Proposed Submission Core Strategy

While (xi) refers to cultural assets we do not consider that this is strong enough to cover the recommendations that we have made in respect of Rye's cultural offering.

Paragraph 13.13 refers to the Rother's biomass resource (woodland). Paragraph 17.15 advises that Rother has the highest percentage of ancient woodland cover in the South East (15.5%).
However, there is nothing within the policy to encourage the use of this natural resource that is not only sustainable but zero carbon. This would also support policy EN1 that seeks to enhance the district's landscape and landscape features ((vi) refers to ancient woodland); and policy EN5 that seeks to support opportunities to manage and restore habitats. There would also be benefits for rural employment.

It is clear from the evidence base that there is more locally derived need unmet in Rye than elsewhere in Rother (S.2.37 Rye and Rye Harbour Study 2011). The Affordable Housing Background Paper 2011refers to the Strategic Housing Market Assessment (SHMA) 2010 that recommends 40% affordable housing in Rye. The Affordable Housing Viability Study (AVHS) was drafted in parallel to the SHMA in order to ensure that the conclusions could be used to inform both studies. This indicates that 40% while being less profitable is still viable.

It is therefore disappointing that the provision of new affordable housing within new developments in Rye has been reduced from the current 40% to 30%. The main reason given within paragraph 15.28 is to kick start regeneration. This appears to be a reaction to the current economic conditions whereas the Core Strategy covers a period of 17 years to 2028 which will see the economy over a number of economic cycles.

The reduction in the allocation of affordable housing provision, combined with the reduction in the housing allocation from 450 to 350, and the fact that there is a strong second home market in Rye (including new properties) means that local demand for homes will not be met.

Please also note typing error in the last paragraph on page 119 which refers to proposals for less than 15 houses in Bexhill and Rye and 10 in Battle. It should read 15 in Bexhill and 10 in Rye and Battle

We support the desire to provide guidance on design quality which is important to preserve the unique qualities and environments of settlements. However, we have concerns that the policy will not be sufficient to prevent inappropriate design, especially for larger developments, in Rye outside of the Conservation Area. The current local plan has not been able to prevent inappropriate design being approved i.e. the new school where the design has many merits but it did not reflect its position within the setting of the Conservation Area and on the edge of the High Weald AONB. The same can be said for the proposed new supermarket at Ferry Road where a generic design with no local distinction has been approved.

Given Rye's prominent hilltop location it is important that development within the setting and approaches are of the highest quality and reflects Rye's rich architectural inheritance.

While we do not consider Policy EN6: Flood Risk Management as being unsound we are disappointed that it does not consider the work that is undertaken by local stakeholders such as REACT in Rye in seeking solutions to flood issues. We would suggest therefore that the policy wording is amended as follows:

"An effective and integrated approach to flood risk management in Rother District will be achieved by working with relevant agencies, strategic partners and local stakeholders to ensure that: "

Demographic Trends
The population trends used in the Core Strategy are inconsistent. Paragraphs 3.20 and 3.21 and Figure 7 indicate that the age groups 0-14, 15-29, 30-44 and 45-64 will decrease; whereas age groups 65-79 and 75+ (there appears to be a typo in the age groups used in figure 7) increase between 2011 and 2028. However, paragraph 14.36 indicates that the 0-14 age group will increase by 6.1% and the 15-29 age group by 4.1% between 2006 and 2026.

The use of population data should be consistent through the Core Strategy. If different data sets for population growth are used to support different policies it casts doubts on the robustness of the assumptions made.

Demographic Trends
The population trends used in the Core Strategy are inconsistent. Paragraphs 3.20 and 3.21 and Figure 7 indicate that the age groups 0-14, 15-29, 30-44 and 45-64 will decrease; whereas age groups 65-79 and 75+ (there appears to be a typo in the age groups used in figure 7) increase between 2011 and 2028. However, paragraph 14.36 indicates that the 0-14 age group will increase by 6.1% and the 15-29 age group by 4.1% between 2006 and 2026.

The use of population data should be consistent through the Core Strategy. If different data sets for population growth are used to support different policies it casts doubts on the robustness of the assumptions made.