QUESTION 1: Do you have any comments on the supporting Sustainability Appraisal (SA/SEA) that is published alongside this document?

The Sustainability Appraisal (SA) is based on the Core Strategy (CS) which was approved in 2014 but based on earlier data. The Inspector, having considered evidence advised that if the economy improved significantly it could lead to higher housing need. The 2014 ONS population data has proved need has increased. The CS Inspector's conclusion was based on the need for the Council to review and ensure that the CS was up to date. This has not happened.

The SA has not considered increased need and has relied on the CS requirement. Consequently the SA is inadequate and should be revised.

Full text:

Q.1
The Sustainability Appraisal (SA) is based on the Core Strategy (CS). The CS was approved in 2014 but is based on earlier data, in particular the ONS population projections for 2011 which have now been overtaken by those for 2014. The CS inspectors report noted that the objectively assessed requirement for Rother of 338 households per annum based on ONS 2011 was significantly less than that based on 2008 "How Many Homes" model (584 households per annum). The Inspector, having considered evidence from the RTPI Research Report No.1 Jan 2014 advised that if the economy improved significantly it could lead to higher levels of housing need. The publication of the 2014 ONS population data has proved that need has increased. The CS Inspector's conclusion that the CS was sound was based on the need for the Council to review this matter and to ensure that the CS was up to date. This has not happened.
The Sustainability Appraisal has not considered this increased need and has merely relied on the CS requirement. Consequently the SA is inadequate and should be revised. This is likely to result in an increase in the requirement above that identified in the CS which should be reviewed. A sites allocation document based on levels of housing requirement which are inadequate will not be sound.

Q.8
Option B is preferred on the basis that the delivery of sites for all housing types should be the priority and this option would achieve that objective.
Q.78
Site NO7 and NO8 are preferred.
As set out in the response to Question 1 the current housing requirement for Rother is not met by either the Core Strategy or the proposals in the Local Plan. More housing will be required and Northiam is a sustainable location with schools, shops, bus service and other amenities.
Amendments to the boundaries of NO7 and NO8 have been made, see attached drawing, in order to overcome landscape objections as set out in the SHLAA analysis of these sites. NO7 is now confined to the redevelopment of redundant farm buildings which will give an improvement to the natural beauty of this area of AONB by the replacement of unsightly and dilapidated buildings with those of high quality design and additional landscaping. NO8 will now provide a completed of the street scene along Dixter Road.
Both sites are well related to the services as they lie adjacent to the centre of the village and consequently represent better potential for non-car use than other sites considered as part of the SHLAA.
It is expected that NO7 would deliver 6 units and NO8 would deliver 15 units. The access to NO7 is considered adequate in respect of the numbers of units now proposed.
Additional supporting information was submitted and can be viewed here: http://www.rother.gov.uk/CHttpHandler.ashx?id=28107

1. Executive Summary

1.1. These representations are made on behalf of The Blue Cross, to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation. The Consultation runs until 20th February 2017.

1.2. Once adopted, the Development and Site Allocations Local Plan will sit alongside the Core Strategy as part of the Development Plan. Rother adopted the Core Strategy in 2014. This does not include allocations of land to meet the stated targets, hence the need for a further strategic document (the DaSA) to do this.

1.3. The representations are submitted in light of the promotion of two sites currently owned by The Blue Cross but which are no longer in use for their initial purposes. The first site, the larger of the two, is located in Northiam, and comprises an area of circa 3.9 hectares of land, part of which represents previously developed land. The Site lies adjacent to the existing settlement and formed part of the Blue Cross animal welfare centre which was permanently closed on 14 October 2016. Other land adjacent to The Site is also owned by The Blue Cross but is not the subject of our representations or put forward as a proposed allocation.

1.4. The second parcel of land has an area of circa 0.5 hectares and comprises a grazing paddock adjacent to the settlement of Beckley. Location plans of the two sites are included as appendices to this representation.

1.5. It is emphasised in this representation that both sites were assessed for their development potential in the 2013 SHLAA and in the Sustainability Appraisal of the DaSA. However, neither of the two parcels are shown in the Options and Preferred Options Consultation Document as preferred development sites.

1.6. It is also emphasised that our client was contacted directly by RDC in 2009 enquiring about the availability of the Northiam Site for development.

1.7. The Core Strategy set a requirement for 335 dwellings per annum through the Plan Period. In order to ensure that this target is met, it is essential that the best and most efficient use is made of available, deliverable housing sites. Both parcels of land owned by the Blue Cross offer important opportunities for housing to be provided over the Plan Period. In addition, The Sites would come forward quickly, helping to address housing shortages and the current 5 year housing land supply in the District.

1.8. RDC supports an insufficient level of growth for Northiam, given the high sustainability credentials of the village and the clear capacity of the area to accommodate growth. It is of concern that such opportunities have not been taken or prioritised in areas such as Northiam despite the clear benefits that would accrue, and in light of the NPPF requirement to boost significantly the supply of housing. Allocation of both sites would help to ensure that RDC can meet its objectively assessed need for housing over the Plan Period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.9. Development of the two sites would meet all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. They would provide a new supply of housing in a popular location and that is highly accessible for local facilities and a range of public transport modes. Through appropriate design, the sites would complement the character of the area including local distinctiveness of both the natural and built environments. As can be seen on the illustrative Masterplan for the Northiam Site, a considerable area of open space would be provided within the sites, clearly providing additional community and local benefits, including from a social and health perspective. The sites would have an attractive, welcoming environment whilst making the most efficient use of land available.

