QUESTION 71: Do you agree with the preferred sites for development at Hurst Green? If not, which sites should be preferred?

No objection to the proposed allocation of sites HG18 and HG17 in Hurst Green . According to the Historic Landscape Characterisation site HG18 is early post medieval (1500-1599) regular piecemeal enclosure with historic field boundaries that should be protected. There is also a historic droveway on the southern boundary and it is understood that there may be important archaeological remains on the site that should be investigated prior to a final decision on the development potential of this site. Site HG17 is an existing commercial site.

HG3/HG4 - An admission that is unexplained is why is it that HG3 and HG4 that appear in the proposal appear to only be a small section of the original area that was marked as DS4 in the 2006 plan. Essentially it is unclear why a large area of land that was originally marked as part of DS4 area (to the immediate left [West] of the marked HG3 site) was excluded and not considered as a site in this proposal?

HG9 - We agree that any development would be wholly unacceptable within the area marked as HG9. As the proposal states, this is a wholly rural area relating to the wider landscape, it is countryside used for farming and forms part the valley to the east of Hurst Green. We agree there would be clear issues with Core Strategy Policies OSS1, OSS4, OSS5, RA1, EN1, EN5 and TR3.

HG11 - From the evidence presented we disagree with the proposed position regarding HG11. If development must take place, which we believe is ill-advised in Hurst Green at present; HG11 would offer the ability to build a number of homes, in a layout and with plot sizes similar to the next door houses at South View Close. The current pedestrian access could be easily improved, along with reconsideration following recognition that being a village location, any family moving to Hurst Green will in all probability have at least one car, if not more.

Other Sites - The site currently occupied by Ernest Doe in the centre of the village, in a similar way to the Caravan Tech site, could well be a prime location for future housing within existing development boundaries, if the owner was happy to relocate - the farm machinery business, of which we are a customer, perhaps being more at home outside of the village, rather than on the busy A21. Perhaps moving to the site currently occupied by the garden centre and nursery just outside the village on the A265.

We agree with the assessment of the HG17 site, but not the allocation.

Please note the 75 objections to the 60 houses exiting in the middle of the village on the A21 on your planning site. People may not realise they have to contact you again for this plan, having already listed their objections.This is a very dangerous road with many accidents occurring. These proposed houses are on the site where the bypass was intended. The Caravantec site is on the right side of the road for the school, shop etc and would be more practical and a much safer exit onto the A21, with a more reasonable number of houses.

Both sites are suitable for some development but HG18 is outlined for much more density of housing than is suitable for this access and is separated from the main centre of the village by the A21 with its ever increasing traffic burden.
HG2 could be used to link up Coronation Gardens and Ridgeway and perhaps alleviate some of the vehicle access issues in the former and allow for a small development although care would be needed due to sensitive nature of the ancient woodland at the Coronation Garden end.
HG6 could be looked into as a possible site

I do not agree that the HG18 and HG17 should be the only preferred sites, in particular HG18 as the housing outlined is too dense. I feel it would be better to have the other proposed sites added to the preferred list and less dense housing shared between the other possible sites shown outlined in blue.

I understand that Hurst Green are starting the NP process, and therefore this may become irrelevant.

My Company has been instructed to act for Mr. John Matthews, who owns and operates Orchard Farm, London Road, Hurst Green TN19 7QS. It is considered that my client's land should be allocated for residential development in your draft local plan. Indeed, since, being a brownfield site, then it is just the sort of land that the Council should be looking to develop in order to meet its requirements.

I have considered the contents of the draft local plan and set out my representations below.

Site location and description

Orchard Farm is situated on the eastern side of the A21, a short distance north of its junction with the A229. It comprises a farm shop and nursery business, together with a café, cold store and other commercial uses. Overall, the floorspace of these buildings - which are single storey-is approximately 900sq. metres. There is a large car park at the front of the buildings, with an extensive frontage onto the A21. The land adjacent to the buildings is used for open storage. The site has an overall area of around 1.2ha.

Justification for the allocation of Orchard Farm for residential development

It is clear from the draft D&AS that the Council's overall requirement for the plan period is at least (my emphasis) 5,700 dwellings. Unfortunately, it appears that the Council has no intention of doing anything other than providing the bare minimum of housing - and this is at a time when there is a local, regional and national need for housing provision to be increased.

The details of this site were submitted in response to your earlier "call for sites". Despite the fact that it comprises a brownfield site, you decided not to allocate it on the grounds that it was in an unsustainable location. This decision ignored the fact that Hurst Green had been identified in your Core Strategy as a Local Service Village, due to its good array of services. The site itself is a relatively short distance away from the village and lies on the A21 - which is well-served by public transport.

The site has also been subject to pre-application discussions. However, at that time, the economics of running the business and the lack of interest in the site from other commercial operators was simply ignored. In these circumstances I need to inform you that my client wishes to put forward an alternative suggestion for development.

In order to retain commercial activity on the site, it is now proposed that one alternative would be to develop only half of the site for residential development, and continue to operate the existing business from the remaining part of the site. This would hopefully improve the viability of the business - and provide some much-needed housing on the other part of this brownfield site.

Alternatively, you could always allocate the whole site for residential use. However, the proposal above would meet with your preference for retaining commercial premises in the countryside.

I would therefore ask that you seriously consider both proposals.

At this stage, my client has not produced a draft layout. Nevertheless, on the basis of the site area, it is suggested that around 20 dwellings could be provided on the whole site, or around 10-12 on half of the site.
It is a fact that you need to allocate greenfield land from within the AONB in order to meet your housing requirements. In these circumstances, it would surely be appropriate to make use of brownfield sites, rather than rely solely on undeveloped land. In answer to Question 71 in the draft D&AS, it is submitted that the land at Orchard Farm should also be allocated for development. After all, the Council does not have a five year supply of land for housing, whilst it also needs to demonstrate that it is proposing to do more than simply meet its minimum housing requirements.

In these circumstances, it is requested that my client's site be allocated.

A plan of the site is attached. If you require any further information, then please contact me.

Additional supporting information was supplied which can be viewed here:

https://www.rother.gov.uk/icm/mediaaccess.cfm?CFID=6400feb4-9dda-4a01-841e-09d99cf4611e&CFTOKEN=0&file=pdf/a/7/Orchard_Farm__Hurst_Green_Location_plan_16_February_2017.pdf

Landscape

VILLAGES WITH SITE ALLOCATIONS

Yes to all questions - Agree and support all of the village boundary and other policies.

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

VILLAGES WITH SITE ALLOCATIONS page 219

Hurst Green

Yes