1.5

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24321

Received: 06/12/2018

Respondent: Town and Country Planning Solutions

Representation:

Paragraph 1.5 states that the DaSA needs to be read in conjunction with Neighbourhood Plans "that are in force" and does not cover parts of the District where a Neighbourhood Plan is proposed but has not yet been 'made'. The DaSA excluding these areas means that it is seriously flawed in that;
i) it does not provide comprehensive Development Management (DM) or Site Allocation Policies for the entire District.
ii) there is no confirmation that the proposed DM Policies will apply within areas to covered by NPs, so there will be large parts of the District where these policies do not apply.
iii) the DaSA cannot be certain to deliver the amount of housing and employment land required by the Core Strategy as it does not cover a significant extent of the District.
iv) Until such time as NPs are made, the Council propose to rely on outdated, saved Policies of the 2006 Rother Local Plan for those parts of the District to be covered by NPs.
v) The DaSA makes no contingency arrangement in the event that a NP is not proceeded with or remains unmade.
Wealden District has taken an entirely different approach.

Full text:

Paragraph 1.5 states that the DaSA needs to be read in conjunction with Neighbourhood Plans "that are in force" and does not cover parts of the District where a Neighbourhood Plan is proposed but has not yet been 'made'. So far only two Neighbourhood Plans (NP) have been made (Salehurst and Robertsbridge Parish NP and Sedlescombe NP), but there are 8 other designated NP areas where they have yet to be made covering a significant extent of the District at Battle (and Netherfield), Burwash, Crowhurst, Etchingham, Fairlight, Hurst Green, Rye and Ticehurst. The DaSA excluding parts of the District covered by (or to be covered by) a NP means that as a Policy document, it is seriously flawed in that;

i) the DaSA does not provide comprehensive Development Management or Site Allocation Policies for the entire District.
ii) there is no confirmation that the proposed Development Management Policies will apply within areas to covered by NPs, so there will be large parts of the District where these policies do not apply.
iii) the DaSA cannot be certain to deliver the amount of housing and employment land required by the Core Strategy as it does not cover a significant extent of the District where such development is required by strategic policies such as at Battle and Rye within rural settlements.
iv) Until such time as NPs are made, the Council propose to rely on outdated, saved Policies of the Rother Local Plan adopted over 12 years ago in July 2006 for those parts of the District to be covered by NPs.
v) The DaSA makes no contingency arrangement in the event that a NP is not proceeded with or remains unmade for the duration of the DaSA period.

The neighbouring Authority of Wealden District has taken an entirely different approach in order to ensure that development management policies will cover the entire extent of their area and to ensure the delivery of housing and employment land by proposing allocations within areas where NPs have been made or proposed.

The Proposed Submission Draft of the Wealden Local Plan (August 2018) states "There are Neighbourhood Development Plans being produced in Wealden District. If a Neighbourhood Development Plan is adopted prior to the submission/adoption of the Wealden Local Plan, the relevant policies may be removed from the Wealden Local Plan. If the Neighbourhood Development Plan is adopted after the Wealden Local Plan, then the Neighbourhood Development Plan policies will supersede relevant Wealden Local Plan policies" (paragraph 1.18). Within Wealden District there are three Neighbourhood Plans, but only one has reached a referendum stage.

Given the holes in the Local Plan coverage due to the extent of the District proposed to be covered by NPs, the DaSA cannot be considered sound in being positively prepared, justified or effective and as such, is not consistent with national policy (paragraph 35 of the NPPF - 2018). Due to the flawed approach in not providing for policy coverage and site allocations in areas covered by NPs, there are no modifications that could be readily made available to remedy this concern and the proposed submission of the DaSA should be suspended to address this and to review paragraphs 1.5, 1.11 (regards employment provision at Battle), 1.14, 1.30 (in relation to new Inset Maps that would be required for NP areas), 5.37 (items (g), (k), (l) and (n) and 5.39, Policy DIM2 - Figure 14, 8.1 (Battle and Rye), 89 and 8.10 and Policy OVE1.