2. Introduction

2.1. On behalf of our Client The Blue Cross, ("our Client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA").

2.2. The Blue Cross is a leading national pet charity that helps over 40,000 sick, injured and homeless pets every year through its rehoming centres, rehoming network service, animal hospitals, clinics, and shops. As a registered charity and therefore being bound by the Charities Act 2011, Blue Cross is obliged to seek professional advice prior to the sale of any land and in doing so to obtain the best possible value.

2.3. The DaSA consultation closes on 20 February 2017. Once adopted, the DaSA will form part of the Development Plan and sit alongside the Core Strategy which was adopted in September 2014.

2.4. The purpose of the DaSA is to allocate land for a range of development types to meet specific targets and requirements set in the Core Strategy. Of most relevance to this representation is proposed allocations for housing. The Core Strategy set a housing target of 335 dwellings per annum (dpa) over the Core Strategy period (2011-2028). However, due to low early completion levels, this increased to 362 dpa between 2013 and 2028, notably 47% higher than the average past completions in the District (para 7.30 Core Strategy). In addition, this housing target is circa 30 dwellings per annum lower than the Objectively Assessed Need for housing (OAN) in the District, as set out in the Strategic Housing Market Assessment 2013. However, at the Examination of the Core Strategy, the Inspector did acknowledge this, highlighting that the housing targets were to be applied as a minimum (see paragraph 43 of Inspector's report).

2.5. Review of the Preferred Allocations in the DaSA indicates that RDC is looking to allocate 1,341 dwellings over the Plan Period. This falls considerably short of the required minimum provision as set in the Core Strategy, even if commitments and completions since 2011 are taken into account.

2.6. It is also a recognised fact the RDC is currently unable to demonstrate an up to date supply of sites, sufficient to provide 5 years worth of housing against the adopted Core Strategy target. The August 2016 published statement "housing land supply as at April 2016" indicates that RDC can only demonstrate a 3.9 year supply. This is likely to have reduced further since April 2016 and therefore puts RDC at risk unless it can find and allocate sufficient land to accommodate the housing growth and OAN of the District.

2.7. In this regard, the Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change, and plans and decision making should be underpinned by the goal of boosting significantly the supply of housing (see paragraphs 14 and 47 of the NPPF).

2.8. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed of various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan.

2.9. Much of the evidence base supporting the Core Strategy remains applicable to the DaSA Consultation. However, additional documents have been published, including:

* Sustainability Appraisal of the DaSA
* Green Infrastructure Background Paper Addendum
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.10. Of these documents, this representation will examine the Sustainability Appraisal and where applicable other evidence from the Core Strategy, including, for example, the Strategic Housing Market Assessment 2013, Assessment of housing need in the Hastings and Rother HMA and Strategic Housing Land Availability Assessment June 2013.

2.11. Whilst many of the other evidence base documents are not applicable to the sites of interest in this representation, we reserve the right to comment further on any of the consultation documents and associated evidence base at a later date in relation to the sites of interest.

Structure of the Representation:

2.12. This representation is divided into the following sections:

* Details of the Sites
* Review of evidence base
* Review of policies and response to specific questions
* Proposed allocations
* Conclusions and summary

2.13. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to incorporate the sites into the emerging plan.

3. The Sites - Northiam and Beckley

3.1. This representation is submitted on behalf of The Blue Cross, and specifically in relation to two sites located in the District, one at Northiam and the other at Beckley. Each are described in this section.

St Francis Fields, Main Street, Northiam

3.2. This site herein referred to as "Northiam Land or "Northiam Site" comprises a number of vacant fields and associated buildings that once formed a functional part of the Blue Cross animal welfare centre. The centre focused on the rest and retirement of horses, and also provided dog and cat re-homing services. The animal welfare centre closed permanently on 14 October 2016. A location plan of the Northiam Site is attached at Appendix 1. A copy is also provided in figure 1 below (not to scale).

3.3. The Northiam Site comprises an area of c.3.9 hectares, part of which falls is now vacant previously developed land. The Northiam Site comprises numerous grazing fields, maneges for horse training, stables, storage structures, dog kennels, a cattery, a small Oast House and a pair of semi detached bungalows with private gardens. All of these buildings and structures are now vacant but remain in situ.

3.4. There are two access points serving the Northiam Site both of which are off Main Street. The northern most access provides the main thoroughfare into and out of the former establishment and is an hardstanding, providing direct entrance into the main complex and parking area. The second access lies further south and is a typical field access, used mainly for farm machinery. Mature planting lies adjacent to this access.

3.5. In addition, the Northiam Site has an additional street frontage to Main Street. There is however a drop in land level to the highway of between 1 and 2 metres. The boundary in this location is defined by mature and overgrown planting.

3.6. The Northiam Land has a varying topography, with levels changing most notably in a northern direction towards Beales Lane and in some places to the west towards Main Street. With the exception of the bottom part of the complex, the land is predominantly open grassland / fields, with some mature planting within and along the boundaries. Land adjacent to the Northiam Site but falling outside of the defined redline area, is also understood to contain trees that are protected by a Tree Preservation Order.

Figure 1: Location Plan of the Northiam Site: http://www.rother.gov.uk/CHttpHandler.ashx?id=28195

3.7. In the immediate area of the Northiam Site there are numerous residential dwellings, including development fronting Main Street that appears to have been constructed relatively recently. Dwellings are typically two storeys in height and a varied materials palette is present in the locality.

3.8. The majority of the village falls within a Conservation Area, which extends along Main Street to a dwelling known as "Nautilus" and along Dixter Road, Higham Lane and High Park. To the south, the Conservation Area extends to the junction of Main Street (A28) with the B2088 adjacent to the Northiam CE Primary School. None of the Northiam Site is within the Conservation Area.

