of the opinion that such a large number or houses will severely damage the rural charm of Robertsbridge. Contrary to Rother District Councils (RDC) own 'Key Test for Growth'.

I feel that a development will also pose a major flood risk to Robertsbridge, as rain water will run off the development placing homes at risk of flooding.

Main Modification Strategy Not Legally Compliant

I feel that with the high number of houses proposed parking and congestion will be detrimental to the Rural Charm of the Village. This will become worse over time due to the trend of children living at home into their twenties or thirties. This could certainly not be considered sustainable for the village.

Not
I feel that there has not been effective consultation of the proposals

Despite high levels of development over the last 30 years, recent close partnership working with RDC towards an agreed Village Study (under localism principles) shows us that, as a Rural Service Centre, Robertsbridge has capacity for further development over the plan lifetime as per the original allocation. Whilst acknowledging the additional need in response to NPPF, we consider the increase to 155 to be too great, as it can only be accommodated by use of additional Greenfield areas, which would threaten the essential central green corridors that are a conspicuous visual feature of the landscape and character of the village within the AONB; would threaten the effectiveness of our current Flood Alleviation Scheme (1 in 100 year event); put significant increased strain on current parking, traffic and drainage problems, and so have a detrimental effect on quality of life. A Housing Needs Survey in 2011 confirmed need for housing for the elderly (no current provision!) and low cost, starter homes - both Housing Association and open market. Existing development allocations can support increased numbers (up to 75 new, total 130), removing the need for new allocations and associated impact.

although the tables look the same at first glance there is a fundamental difference.there is no minimum column on the modification. this has the effect in Catsfield of increasing our allocation from 0 to 30 up to 47 dwellings. an increase of 56% at 30 rising through 370% at 10 to infinity% at 0.
I consider this change to be illegal and to go against the policy of reasonable change within a small village. It goes against Policy 7.41 ,7.43

We support the proposed increase in the level of development in the villages in the rural area, and particularly the focus of the larger quantum of development in the most sustainable settlements, such as Northiam. Consistent with our representations on other modifications, and the Council's proposed modification 7.6, the footnotes to the table should make it clear that the housing targets are themselves minima.

1. 3.5.1 Sustainability Appraisal reads "Economic recovery has become the national imperative, although it is likely that the process wtll be a lengthy and difficult one. The need to promote economic recovery is also the primary influence on policy makers, as exemplified in the National Planning Policy Framework". How will the short term effect of further increasing residential housing numbers from 119 to 155 have on economic recovery wtthout adequate employment facilities. Please note that the increase of people travelling to & from work, whether by train, car or bus adds to greenhouse gases and unsustainable travel costs for employees as wages continue to stagnate against inflationary increases. The current train season ticket cost from Robertsbridge to London is £4,500 and is set to rise 4% over the next year.

2. 5.2.1 Sustainability Appraisal reads "As previously outlined, there is a requirement to revisit the assessment of housing need. This is in the light of the even greater weight now given to the NPPF and to meeting current objectively assessed need." This has not been positively prepared as the effects of increased housing numbers to 155 as it would appear are not for immigration needs or those solely coming to the area from outside the UK, but the increase accommodates people wishing to move out of London due to the excessive expense in living there. Yet, what indication is there that those properties vacated by such people wishing to live in a rural location can be afforded by those who wish or need to live in London?

3. 5.2.9 Sustainability Appraisal reads "Careful consideration should be made to the balance of jobs to support housing growth, the capacity of the transport network to accommodate a higher housing target". There is insufficient local employment to justify increased housing numbers and the strain of increased motor vehicle usage which is already problematic, will be greatly exacerbated. The village during term times is already congested and without changes to the network structure, how will the increased vehicle numbers be safely achieved without damaging the aesthetics and characteristics of the historic village? Any such changes in road networks & housing numbers would be contrary to 6.7.7. Sustainability Appraisal which states "The key test for growth in the villages is whether it reflects the vision to retain their distinctive, individual character and qualities, as well as support local services and community "life".

