Proposed Submission Core Strategy

We welcome the inclusion of a policy which aims to meet identified needs.

We have concerns about the level of permanent site provision planned for in the light of all the evidence

The background paper identifies 9 authorised pitches within the district and 3 temporary pitches. The latest caravan count (Jan 2011) identifies in addition 4 caravans without the benefit of planning permission (1 tolerated and 3 not tolerated). Thus including the temporary permissions there appears to be an outstanding and immediate need for 7 pitches taking into account the two pitches provided for since 2006. In our view Rother should make provision for these pitches as an existing unmet need to bring the total number of authorised pitches in 2011 to 16 pitches. It should take into account family formation from 2011 to 2016 (estimated at 3% compound) as a further 2-3 (to be precise 2.5 ) pitches bringing the total requirement 2006-2011 to 18-19 pitches. This leaves an outstanding need of 9-10 pitches for 2006-2016.

The council should plan beyond this date to take into account family formation to 2028 (as it does in para 15.43) and plan for a further 7-8 pitches over the period 2016-2028.

We are very concentred that the council intends to make no provision for Gypsies and Travellers in housing but with a need for a pitch. The background paper dismisses this on the basis that (para 7.4) that RSL providers could identify few Gypsies and Travellers in RSL accommodation. We do not accept that this statement and the limited piece of work can be justified in the face of the recommendations of the Panel about Gypsies and Travellers in housing. In any event ethnic monitoring for Gypsies and Travellers is in its infancy and many do not self-identify for fear of prejudice. It is wise and prudent to make the sort of 10% uplift recommended by the panel to make a start on meeting needs from this source. Clearly Gypsies and Travellers do indeed live in Rother both on sites and in housing and to not make a start on meeting those needs would seem to be unwise and unjust. Failure to make a start on such provision will inevitably mean that such provision is unlikely ever to be made. A 10% uplift only involves one extra pitch to 2016 bringing the total need to 2016 to 10-11 pitches on our calculations.

Criteria in Policy LHN6
We object on the basis that some of the criteria are in conlfict with Ciruclar 1/2006 and are unduly restrictive and not justified or effective.

1. The stricture that the site is not located in a nature conservation area does conflict with para 53 of C 1/2006 (which still stands) which states that local nature conservation designations should not in themselves be used to refuse planning permission for sites.

2. Flood risk - this quite properly excludes sites from high flood risk but does not take into account the problems associated with EA mapping which are sometimes found to be wrong. This does not accord with a risk based approach and should be amended to states that where a site is in an area liable to flood as indicated in the EA Maps permission should not be permitted unless a flood risk assessment indicates otherwise. This would give applicants the opportunity to challenge the validity and reliability of the EA mapping system.

3. Whilst location close to or within an existing settlement is a laudable aim this may not be achievable in practice and may exclude otherwise suitable sites. A more reasonable approach to sustainability issues is required in line with para 54 of C 1/2006.