3.9. There are numerous listed buildings within the village. Those in proximity to the Northiam Site located in Main Street include The White House (Grade II), Beachfield (Grade II), The National Westminster Bank (Grade II), The Crown and Thistle Inn (Grade II) and Clinch Green Cottage (Grade II).

3.10. Northiam falls within the High Weald Area of Outstanding Natural Beauty (AONB), as does a considerable part of the District.

3.11. The Northiam Land is identified in the DaSA consultation documents as site "NO16" and "NO19N/E/S". It is also highlighted that in 2009, RDC contacted our client to enquire about the availability of the land for development.

3.12. As part of this representation, an indicative site layout plan has been prepared by OSP Architects and is produced at Appendix 2. This clearly shows the capability of the Northiam Site to accommodate circa 125 dwellings with new areas of public open space that not only protect the character and appearance of both the built and natural environments, but also provide good quality amenity space that can benefit the health, wellbeing and social interaction of the wider community.

3.13. Allocation of this site is therefore a very favourable option for the village and should be considered positively by RDC as part of the DaSA.

Land at Kings Bank Lane, Beckley

3.14. This site herein referred to as "Beckley Land or "Beckley Site" has an area of 0.5 hectares, and is located off the eastern side of King's Bank Lane. It lies outside of a defined village boundary, although the boundary of Beckley does not cover a single area, rather it covers various smaller parcels to the west of the larger settlement area.

3.15. The Beckley Land comprises an open grazing paddock which is bound, in part, by mature trees and hedgerow, and to the east by post and rail fencing separating it from an adjacent paddock. This adjacent paddock is understood to have been the subject of various planning applications for residential development of up to 47 dwellings, including, most recently an application for 16 dwellings (reference RR/2016/3286/P). Although these have not been granted planning permission, this site does now form one of RDC's two preferred development options for Beckley, identified as parcel FO12.

3.16. The Beckley Land has direct vehicular access onto Kings Bank Lane, and this is located directly opposite a newly constructed terrace of dwellings which front immediately onto the highway. These form part of a planning permission for the erection of 7 dwellings at a former Public House, allowed on appeal in 2004 (reference RR/2003/3300/P). To the south lies another dwelling with associated outbuildings.

3.17. The Beckley Land is identified as site "FO10" in the DaSA consultation documents.

3.18. A location plan is produced in Appendix 3 and an extract for ease of reference is contained in Figure 2 below. It is noted that this does not show the development as now constructed on the western side of Kings Bank Lane. The blue arrow depicts the site entrance.

Figure 2: Location plan extract (not to scale) of the Beckley Land: http://www.rother.gov.uk/CHttpHandler.ashx?id=28196

3.19. There is a range of dwelling types in the locality, and these vary in age, character and materials palette. The majority of dwellings in the immediate vicinity are however two storey in nature. The site is not subject to any heritage designations nor are there any in the immediate area (including both conservation area and listed buildings). However, the site, as with the majority of the District, is within the High Weald AONB.

3.20. Due to the relatively modest size of this plot, no indicative layout has been prepared. However, assuming a developable areas of two thirds to allow for infrastructure, access, open space and buffer planting, the site can easily accommodate 10 dwellings which would make a very reasonable addition to the village and provide an acceptable density of 30 dwellings per hectare, to ensure the most efficient use of land is made.

4. Evidence Base

Sustainability Appraisal

4.1. Question 1 of the consultation asks for comments on the published Sustainability Appraisal (SA) which accompanies the Development and Site Allocations Local Plan, options and preferred options. The SA assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Table 5 of the SA sets out the scoring used, a copy of which is produced in figure 3.

Figure 3: Extract of table 5 from the SA showing scoring used in Assessment: http://www.rother.gov.uk/CHttpHandler.ashx?id=28197

4.2. RDC proposes only 1 site (of 18 sites) for its preferred allocation in Northiam. This is parcel number NO15. The SA concludes that NO15 has "mostly positive scores reflecting the good accessibility to local services", and that the site scores well against the SA objectives in relation to social and economic considerations. Negative scores are attributed to the site due to its Greenfield status and TPOs in and around the site.

4.3. Our Client's Northiam Site is shown as various parcels in the SA, namely NO19E, NO19N, NO19S (all of which are assessed as one in the SA) and NO16. The SA conclusions on these sites are stated as follows:

NO16:
"Moderately positive sustainability criteria identified, including relatively close proximity to local services in the centre of the village, which would have a positive impact on sustainability by encouraging walking, cycling and the use of public transport. However, significant development in this location would impact negatively on conservation area and allow further visual encroachment into the wider AONB landscape bringing it into direct conflict with Objective 15."

NO19 N/E/S
"Some positive scores reflecting the site's central location and close proximity to services and good accessibility to local amenities. However development would change the character of the wider AONB landscape with visual encroachment to the east of the village. Furthermore, there would be conflict with the integrity of the Conservation Area in direct conflict with objective 15."

4.4. Much of the same reasoning provided for NO15 would apply equally to both NO16 and NO19. Both sites have "good accessibility to local services" and would score well against both social and economic considerations by making positive contributions to the locality and community. Equally, some minor negative scores may result from an environmental perspective, however, as with any development site, there are opportunities to provide substantial enhancements to the natural environment through an appropriately designed layout for a scheme. As such, the overall conclusions are not considered to adequately reflect the position of the Northiam Land and its relationship to the adjacent settlement.

4.5. The conclusions were however drawn on the basis of the scores allocated in the SA. The following table draws together the SA scores of these three sites.