4. From the NPPF, "This should be a collective enterprise. Yet, in recent years, planning has tended to exclude rather than to include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them." There has been insufficient village and locality engagement within the consultation processes which itself is complex, too restrictive and itself excludes residents from the changes that are being imposed by central & RDC governments. Are all age groups of the population adequately accommodated in terms of representation access and facility? Please note that only 31 people responded to the last consultation process for the whole of RDC. Therefore this further increase is contrary to the basic foundations of the NPPF.

5. With regard to the NPPF three dimensions to sustainable development, an environmental role - contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy", this will not be achieved due to heightened risks of flooding, increased carbon emissions from homes (which are the biggest emitters of C02) and degrades wildlife, hedge-rows and the historic environment of Robertsbridge. This would be contrary to NPPF paragraph 18: "The Government is committed to securing economic growth in order to create jobs and prosperity, building on the country's inherent strengths" & is contrary to paragraph 28 "promote the development and diversification of agricultural and other land-based rural businesses" & promote*the retention and development of local services and community facilities".

6. NPPF paragraph 14 states: "any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole". This increase of a further 36 homes on top of the existing 119 has not been shown to outweigh the benefits nor have the residents been consulted in an efficient and effective way throughout the process, a central tenet of the NPPF. Those without internet access are greatly disadvantaged - in this case charges of £5 are levied for hard copies of this consultation.
The NPPF states in point 6, 47 "identify and update annually a supply of specific deliverable11 sites sufficient to provide five years- worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land.Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land". This is in direct conflict with the underlying principles of the NPPF and clearly shows the predisposition for building increased housing numbers at the expense of rural & town communities and safeguarding existing natural & historic amenities. Furthermore point 47 goes on to say "set out their own approach to housing density to reflect local circumstances". The current process of imposing targets on communities from other bodies is against the principles of the NPPF and this point in particular. By forcing local authorities to have an annually updated supply of sites and increasing housing numbers which are encouraged to do so by financial incentives to build, the safeguards of ensuring sustainable growth (if possible) without long term detriment to the environment and local communities.

7. NPPF point 50 states "identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand". Currently there are a considerable number of houses for sale in Robertsbridge many of which have been on the market for many months. Where is the local demand for 119 -155 extra properties? Currently (2/9/13), there are 32 properties for sale within Robertsbridge and 105 within a 5 mile radius of the village. The Local Plan and modifications to the Core Strategy have not made a case for building further properties as the market is already available with properties.

8. NPPF point 55 states that "the exceptional quality or innovative nature of the design of the dwelling. Such a design should:
- be truly outstanding or innovative, helping to raise standards of design more generally in rural areas;
- reflect the highest standards in architecture;
- significantly enhance its immediate setting; and
- be sensitive to the defining characteristics of the local area."
With current market forces presently in operation, how will developers build such houses and keep the cost down of new builds so people in the area who earn on average £6.000 pa less than other areas in the South East can afford to buy them? The current average price for properties nationally is between £198,000-330,000.

9. NPPF point 69 states "safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas'. Further congestion in Robertsbridge Village centre and by the school strongly suggests dangerous road congestion leading to pedestrian & motor vehicle accidents. Increased congestion suggests negative effects on existing businesses within the area through loss of income due to limited parking and overcrowding.

10. Points 79 & 80 of the NPPF state the importance of green belt protection. By the increase in housing even to 119 then possibly 155, such spaces will be lost and damaged irreversibly. Point 80 states: ''To check the unrestricted sprawl of large built-up areas;
* To prevent neighbouring towns merging into one another;
* To assist in safeguarding the countryside from encroachment;
* To preserve the setting and special character of historic towns; and
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land".
The current increases in housing go against the fundamental principles of the NPPF Green Belt Land policy.

