MOD 12.6

It is inappropriate to include previously unidentified large sites(6 dwellings and over)as contributing towards "Potential new sites" prior to adoption of the Plan as the Council consider the target of 5700 as a minimum. Any sites granted consent prior to the Plans adoption are clearly windfall sites that fall within this unidentified category and therefore should be viewed as such and not used to reduce the Councils minimum target. This approach should also apply to developments of less than 6 dwellings and "Exemption sites"

Mod 12.6: main modification not Sound.
All housing granted permission should be taken against the total housing allocation for that village. To not do so would make housing number unsustainable. The rural areas sustainability report is tenuous as to whether further development can be sustained.

This insertion reflects the numbers game RDC is forced to play. The fact is that some villages have no allocations and therefore any windfall sites wherever in the rural areas are counted against a total rather than a total for a particular village. This does not take account of the impact of any development in a village with an allocation of housing. Any windfall site within a village with an allocation should be deducted from their allocation.

The additional text which is proposed to follow Figure 12 would seek to restrict the level of development in the rural area if 'previously unidentified' sites were to come forward in advance of a site allocations DPD. This proposed modification appears to be inconsistent with the new housing target, which is a minimum figure (proposed modification 7.6), and which has only been limited due to the Council's belief that there may be limited capacity for development within the District. The Council's evidence shows that there is a need for more housing tom be delivered within the housing market area than has been proposed in these modifications.

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We understand that the 'previously unidentified' sites referred to here would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.

12.6 "states depending on the stage reached and the suitability of other potential sites".

This is contrary to NPPF policies across the board and in its principle of protecting existing communities and the environment. This allows for a builder's charter to be in operation and is a gross misuse of power and practical application. Point 17 NPPF principle 5 states "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it ".

We are pleased that the document no takes on board the thrust of the new LPPF document and no longer refers to the defuncy South East Plan. The increases in housing supply are welcomed which will aid to create a more prosperous local economy which will in turn be significantly beneficial to local communities.

MOD2.2 The inserted text is welcomed but we see no necessity for the final sentence which makes reference to the South East Plan which is no longer applicable, by referencing it as a document only causes unnecessary confusion. Future infrastructure investment should now be based on the new LocalPlan. The final sentence should be deleted.

MOD 7.1 The new reference to the 4,800 dwellings as set out in the South East Plan is unnecessary.

MOD 7.5 The increased supply to at least 5,700 is to be welcomed.

MOD-7.6 We seek to alter the proposed paragraph 7.30 as follows: (changes in CAPS)

7.30 This growth is justified primarily in terms of COMPLYING WITH THE NPPF TO INCREASE HOUSING SUPPLY AND contributing to the projected demand for new homes, as well as in meeting the local need for housing and the need to support economic regeneration. The possibility of further opportunities for sustainable housing (as well as employment) development arising over time is A DISTINCT POSSIBILITY; hence the requirement is expressed as a minimum QUANTUM for the purposes of plan making. These will be further assessed as part of site allocations/neighbourhood planning processes.

MOD 7.9 With regard to the additional sentence; please consider adding 'modest' prior to 'potential' and insert 'detailed' prior to 'assessment'.

MOD 7.10 Please delete the additional modification as it is not necessary.

MOD 7.12 The increased housing provision figures at 5,700 are welcome as a minimum provision.

MOD 7.13 After the words 'sites are assessed' please add 'or subject to planning applications'.

MOD 7.14 Figure 8; the increase for the Villages to have 1,670 dwellings is welcomed.

MOD 7.18. At the proposed paragraph 7.57 the Council is taking windfalls into account. In terms of making an assessment of the 5 year land supply, is the Council making an allowance for the non­ implementation of planning permissions. We suggest that a percentage figure based on evidence be used in order to have a fair methodology.

MOD 8.5. Add on to the modification 'and that this delivery rate will be monitored on an annual basis'.

MOD 8.7. Delete 'support' or 'deliver' and add on to the final sentence 'or to allocate fresh housing land via planning permissions or alternative allocations'.

MOD 8.10. Delete 'marginal but critical' for 'strategically important'.

MOD 9.1 We object to the inclusion of the modification and seek that it be deleted.

MOD 12.4. We support the additional dwelling supply.

MOD 12.6. After 'Neighbourhood Plans', please add on 'or newly approved planning permissions'

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.

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.

Please see our comments on Mod 7.11 (see below) which are relevant here and the whole mod needs re-writing to ensure that windfall sites in villages ARE counted towards the allocations each village has.
Mod 7.11: We support the amendment emphasising absolutely the words from ' without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.