Table 1: SA scoring of NO16, NO19 and NO15 (for residential use): http://www.rother.gov.uk/CHttpHandler.ashx?id=28198

4.6. RDC has negatively assessed and ultimately scored the Northiam Land considerably lower than the one suitable site in the village. However, we cannot concur with these conclusions.

4.7. It appears that the assessment has been based solely on assumptions and there is no foundation to the conclusions or scores attributed. For example, NO19 (N, E and S) is stated to have potential negative effects on objective 2 (improve the health and well-being of the population and reduce inequalities in health). The parcels are collectively of a sufficient size to accommodate high quality area of public open space. They would also form part of a potential development incorporating NO16 and therefore, as a whole, these sites would have potentially significant beneficial effects. This is supported by the illustrative Masterplan in Appendix 2. Such space would have a positive effect on the health and wellbeing of the community, and would also be located where it can help protect amenity of existing occupiers.

4.8. Objective 4 is to reduce depravation and social exclusion. Again, a well designed scheme with a range of dwelling types and tenures can ensure that this objective is met for sites NO16 and NO19. The Northiam Land as a whole may also contribute to achieving objective 5 (raise educational achievement levels) but in any event the contribution towards this objective would be no different to that of NO15,. Therefore the Northiam Land should receive an equal scoring to NO15 of potential beneficial effects.

4.9. Objective 9 is given a strong negative effect score for NO19. This objective is to improve efficiency in use of land and encourage prudent use of natural resources. Both NO19 and preferred site NO15 are located outside of, but adjacent to the settlement boundary. However, NO16 and 19 combined would use both Greenfield and Brownfield land, therefore making an efficient use of the land available. It is highlighted in this regard that part of the Northiam Site is vacant previously developed land, and should therefore be put to an efficient use in accordance with the National Planning Policy Framework (NPPF). The same cannot be said about NO15 which is a wholly Greenfield site.

4.10. The NPPF is very clear that housing supply is to be significantly boosted, and it is the role of the LPA in producing its plan to ensure that this is achieved. As such, allocating an acceptable, albeit large site outside of a settlement for development, which is in part brownfield, should not discourage the efficient use of other brownfield sites and the efficient use of natural resources both on site and in the wider area.

4.11. Furthermore, objective 10 relates to the reduction in congestion and increasing travel choices. Evidently, a larger development will increase the number of vehicles on the local road network. However, there is an urgent need to provide housing and therefore, wherever it is sited, there will ultimately be an increase in traffic generation. This cannot be avoided. Furthermore, The Northiam Land had a former use that would have attracted regular vehicle movements to and from the Centre. This must be taken into account when determining the amount of traffic a development of the Northiam Site is likely to generate.

4.12. On this basis, it is wrong for such considerations to go against the Northiam Sites and no other in the area, unless there is sufficient highway evidence to support conclusions. Such evidence does not appear to exist.

4.13. On this basis, we strongly contest the SA scoring and conclusions particularly for NO19. This should be reviewed and subsequently altered to correctly reflect the relationship of the Northiam Land to the settlement and its ability to positively contribute to the sustainability of the local community.

Beckley

4.14. In terms of Beckley, the DaSA supports two sites for development, namely FO12 and FO15. Our Client's land forms site reference FO10. FO10 was summarised as having both positive and negative effects on the village, including the setting of listed buildings, an historic field boundary and the AONB. In contrast, FO12 located immediately to the east of the site, was summarised as follows:

"Scores well in several SA criteria and strongly positive in terms of access to services and wider transport connections (Objective: 7/8/10). The site scores negatively against Objective 12because of potential surface water flooding mainly on the western half of the whole site. This could be mitigated with the implementation [of] a SUDs scheme. BAP status also impacts onthis site but habitat will be enhanced with further planting along the boundaries. SA scores arebased on the development of land to the rear of the existing Buddens Green estate.Development of the whole site would bring about a wholly inappropriate scale of developmentfor the village and would negatively impact on the AONB landscape. Land to the west of proposed residential area would be suitable as amenity space and the creation of a SUDs scheme."

4.15. It is considered that the conclusions of the two sites are relatively comparable, both having positively and negative effects on the surrounding area. However, this does not appear to be sufficiently reflected in the scoring. Table 2 below provides a copy of the SA scoring for sites FO10, FO12 and FO15.

Table 2: SA scoring of FO10, FO12 and FO15 (for residential use): http://www.rother.gov.uk/CHttpHandler.ashx?id=28199

4.16. FO10 scores positively for objectives 1 and 5 (greater than the two selected sites). It also scores higher (albeit a neutral effect) than FO12 on objective 12 (minimising flood risk) and 14 (biodiversity), and higher (potential positive effects) than both selected sites on objective 3 (reducing fear of crime).

4.17. It is only objective 15 (enhancing the natural and built environments) that FO10 scores lower than the two selected sites. When looking at this scoring very crudely, there is clearly no reason why, having scored lower on only 1 objective, FO10 has been rejected as a preferred allocation.

4.18. This is particularly so, given that FO10 and FO12 are located immediately adjacent to one another and therefore, have a comparable relationship to the natural and built environments. There is clearly no justification for different scores being given to these two plots on the basis of impact.

4.19. Subsequently, we cannot agree that FO10 should be rejected as a preferred site for housing. It is clear that FO10 is a suitable site, scoring better in many categories than the selected site at FO12 immediately adjacent to it. RDC should therefore reassess the FO10 in the SA and provide a more accurate appraisal that sufficiently reflects the site and its relationship to the neighbouring, preferred site. It should also be allocated for housing as part of the DaSA.