11. NPPF point 96 states: "take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption". This has a direct impact with point 55 of the NPPF and will adversely affect the village community.

12. NPPF point 103 states:"When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where, informed by a site-specific flood risk assessment20 following the Sequential Test, and if required the Exception Test". With the increase in housing, water run-off will add to flood risks and will adversely affect insurance premiums for those living in flood areas.

13. Paragraph 11, point 109 states: "protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability;
* Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. This is clearly not met by increased housing numbers within Robertsbridge by the extensive loss of natural areas for such housing numbers. Point 115 NPPF states "Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty". Robertsbridge is in an AONB; therefore any further housing greatly reduces its natural beauty!
The presumption of development within the NPPF and other documentation is based heavily on economic growth at the expense of sustainability (the official meaning used by Government found on the introduction of the NPPF is nebulous and ill defined). At present the housing numbers exceed the ability for the locality and the presumption of house-building is unduly weighted in favour of developers and Councils who will receive an incentive for house building. The Chartered Institution of Water and Environmental Management (CIWEM) have raised these severe problems in reducing the NPPF to a bare-bone structure which removes many safeguards found in previous NPPF documents. The increase in housing numbers therefore represents "a builder's charter to develop at the cost of wider local & environmental interests as opposed to considering economic, social & environmental factors in a balanced manner which respects the principles and recognised definitions of sustainable development and the best interests of all in society".
The average rise in property prices in the UK as defined by ONS notes and increase of £833 or 2.9% to May 2013. The increase of 155 houses in Robertsbridge is not enough to lower the over inflated house price within the UK. The rise of properties was due to banks increase in profitability with their mortgage products which rose 450% in profitability for the banks. The increase in housing supply is insufficient to bring down housing costs but is too great (155 houses) for this area to accommodate with detrimental effects for the community.
CHART UK House Prices: 1997 - 2010
Secondly house prices rose considerably faster and higher than wages. This remains severely problematic for this area and remains one reason why new build housing is unaffordable for a large percentage of people. This principle is contrary to NPPF's policy of community inclusion.

Further supporting evidence was submitted and can be found using the following link:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20618

There has been no consultation with the local community about the increased number of dwellings for potential new sites.

There needs to be an opportunity for a village consultation which will allow parishioners to understand the need for additional dwellings and how such numbers are allocated and where they will be accommodated. There is concern that the proposed number of dwellings are to be located on one site which would create an 'estate' type provision which would be inconsistent with the character of the village. It is the view of the Parish Council that this matter needs to be addressed in order that the proposal can be considered 'sound'.

MOD 7.8 pg33.
This deprivation of Hastings and Bexhill is caused by the marketing of everything; we have the wrong idea about growth? Building houses seems to be what everybody believes will sort the economy out, but it just delays the crash; the higher things go the further they will fall, so we should stop the problem before it starts.
We have young and elderly people suffering from mental depression, people can't save for their pensions, what do these modifications do for them?
The plans that Rother are trying to put forward can only make things worse.
The large proposed development areas such as North Bexhill off the link road need to be offered as a site where people can grow, play and live in an oasis of peace.
Work units can only cost a few thousand pounds, yet we have sea space inviting big businesses to invest in the area at rents that one can rarely afford, having paid a development value for the land, let's put out a new plan. Consider the document, 'Protect our Open Spaces', we should have a referendum on this document before the idea goes to the full council. At the Link Road enquiry I asked what the County Council were paying for the land they were compulsory purchasing; they replied 'agricultural value'.
With 10,000 unemployed and 4,000 on the housing waiting list, we should do the same for the sake of Rother and Hastings; we should look at land reform on a national scale, start here? Stack the houses, create a community farm and have an elderly people's village!
The strategy as it stands will create debt and despair. It is unsound and Hastings is the same, you are all supposed to be working together, but it would appear a few are not co-operating, are they the ones who are making the decisions?

