MOD 16.2
Object
Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21325
Received: 02/09/2013
Respondent: Devine Homes
Agent: Courtley Consultants Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The proposed amendment provides no strategic guidance for employment especially in the Rural Area i.e. Robertsbridge. This is inconsistent with NPPF paragraph 19 and 28.
The Employment Strategy and Land Review suggested a provision of 10,000sq m for Battle(a settlement
in the AONB)yet no employment provision is set for the largest sustainable rural settlement-Robertsbridge. An overall target of 10,000sq m is set for the Rural Areas but this does not set out any proper strategic guidance or sequential approach based on individual settlement sustainability.
Policy EC2 in the Deposit Plan clearly sets out in paragraph its objective of (iii) "Improving the supply and range of small-medium sized sites, in towns and villages which act as local service centres, particular those that have good strategic accessibility(i.e. to the A21 road and rail corridor)"This objective should remain. This paragraph gives clear guidance on the strategic sustainable criteria over where employment sites should be directed. Indeed, settlements should be rightly identified where appropriate employment targets can be meet. The proposed amendment provides no strategic guidance for employment especially in the Rural Area i.e. Robertsbridge. This is inconsistent with NPPF paragraph 19 which state "Significant weight should be placed on the need to support economic growth through the planning system" The NPPF (para 28) state that planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development.
The Employment Strategy and Land Review suggested a provision of 10,000sq m for Battle(a settlement
in the AONB)yet no employment provision is set for the largest sustainable rural settlement-Robertsbridge. An overall target of 10,000sq m is set for the Rural Areas but this does not set out any proper strategic guidance or sequential approach based on individual settlement sustainability i.e. priority to sustainable towns and villages.
The Council appear to have deleted its previous paragraph (iii) purely because it did offer strategic guidance "in towns and villages which act as local service centres, particularly those that have good strategic accessibility(i.e. to the A21 and rail corridor)". This does appear to point towards Robertsbridge as a suitable sustainable settlement for further employment provision.
Object
Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21427
Received: 27/09/2013
Respondent: Cllr Susan Prochak
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Not specified
Support the retention and development of employment sites. Acknowledge there should be ability for developers to balance employment with some enabling housing as long as the housing does not override the employment opportunities.
However, removal of the specific support for improving employment opportunities in the towns and villages which act as local service centres, gives developers more freedom to over ride the employment designation of sites. Rural employment sites already designated as such must be retained.
Support the retention and development of employment sites. Acknowledge there should be ability for developers to balance employment with some enabling housing as long as the housing does not override the employment opportunities.
However, removal of the specific support for improving employment opportunities in the towns and villages which act as local service centres, gives developers more freedom to over ride the employment designation of sites. Rural employment sites already designated as such must be retained.
Support
Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21429
Received: 27/09/2013
Respondent: Salehurst & Robertsbridge Parish Council
The Parish Council considers the retention of existing employment sites to be an important aspect in maintaining sustainability for additional development.
The Parish Council considers the retention of existing employment sites to be an important aspect in maintaining sustainability for additional development.
Object
Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21560
Received: 27/09/2013
Respondent: Robertsbridge Enterprise Group
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Tthis proposal does not adequately protect the existing use of employment land particularly in villages such as Robertsbridge. This problem is exacerbated by the recent changes to changes of use legislation.
An industrial estate except in exceptional circumstances is not appropriate to a village, especially where villages have grown up with some industrial life in them.
So provision for commercial activity needs to be integrated into the grain of the villages.
Therefore there needs to be stronger protection in terms of a policy for retaining existing business use and the amendment to the policy EC2 does not achieve that.
We believe that this proposal does not adequately protect the existing use of employment land particularly in villages such as Robertsbridge. This problem is exacerbated by the recent changes to changes of use legislation.
An industrialestate except in exceptionalcircumstances is not appropriate to a village, especially where villages have grown up with some industrial life in them.
So provision for commercial activity needs to be integrated into the grain of the villages such as Robertsbridge.
Therefore there needs to be stronger protection in terms of a policy for retaining existing business use and the amendment to the policy EC2 does not achieve that.
Object
Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21574
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Whilst we broadly support the aim of this change, as with Mod 16.1, mixed use creeps in here without any restraint all. Mixed use development has to be a last resort after all alternatives have been explored. It would be helpful also to have a definition of what is meant by strategic since what was a proto definition in the previous version has been removed in this latest one.
If particularly a village is to be sustainable and to remain so, there needs always to be economic activity and that demands sites. Otherwise a village will no longer be sustainable.
Whilst we broadly support the aim of this change, as with Mod 16.1, mixed use creeps in here without any restraint all. Mixed use development has to be a last resort after all alternatives have been explored. It would be helpful also to have a definition of what is meant by strategic since what was a proto definition in the previous version has been removed in this latest one.
If particularly a village is to be sustainable and to remain so, there needs always to be economic activity and that demands sites. Otherwise a village will atrophy and no longer be sustainable.