4.20. Recommendations: Update and correct the SA review of the Northiam Land (NO16 and NO19), in addition to providing a fair review of the Beckley Land (FO10) which appropriately reflects the relationships of the sites to their surroundings.

Site Assessment Methodologies Background Paper

4.21. The purpose of this document is stated to provide a consistent and transparent methodology for assessing sites are part of the DaSA proposals. The general approach to determining if a site is appropriate for inclusion in the DaSA is stated to comprise the following key aspects:

* "ensure that it accords with the development strategy contained within the adopted Core Strategy
* be consistent with the 'core', strategic policies of the Core Strategy
* support 'sustainable development' as defined by the National Planning Policy Framework (NPPF) and
* otherwise is consistent with its policies
* duly consider the deliverability of development
* have regard to the findings of the separate Sustainability Appraisal process"

4.22. Our Client's two sites at Northiam and Beckley have been assessed as part of the DaSA, but neither are included as proposed site allocations. This is despite RDC showing some interest in the opportunity of the Northiam Site in 2009 as to its development potential, and despite the status of part of the Northiam Site as vacant previously developed land. This representation however clearly demonstrates that the allocation of the two sites would be entirely acceptable and consistent with the NPPF and adopted policies of the Core Strategy, particularly in terms of housing delivery and meeting objective assessed needs for housing in the District. It has also been demonstrated that the Northiam and Beckley Land should have scored more positively in the SA and that both parcels of land can come forward quickly to contribute to housing delivery. Therefore, on the basis of the above, the assessments of the sites should have been more positive and both should form allocations in the DaSA.

4.23. No further comments are provided at this stage in respect of the Site Assessment Methodology. However, Savills reserves the right to comment on this at a later date should the need arise in future iterations of the DaSA Local Plan.

Core Strategy Evidence Base - Strategic Housing Land Availability Assessment

4.24. The SHLAA forms part of the evidence base from the Core Strategy and this also supports the proposals in the DaSA. Therefore, whilst it was produced some 3-4 years ago, the conclusions have influenced RDC's preferred strategy as contained in the DaSA. In fact, the SHLAA site identification numbers have been used in the DaSA and SA to assess the sites and determine the preferred development strategy for the District.

4.25. In terms of the Northiam Land, the SHLAA identifies and assesses the site as separate parcels, with conclusions being drawn that there are significant access issues owing to the historic nature of Beales Lane which would need upgrading. However, by failing to consider the Northiam Site as one, RDC has failed to appreciate that there are many other access opportunities for the Northiam Land which would not have any detrimental impact on the existing road network or historic routes such as Beales Lane. No dwelling would need to be removed from the Conservation Area to accommodate an access to the Northiam Site, particularly as there is already an existing, suitable access serving the land at present.

4.26. The SHLAA states that sites NO19 are not suitable for housing development. However, it is well known that SHLAA assessments are very basic and do not take into account more detailed evidence or policy considerations. It is therefore of concern that the findings of the SHLAA, particularly for NO19, appear to have directly influenced the findings of the SA as examined above. RDC needs to fully justify its conclusions on this site.

4.27. Equally NO16 is stated to have considerable landscape constraints that render it unsuitable for development. No up to date landscape evidence is available to support this conclusion which again appears to have directly influenced the findings of the SA and resultant preferred allocations in this area.

4.28. With regards to the Beckley Site, the SHLAA reference, FO10, was also carried through to the DaSA evidence base and draft Plan. The SHLAA suggests that the site is an integral part of the AONB, has an historic field boundary and although acknowledging the access to the site, concludes that it is unsuitable for development. It should be highlighted that through development, the historic field boundary could be protected. This should not prevent development from taking place. It has also been demonstrated above that the concerns regarding the AONB are unfounded based on the very different conclusions drawn from FO12, immediately adjacent to the site. There is no evidence available to support the conclusions and subsequent objections to the development of the Beckley Site.

4.29. Recommendations: Review the Northiam and Beckley Sites again, having regard to all evidence available including the proposals as now put forward for this site and which form part of this representation.

Core Strategy Evidence Base - Strategic Housing Market Assessment

4.30. The SHMA was produced in 2013 as part of the evidence base for the Core Strategy and covers both Rother and Hastings Districts. The SHMA indicates that over the Core Strategy Plan Period (2011-2028) a total requirement for 6,178 (rounded up to 6,180) additional dwellings exists, as a baseline figure, based on 2011 census data and the 2013 updated population projections. This equates to an annual requirement for 363 (rounded down to 360) dwellings.

4.31. The Core Strategy housing target of 335 dpa (5,700 over the Plan Period) falls short of the OAN by c.30 dwellings per annum, or c.400 over the Plan Period. The Examining Inspector for the Core Strategy however noted that the Core Strategy target is a minimum (para 43). It should therefore be exceeded in order to comply with the requirements of the NPPF, in particular paragraph 47.

4.32. In order to meet the District's housing needs, RDC must allocate sufficient sites in the DaSA to meet the minimum Core Strategy target. As indicated above, the DaSA Preferred Options appears to only allocate sites for 1,341 new dwellings over the Plan Period. This would fall considerably short of the minimum target in the Core Strategy, even if completions and commitments since 2011 were taken into account. Our Client's sites at Northiam and Beckley provide excellent opportunities to meet the housing needs. The Illustrative Masterplan produced in Appendix 2 also shows in more detail that the Northiam Land can accommodate circa 125 dwellings with provision of new areas of public open space. It would make a valuable contribution to the community and should therefore be considered more thoroughly as part of the emerging DaSA Local Plan.