This point also applies to MOD 7.4, pg.36 regarding Battle and Rye, MOD 11.3 pg.70 Policy BA1 for Battle.

Mod 12.5 pg81, figure 12,
The extra houses should be given to the villages (from Udimore onwards) which could all take 20 houses under the Trust scheme; villages are desperate for homes for locals, unless we build something for them they will become fully occupied by elderly residents.
If you move on 30 years, as the generations die off properties will be bought by the buy to let companies because the local people won't be able to purchase them, in turn they will be let out at outrageous rents that only drug addicts and people who receive benefits can live for, do we want that?

MOD 12.5 pg80 Policy RA1

Each village could take a number of houses under the Land Community Trusy instead of the 1 or 2 mentioned in the Rother Core Strategy Modifications.

Chapter 8 vii 'Provide for employment and housing growth'

Employment work units and shops should be pursued which are affordable for any starter businesses. If the council control the sites and sell these units for cost for new people then the council will have control to monitor these people and see what is happening within businesses, this also means that the extra land can be rented rather than put on the market to be unused or misused.

Supplementary information submitted with the representation can be found here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=20689
http://www.rother.gov.uk/CHttpHandler.ashx?id=20673

I think you will already be aware that we have a legal duty to supply new developments with water but in some cases we will also need to reinforce our mains network if we are to continue to meet levels of service for both new and existing customers. If the rate of development is increased it is likely that reinforcement will be required sooner as our network is already nearing capacity in some areas. Developers may be required to make a financial contribution towards this work.

The further increase in proposed new housing for Catsfield from a span of 0 - 30 to 47 is not legally compliant or sound with National or Rother DC's Policies:

Referring to NPPF - Paragraph 54.
In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites were appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs.

Rother Core Strategy 7.41, 7.43(c), 12
7.41 Rural communities in particular are keen to ensure that development in villages contributes to their character and sustainability of services, as well as meets local needs (such as for affordable housing, play areas, community halls, etc). Hence, development in rural areas should be set at a level which allows for limited growth, reflecting individual settlement's needs, opportunities and service provision.
7.43 The overall impact of the distribution of new development proposed set out below (and in chapter 12 for individual villages) is to maintain the existing settlement pattern. It both supports the role of the main service centres in ways compatible with their context and provides for the sensitive evolution of smaller settlements, with a focus on enabling them to meet local needs locally.
7.43(c) facilitate the limited growth of villages that contain a range of services and which contributes to supporting vibrant, mixed rural communities, notably in relation to service provision and local housing needs, and is compatible with the character and setting of the village;

MOD 12.6 p81 [Insert]
Potential new sites' in Figure 12 refers to sites expected to be formally allocated via the Development and Site Allocations DPD or Neighbourhood Plans. These will normally comprise development sites accommodating 6 or more dwellings.
Previously unidentified large sites (6 dwellings and over) in a village gaining planning permission before adoption of the relevant DPD/Plan may be deducted from the total 'Potential new sites' that an individual village is expected to achieve, depending on the stage reached and the suitability of other potential sites.
Developments of less than 6 dwellings, on currently unidentified sites, will count towards the overall rural housing numbers total as 'small-site windfalls'; an estimated allowance for them has been included for years 5-15. Therefore, to avoid double counting, they are in addition to the 'Potential new sites' for individual villages.
Affordable housing 'Exception sites' are typically between 6 and14 dwellings. In common with small site windfalls, they are dealt with in a separate row on Figure 12. Hence, they cannot be deducted from the 'potential new sites' totals for villages, since to do would entail double counting. The estimated number of 65 dwellings on 'Exception sites' across the rural areas for the plan period is based upon figures derived from the Council's Housing Strategy.