5. DaSA Part B - Development Policies

Question 8: Affordable Housing

5.1. Three options are proposed for affordable housing delivery.

5.2. Option A is to retain the Core Strategy requirements for affordable housing provision. However, the DaSA is clear that this does not accord with the PPG or the written ministerial statement that now prevents contributions being sought on schemes of 10 or less units, or on schemes of 5 or less units in some rural
areas such as AONBs, unless specific circumstances apply. Consequently, by applying the Core Strategy requirement, the Plan would be at risk from challenge unless there is sufficient, up to date evidence to demonstrate a local justification.

5.3. Options B and C reflect the PPG and the most up to date Government advice on affordable housing. These options are unlikely to prejudice or discourage smaller developers from coming forward with smaller housing schemes, and this is particularly relevant in smaller villages where housing will still need to be
provided.

5.4. If a discretionary application of financial contributions is to be applied, RDC must undertake detailed research in order to demonstrate that there are specific locations where the discretionary charge would, and should, be applied.

Question 9: Approaches to Space Standards, Building Regulations and Older Persons

5.5. With specific regard to internal space standards, there is no obligation for a Local Planning Authority (LPA) to adopt standards, but if they do, the Nationally Described Space Standards should apply. These are not compulsory but are important to ensure that a minimum, acceptable living space is (at the very least)
provided by new development.

5.6. RDC must however recognise that the national standards are near identical to the London space standards, and it goes without saying that the characteristics of the District are far from comparable to inner and outer London. Therefore a careful application of the standards, if adopted, would need to be applied to ensure the right type of housing is provided to meet the community's needs.

5.7. In this regard, the application of minimum standards would ensure that a range of dwelling types, sizes and tenures can be provided in the District. It would also ensure that the best use of land can be made to increase the supply of housing over the Plan Period. However, this potential for increased density and use of land would need to be balanced against other considerations, notably local character, and therefore, RDC would need to ensure that a sound policy basis is in place to allow this balance to be drawn. A strong evidence base would also be required to justify different conclusions and applications of the standards in different locations.

5.8. Furthermore, RDC would need to clarify in what instances the standards would apply, including, for example, whether they would apply to conversions or even retrospectively. Further comments will be provided on this subject should RDC seek to include a policy requiring minimum standards to be met.

Question 12: External Space Standards

5.9. In deciding whether to prepare a policy on external standards, such as amenity space and parking, RDC needs to consider what impact this may have on the ability to make an efficient use of land and ensure an appropriate quantum of development can be provided. For example, the proposed policy DHG3 part i) states that gardens should be at least 10 metres in length. In some instances this may be alien to the
prevailing urban grain or simply impractical, and therefore some flexibility should be included in the policy text or accompanying preamble.

5.10. Equally, regard must be given to the wide variety of needs of the community, including those who may not want, or indeed be able to manage a garden space. The policy also indicates that for flats, an appropriate level of useable community space will be expected. Further clarification on this requirement should be
provided to ensure applicants are aware of RDC's expectations on "appropriate" provision.

Question 20: Biodiversity and Green Space

5.11. Proposed policy DEN4 seeks to positively address biodiversity and ecology in the District. Whilst this does come across in the policy, there are some concerns regarding the requirements of part iii), in that by requiring all development to retain and enhance biodiversity, development opportunity on sites will be considerably limited.

5.12. In some instances, this requirement would render an otherwise suitable site, undevelopable. RDC needs to balance this consideration against wider housing needs and ensure that suitable flexibility is in place to ensure land can come forward. This could be achieved through a requirement for full consideration of
existing features, provision of enhancements on or off site, and provision of suitable mitigation. The context of this policy should be considered in more detail, in line with the NPPF requirements for biodiversity and ecology. It is considered that the wording of the proposed policy should therefore be altered.

Question 21: Sustainable Urban Drainage

5.13. Policy DEN5 requires SUDS to be provided on all development unless it is demonstrated to be inappropriate. The associated policy wording should make clear the type and level of SUDS that is expected to be provided on sites, depending on their size, development type and development quantum. This must however account for variations that will be inevitable between smaller and larger development sites, in addition to the cost implications of providing SUDS particularly on smaller development sites.

5.14. The policy as currently worded provides a blanket approach to SUDS which may not, in reality be achievable and could prevent developments from coming forward. In addition, guidance should be provided in the associated policy text as to what other policy objectives the SUDS should aim to achieve (point iv).

Question 24: Comprehensive Development

5.15. It is not clear from the policy in which circumstances this would be applicable. Clearly if it relates to strategic, large scale development sites the policy may have more relevance. However, on smaller sites, in and around villages in the District, it is unlikely that this policy will be applicable. RDC would need to define the parameters of this policy better if it is to form part of the DaSA.

5.16. Although the objective is to secure appropriate funding for necessary infrastructure, development of a scale requiring such significant infrastructure often does come forward together, or when it does not, CIL and S106 contribution (or the equivalent that may come forward as proposed in the White Paper) can ensure
that the necessary infrastructure is delivered. As such, it may be more applicable for RDC to rely on existing Core Strategy policies or to alter the policy text to relate specifically to development of a certain size and type.

Question 25: Development Boundaries

5.17. For clarity of the policy, the types of acceptable development in the countryside should be made clear either by reference to a specific policy in the Plan, paragraphs of the NPPF, or a list of "appropriate" development.

5.18. It may also be necessary to include a review mechanism for development boundaries, particularly in the event that housing targets increase over the Plan Period and there is a need to allocate new sites.

General Observations

5.19. It is noted that there are no specific policies in the DaSA Preferred Options relating to design of development. Although the Core Strategy does provide a general direction under policy EN3, this is very broad and may not provide the guidance or certainty expected by applicants. It is assumed therefore that
RDC will look to rely upon the general design requirements in the NPPF or, alternatively, more specific requirements that may be set in Neighbourhood Plans. alternatively, RDC should look to produce an SPD that provides the level of guidance expected and ultimately ensures consistency in decision making.

6. Strategic Allocations

6.1. Part C of the DaSA provides the preferred site allocations, with chapter 15 covering villages with allocations. The Blue Cross Land at Beckley and Northiam is shown on the options maps but are not indicated as preferred development options for the DaSA.

6.2. Chapter 12 of the DaSA indicates that at least 5,700 houses are required over the Core Strategy Plan Period of 2011-2028. Of these, 1,670 are expected to be provided in villages. It is suggested that 740 dwellings still need to be identified in villages through the DaSA and Neighbourhood Plans, owing to permissions already granted. Figure 15 breaks down the housing requirements for villages and shows thefollowing information:

* Housing requirements as of 1 April 2016
* Housing completions (sites of 6 or more dwellings) between 2013-2016
* Where villages have allocations in the DaSA
* Where villages have emerging Neighbourhood Plans

6.3. The table indicates that for Beckley there have been 6 completions leaving a residual requirement for housing over the remainder of the Plan Period of 20 dwellings. For Northiam the total dwelling requirement is for 123 units. It is suggested that planning permission has been granted for 123 units in the village but that one of the scheme (which is not specified) can only achieve 52 units as opposed to 58 as approved. Therefore, the residual requirement for the village is stated to be 6 dwellings. Both are shown as subject to allocation in the DaSA.

6.4. It is of concern that the figures shown are unclear and non-descript. RDC do not clearly show where planning permission has been granted, when it was granted, or provide any indication that the developments will come forward. RDC need to demonstrate how it can be sure that the sites will come forward and that there is, subsequently, no need for any further allocations in the village. In our opinion, the fact that planning permission may have been granted does not prevent the appropriate allocation of further, deliverable sites in the DaSA. If anything, additional allocations, securing development, would ensure that housing targets are met, housing needs are met, and the objectives of the Government to
boost housing supply significantly are also adhered to.

6.5. In Northiam in particular, evidence is provided in this representation that the Northiam Land is suitable, available, achievable, developable and deliverable within a short period of time. This would not only help ensure that Core Strategy targets are met, but it would also help address the considerable shortfall in housing land supply that currently exists in the District (3.9 years as of April 2016) and ensure that there is flexibility to adapt to growth in the District over the Plan Period. By relying specifically on planning permission granted, there is no guarantee that development will come forward (unless it has already commenced) and therefore, no certainty that the plan will deliver the housing required in this village.

6.6. In this regard, para 12.9 is key. This, referring to the Core Strategy, clearly stages that "Plans should not dismiss sustainable sites simply because other sites have come forward that mean that development targets can be met without it. At the same time it is appropriate to have regard to the general scale of development in a settlement relative to its overall sustainability and status in the settlement hierarchy, as well as having proper regard to the individual merits,
and demerits, of sites."

6.7. As emphasised above in relation to the SA, RDC has not sufficiently assessed the merits or demerits of development on the Northiam Site and has disregarded the land for development based on planning permissions already granted. The Northiam Site is clearly a very sustainable site, in a sustainable, accessible location where it can make a very positive contribution to the local community as well as the District's housing requirements (see Illustrative Masterplan in Appendix 2). This is also emphasised by RDC initial interest in the availability of the land for development. On this basis, the Northiam Site should clearly be included as a key allocation in the DaSA.

6.8. Equally, in terms of the Beckley Site, whilst RDC may have identified two sites that can collectively provide the amount of housing sought for the village, this does not mean that the two sites are the best sites. This is again emphasised by our comments above in relation to the SA, which shows a more positive Sustainability Assessment for our Client's land, but, irrespective of this, the Site is not taken forward as a preferred allocation. The Beckley Site should however come forward as it is just as sustainable as the adjacent FO12 parcel. The Beckley Site would make a very positive contribution to the locality, both in terms of housing requirements, and the character and appearance of the area. On its merits, the site is
clearly very favourable and suitable for development. Again, we strongly contest that the Beckley Site should be allocated for residential development in the DaSA.

6.9. The availability and deliverability of The Northiam Site and Beckley Site is a material consideration of considerable weight, bearing in mind the that RDC does not currently have a 5 year housing land supply and desperately needs to secure suitable housing sites that can deliver in the early part of the Plan Period. RDC also concedes at para 12.14 that the preferred allocations would "meet, and potentially, slightly exceed, the minimum Core Strategy requirements". This approach, to barely meeting targets, does not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, RDC risks the plan being challenged at examination for failing to sufficiently meet housing needs with sufficient flexibility and, ultimately failing to sufficiently conform to the NPPF requirements.

6.10. In our opinion, further review is required of both the Northiam and Beckley Sites by RDC to sufficiently justify their exclusion from the DaSA allocations, particularly on the basis of concerns raised above regarding the SA of these parcels and the impactions of this on the preferred allocations now put forward.

6.11. Question 59 specifically relates to proposed allocations at Beckley Broad Oak and agreement is sought for the proposed preferred allocation and strategy. We cannot agree to the proposals for this area. There is absolutely no reason why the Beckley Site FO10 has not been included in the proposals for the DaSA, particularly as the SA assesses the site more positively than one of the preferred allocations. There is clearly an insufficient level of evidence available to support the DaSA preferred strategy for Beckley and therefore, more robust evidence is required if the Plan is to be unchallenged and ultimately, found sound.