The number of additional dwellings is disproportionate to the size of the Village (the development boundary has 133 dwellings against the total of 64 additional houses proposed) and does not correspond to 'limited' growth. Rother DC has not undertaken a local needs consultation prior to this publication so cannot be aware of what reflects the local needs. Our Catsfield Local Action Plan 2009 - 14, which does reflect the local needs, has been disregarded. To quote from page 21:-
'The majority of residents in Catsfield did not want to see any major housing developments and overall it was felt that there was no real need for more property to be developed. Some residents were happy to see some "affordable housing" developed but in this respect the schemes available are not full proof in offering housing only to Catsfield residents or relatives of and so we propose to limit future large scale development as much as possible.

We have already been earmarked to provide a further 40 dwellings by 2026 according to the Rother Local Development plans and to this end we have already seen a significant number of "in fill" properties and the Parish Council will make sure that these "count" towards our final total'

The scale of the developments, which will be dictated by the caveat to be inserted after figure 12 in the Core Strategy - 'Potential new sites in figure 12 refers to sites expected to be formally allocated via the Development and Site Allocations DPD or Neighbourhood Plans. These will normally comprise development sites accommodating 6 or more dwellings', will not be in character with the Village. Developments of more than 6 dwellings are not characteristic of the village and are in danger of creating an enclave. The impact on our current services will be overwhelming as opposed to sustainable

The number of additional houses is disproportionate to the size of the village and does not correspond to limited growth. Rother has not completed a local needs consultation before this publication and therefore cannot be aware of local needs. Our current Catsfield Local Plan which has consulted local residents states that residents did not want to see any major housing developments.

The scale of the developments which will be dictated by the caveat inserted after figure 12 in the Core Strategy will not be in character with the village. Developments of more than six houses are not characteristic of the village and the whole ethos of the village will change with such a large development. Current services will not be able to cope with such an influx.

The number of additional houses is disproportionate to the size of the village and does not correspond to limited growth. Rother has not completed a local needs consultation before this publication and therefore cannot be aware of local needs. Our current Catsfield Local Plan which has consulted local residents states that residents did not want to see any major housing developments

The scale of the developments which will be dictated by the caveat inserted after figure 12 in the Core Strategy will not be in character with the village. Developments of more than six houses are not characteristic of the village and the whole ethos of the village will change with such a large development. Current services will not be able to cope with such an influx.

The proposal to increase housing numbers in the villages conflicts with the NPPF and with the spatial and strategic policy objectives of the district which are unmodified.

The methodology leading to the increase in housing numbers in the villages is fundamentally flawed and unsound and wholly unrelated to policy considerations. The decision to increase housing numbers in the villages is driven exclusively by the objective of spreading the district-wide 5700 unit number.

The NPPF states at paragraph 54 that in rural areas local planning authorities should plan housing development to reflect local needs. The Local Plan Strategy spatial and strategic policy conforms with this NPPF policy. This policy has not been modified. The level of growth and the location of growth must be policy-led. Only if the level of development proposed in any village was unreflective of its local needs could a modification to its individual allocation have been justified. However, no local needs based analysis was undertaken or affected the modifications decision.

Further, the modification to village housing numbers conflicts with national policy on localism and neighbourhood planning as the Council seeks to impose a prescriptive amount of development on individual villages which is unrelated to the villages' needs in order to bind the villages at the Neighbourhood Planning stage to these levels of growth. This means a village would be compelled to provide for an amount of housing development unrelated to its local needs, in conflict with NPPF paragraph 54 and with Local Plan strategic policy, were it to comply with NPPF paragraph 184 on the amount of development. This illustrates why the modifications are unsound.

With specific regard to Catsfield, there is an additional policy reason why the proposed housing allocation is unsound. The existing settlement size was assessed in 2008 in the village settlements study as 133 households meaning it is a small village in Rother District. Plainly, the level of growth proposed for Catsfield over the plan period - 64 dwellings - is far too high and wholly disproportionate to the size of the existing settlement. An important caveat to the identification of Catsfield as a "local service" village was provided at paragraph 12.15 of the Local Plan Strategy and this text has not been deleted. This text led to the original allocation of the 7-37 range for Catsfield in Figure 12, allowing Catsfield to plan within this range for the number of dwellings required to meet its local needs, insofar as this is proportionate to its existing size and character. It is not possible for the Council to renegue upon this undertaking now, given the settlement hierarchy was consulted upon with this important caveat in place and relied upon, and in any case the undertaking is retained unmodified.

This is an objection to footnote 5 to Figure 12 (MOD 12.5) and the proposal in MOD 12.6 to prevent a village counting housing developments of fewer than 6 dwellings in the amount of development prescribed to be met in Figure 12 settlement allocations.

This modification, which is wholly unjustified in policy terms, also conflicts with national policy on neighbourhood planning and localism. It is a fundamental principle in national policy that any neighbourhood can plan the nature of the development which takes place within its community provided the amount of development is consistent with the Local Plan Strategy (paragraphs 184 and 185). For a village, the amount should be reflective of its local needs. Once that amount has been evaluated, the village (like any other community) is free to determine how that amount is to be developed. The Council cannot prevent any neighbourhood, including a village, using developments of fewer than 6 dwellings to achieve the amount of development within its community in a Neighbourhood Plan. Therefore the objective of this modification is to bring a planning function properly within the remit of neighbourhoods within the control of the Council and this is unsound.

This substantially alters the meaning of Figure 12 and it is not transparent. It is clear the purpose of the footnote and text modification is to maximise use of the villages to achieve the modified district-wide 5700 housing unit figure.

Further, the type of development most characteristic of the pattern of development in villages consists of developments of fewer than 6 dwellings. To seek to prevent villages continuing to evolve in this manner further conflicts with the Council's unmodified strategic policy for the villages and is therefore unsound.

This modifications sets to find ways of increasing numbers in villages which for Rother means villages in AONB, so the NPPF criteria apply. It does not appear than RDC have applied this in simply increasing numbers so the higher original allocations get more. RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong in principle to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC. Therefore the whole principle of identifying numbers for each village is clearly unsound whether they are stay the same in the modification or in many cases now an increased number.
In light of the increases suggested for certain villages the only possible way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.

Distribution of Rural Housing Allocations
Proposed Modifications nos. MOD 12.4 and 12.5

1. These representations (TCPS Representations No. 3), should be read in conjunction with representations submitted in response to proposed modification numbers 12.1, 12.2 and 12.4 (TCPS Representations no. 2). These representations make the case that the draft Policy RA1(v) (MOD 12.4) should be further modified to refer to "at least 1,670 additional dwellings".

2. Although not a proposed modification, the draft policy also states that new housing allocations "will be located in accordance with Figure 12, subject to refinement in light of further investigations by the Development and Site Allocation DPD and/or Neighbourhood Plans". In light of the Council's recognition of the need to increase the housing requirement generally in the District (compared to the submitted draft version of the Plan) and given that the Council has more recently accepted that additional sites might be identified as part of the Site Allocations/ Neighbourhood Plan stage, the purpose and function of Figure 12 is now questionable and should be deleted with further modifications to Policy RA1(v) as required. If retained however, it should at the very least be regarded as providing illustrative housing numbers only for each settlement in relation to column 3 (allocations) and column 4 (potential new sites).

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.

Figure 12: Distribution of rural housing allocations
MOD 12.5- Housing Allocations at Netherfield

1. These representations (TCPS Representations No. 5) relate to Rother District Council's proposed modification to the distribution of rural housing allocations as set out in Modified Figure 12 (MOD 12.5). These representations should also be read in conjunction with TCPS Representations nos. 2 - 4, which made the case that housing provision in villages could be modified to provide at least 1,672 dwellings and that Figure 12 should be deleted or the proposed housing allocation figures should be for illustrative purposes only in order to avoid prejudicing consideration of all potential housing sites as part of the forthcoming site allocations/neighbourhood planning process. In particular, paragraph 4 of TCPS Representations No. 4 indicates that there are examples where the Council's updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) is open to challenge as individual site potential cannot be properly assessed or open to scrutiny without the detailed site allocations process being undertaken as Part 2 of the Local Plan.