6.12. In addition, question 58 asks about the revised settlement boundary. For the reasons outlined we cannot agree with the proposed settlement boundary and strongly argue that the Beckley Land should be included within the defined settlement.

6.13. Question 78 seeks agreement to the proposed development strategy for Northiam. Again we cannot agree with the proposed strategy and preferred allocation in the village. There are clearly insufficient allocations in the DaSA to meet the OAN over the Plan Period, and insufficient allocations proposed in Northiam to allow for a reasonable proportion of housing to be provided in this sustainable village. It is appreciated that care needs to be taken to conserve or enhance nearby heritage assets. It is also agreed that care needs to be taken to preserve and enhance the AONB. However, these considerations do not only affect Northiam, they affect the vast majority of the District; 80% of the District falls within the AONB. As such, this should not be used as a blanket reason to prevent otherwise appropriate development from coming forward without appropriate scrutinising being first undertaken to support the conclusions. The evidence base for the DaSA does not indicate that a recent assessment of the landscape and AONB has been undertaken to support the Emerging Plan.

6.14. It is also highlighted that site NO15 which is the preferred development site is considerably limited and this is clearly accepted by RDC. The site is also within the AONB and it contains TPO trees. This site is a small parcel and cannot reasonably be considered to meet the growing housing needs of the area let alone the wider District. Further sites therefore must form part of the strategy for the village, and our Client's site in Northiam provides the prefect opportunity for new development, and new areas of accessible public open space, to be provided that would significantly benefit the village.

6.15. Question 80 asks about revisions to the development boundary of Northiam. For the reasons above, we cannot agree to the proposed amendments and clearly argue the case for the inclusion of the Northiam Site in the defined settlement.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, it is considered that the evidence base does not provide a sufficient basis to support the proposed allocations for villages in the DaSA.

7.2. In particular, Northiam is a large village with a range of local facilities. The preferred allocation proposes only 6 new dwellings in the village, on the basis that the allocation has already been "filled" by granted planning applications. This is a sustainable village whereby the most efficient use of available land should be made to secure the housing required in the District. RDC does not take the opportunity to do this nor to meet the national objective of boosting significantly the supply of housing.

7.3. This is particularly relevant given that our client's Northiam Site has been vacant since 14 October 2016, when the animal welfare centre was permanently closed. This vacant site is, in part, previously developed land and should therefore be put to an efficient use to help address local housing needs. Such an opportunity was clearly considered by RDC when in 2009 enquiries were made to our Client with regards to the availability of the Northiam Land for development.

7.4. This representation has also demonstrated that the evidence supporting the allocations in Beckley is inconsistent. The preferred site lies immediately adjacent to our Client's land, but both are given very different assessments in the SA and SHLAA, resulting in the rejection of our Client's Beckley Site.

7.5. The OAN for housing in the District is at least 30 dpa higher than the adopted Core Strategy housing target, and whilst the Examining Inspector indicated that this target would be seen as a minimum, RDC does not appear to have applied the target as such. Instead of looking to, at the very least, meet this housing target, RDC has proposed allocations that total only 1,341 dwellings. Even if past completions and committed sites are taken into account, RDC would still fall short of these minimum housing requirements. It is therefore fundamental that RDC increases the allocations in the DaSA to ensure housing targets are met, that flexibility is contained in the Plan to accommodate change, and that the Plan is ultimately in conformity to the National Planning Policy Framework. Our Client's sites at Beckley and Northiam provide key
opportunities for additional housing allocation sites as part of the DaSA.

7.6. In this regard, it has been demonstrated in this representation that further review is required of our Client's sites at Beckley and Northiam, to allow a fair and reasonable assessment of them against sustainability criteria. This is particularly pertinent as such assessments have ultimately informed RDC's decision to allocate sites. In our opinion, there are shortfalls in the DaSA and its evidence base, and the Options and Preferred Options DaSA Consultation Document does not have sufficient, justified evidence to support the current proposals for the Plan.

7.7. Overall it is considered that the Preferred Options are overly cautious and fail to take the opportunity to provide essential much needed housing in the District. RDC has focused heavily on issues, such as landscape and visual impact in order to limit the amount of development that can come forward. Although these are material considerations, there are numerous other planning considerations that also lie in the balance and must be considered by RDC as part of the plan making process.

7.8. It is considered that much more work is required before the pre-submission plan is finalised in order to ensure the final submitted DaSA local plan can be found sound at examination.

7.9. Savills and The Blue Cross reserve the right to comment further on the DaSA and associated evidence base throughout the plan making processes and future consultations.

Appendix 1: Location Plan - Land at Main Street Northiam: http://www.rother.gov.uk/CHttpHandler.ashx?id=28200

Appendix 2: Concept Masterplan - Northiam: http://www.rother.gov.uk/CHttpHandler.ashx?id=28201

Appendix 3: Location Plan: Land at Kings Bank Lane, Beckley: http://www.rother.gov.uk/CHttpHandler.ashx?id=28202

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Representation ID: 23968

Received: 20/02/2017

Respondent: Blue Cross

Agent: Savills

Representation Summary:

Our Client's Site is shown sites-NO19E/NO19N/NO19S/NO16.

Much of the same reasoning provided for NO15 would apply equally to NO16/NO19. As such, the overall conclusions are not considered to adequately reflect the position of my Client's site and its relationship to the settlement.

RDC has negatively assessed and ultimately scored the site considerably lower than the one suitable site in the village.

We strongly contest the scoring/conclusions particularly for NO19. This should be reviewed and altered to correctly reflect the relationship of the site to the settlement and its ability to positively contribute to the sustainability of the local community.

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