2. These representations (i.e. TCPS Representations No. 5) provide an example of potential housing land at Netherfield, which has up to now, been discounted in both the March 2010 and June 2013 versions of the Council's SHLAA. These representations relate to site no. NE2 in both versions of the SHLAA (see relevant SHLAA extracts contained in appendix 1).

3. In 2010, the Council considered the land to be poorly related to the existing built up area boundary and that other sites in Netherfield were preferable whilst in the 2013 update, the Council have added concerns about landscape views into and out of the site and potential ecology issues.

4. The Council's Rural Settlement Study (see extract contained in appendix 2) sets out the 'function' of Netherfield (which includes an assessment of local facilities and services) and its proximity to the nearby town of Battle, which is "within a five minute drive-time". The analysis indicates that there is a need for affordable housing and that there may be potential for allocation of up to 15 dwellings by 2026. Thus, although a relatively small rural settlement, it has a good range of local facilities for its size (which includes primary school and bus services) and effectively forms a satellite settlement for the higher order town of Battle (which has secondary schools, a mainline railway station, good range of retail facilities and employment provision).

5. The land the subject of site NE2 in both versions of the Council's SHLAA is not 'poorly related to the existing built up area boundary', as it is located immediately adjacent to it as shown by the annotated version of the Local Plan Inset Map no. 24 contained in appendix 3. Public views into the site are almost entirely screened by existing development and by the local topography. While to the north there is an area of ancient woodland, this is some distance away from the site and would not be adversely affected by any development proposals. Furthermore, any ecological impact could be satisfactorily mitigated on site.

6. Drawing no. 4376/1/A (contained in appendix 4) illustrates how the site might be developed to provide around 66, two, three and four bedroom dwellings including 40% (26 - 27 units) affordable accommodation. Other elements of the illustrative layout show;

i. A potential expansion of the playing field serving Netherfield C of E Primary School (which is located immediately adjacent to the site to the west) in exchange for a footpath/cycle link to the village school and shop/post office;

ii. The expansion of the village recreation ground which is located immediately to the east of the site, together with the provision of additional public car parking;

iii. The provision of amenity landscape buffers to the rear of properties that front onto Netherfield Road to the south of the site;

iv. The retention and reinforcement of existing woodland within the northern part of the site to include the retention and expansion of an existing watercourse to create a wetland habitat or expanded pond;

v. Additional woodland planting to provide a substantial landscape buffer between the potential housing area and the ancient woodland located further to the north of the site.

7. Appendix 5 contains a Transport and Sustainability Appraisal, which demonstrates how suitable access can be achieved and the alternative modes of transport available. The development of the land would not only provide potential for expanding the school playing field, but also the housing development itself would help sustain the school numbers and ensure its continued viability as a community asset. The existing school role figures indicate that there is currently projected spare capacity (see the figures contained in appendix 6).

8. lt is fully appreciated that it is not the role of the Core Strategy to identify individual housing sites, as this will be the purpose and function of a Site Allocations Plan (or Neighbourhood Plan) in due course. The point is however, that this land clearly has potential to provide a wide range of community benefits including affordable housing and a further assessment of its potential as part of the site allocations/neighbourhood planning process should not be prejudiced by either the updated SHLAA assessment (which is not a policy document) or as importantly, the housing allocation figures currently contained in Modified Figure 12 of the Core Strategy. Furthermore, the modified housing allocation figures should not prejudice a proper assessment of alternative sites at Netherfield at the later site allocations/neighbourhood planning stage.

9. At present, modified Table 12 indicates that Netherfield has potential for
48 dwellings on 'New Sites' (column 4). This appears to relates to SHLAA (2013) sites NE1, NE5A and NE11, but as also indicated in the SHLAA assessment (contained in appendix 1 attached) this land also has various constraints listed including the availability of a suitable means of access. No doubt this land will be the subject of further investigation at the site allocations/neighbourhood planning stage, but this land should also be examined in the context of the considerable public benefit that could arise if the land the subject of NE2 were to be developed instead. Sites NE1, NE5A and NE11 (if actually available and deliverable) would not offer the range of community benefits as identified by the illustrative layout contained in appendix 4 attached and this was not available to the Council at the time it produced either its original SHLAA in March 2010 or its updated SHLAA in June 2013.
Supplementary information submitted with the representation can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20687

Figure 12: Distribution of rural housing allocations
MOD 12.5- Housing Allocations at Fairlight Cove

1. These representations (TCPS Representations No. 7) relate to Rother District Council's Proposed Modification to the distribution of rural housing allocations as set out in Modified Figure 12 (MOD 12.5). These representations should also be read in conjunction with TCPS Representations nos. 2 - 4, which made the case that housing provision in villages should be modified to provide 'at least' 1,672 dwellings and that Figure 12 should be deleted or the proposed housing allocation figures should be included only for illustrative purposes in order to avoid prejudicing consideration of all potential housing sites as part of the forthcoming site allocations/neighbourhood planning process. In particular, paragraph 4 of TCPS Representations No. 4 indicates that there are examples where the Council's updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) is open to challenge as individual site potential cannot be properly assessed or open to scrutiny without the detailed site allocations process being undertaken as Part 2 of the Local Plan.

2. These representations (i.e. TCPS Representations No. 7) provide an example of possible housing land at Fairlight Cove, the subject of site no. FC2 in the Council's March 2010 and June 2013 updated versions of the SHLAA. In 2010, the Council considered the land to be suitable, deliverable and available as a potential 'green' status housing site with scope for approximately 30 dwellings. For reasons which are not clear, in the June 2013 updated version of the SHLAA, the site has been downgraded to having an 'amber' status with a reduced estimated potential for 20 dwellings (see SHLAA extracts contained in appendix 1 attached).

3. The Council's Rural Settlement Study (see extracts contained in appendix 2) sets out the function of Fairlight Cove, which has a fairly large population compared to most other Rother villages. This is likely to be a reflection of its close relationship with Hastings to the west, which has a wide range of services including a mainline railway station with direct connections to Tunbridge Wells and London. Other railway stations are about three miles away at Three Oaks and at Ore.

4. There is an existing allocated housing site within Fairlight Cove (at Fairlight Gardens), which is the subject of SHLAA site no. FC1 and Policy VL3 of the adopted Local Plan (see Inset Map no. 14 of the Local Plan's Proposals Map reproduced in appendix 2). Despite the land being allocated for at least 15 dwellings (including 40% affordable housing), the land has not been developed and no planning application has been submitted since the Local Plan was adopted in July 2006. This must give rise to some doubt as to whether this land will come forward for housing development in the future.

5. SHLAA site FC2 adjoins the existing built up area boundary at Fairlight Cove on three sides (to the north, west and south). It is a relatively large parcel of land of around 3.14 hectares, although the Council has assessed the land as having potential for only around 20 - 30 dwellings. The land clearly has potential to accommodate a greater number of housing units as well as having scope to include other community facilities such as allotments or public open space.

6. Modified Figure 12 (MOD 12.5) provides for 17 dwellings as an existing allocation plus 20 dwellings as 'potential new sites'. As there appear to be no other available, suitable or developable housing land at Fairlight Cove, site FE2 is a key candidate site to help meet future housing needs (including affordable housing provision). To set an arbitrary limit of 20 dwellings in Figure 12 would prejudice any potential for additional housing development on the land as part of detailed investigations and submissions at the forthcoming site allocations/neighbourhood planning stage. Given the area of land available, the land clearly has potential for providing more than just 20 dwellings.

Supplementary information submitted with this representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20685