Proposed Submission Core Strategy

This representation is prepared on behalf of Peer Group Plc and relates to land to the rear of 'Wardsdown House', Flimwell. Whilst it is acknowledged that site specific allocations will be dealt with through the Site Allocations Development Plan Document, a brochure document providing details of the site in terms of context, ecological issues, potential access and a landscape analysis, has been submitted to inform these representations and provide the Council with background information regarding the site.

The reasons why the respondent finds the Submission Document to be unsound are explored below, however the principle reason is:

* That the document is not justified in that it is not the most appropriate strategy when considered against reasonable alternatives;

For the purposes of distributing the housing development requirement of between 3,700 and 4,100 between 2011 and 2028, the Borough Council has divided the Core Strategy into 5 development areas; Bexhill, Hastings fringes, Battle, Rye and the villages. Villages are to take between 950 and 1,000 dwellings in the 2011-2028 period. This distribution hierarchy complies with national planning policy and is broadly supported.

Various studies (e.g. the draft Rother Rural Areas Strategy 2008) have addressed the issue of how the 1,000 or so dwellings for the village categories should be distributed. The option chosen within the Core Strategy is to concentrate firstly on the rural service centres of Ticehurst and Robertsbridge, and secondly on 7 local service centres. Whilst this is the approach taken in the Core Strategy, the document concedes at paragraph 12.15 that the approach it has taken is not absolute;

"the preferred spatial development option for the villages remains 'to primarily focus on the service centres', whilst taking into account other factors. Other factors include local needs, accessibility, environmental factors, local opportunities and whether growth levels are proportionate to settlement size over the course of the plan period. Thus, the service led 'rural function of settlements' (see Table 11.1) is not the sole criteria governing the spatial pattern of development. Moreover, a village's role can be fluid over time and some villages may still enjoy a reasonable level of facilities, although falling just outside the criteria to be defined a 'service village."

The Core Strategy goes on to make a very specific number allocation of units to each individual village, albeit steering clear of making specific site allocations. The only allocation to Flimwell is for 25 dwellings which relates to existing allocations on previously developed land contained within the Rother Local Plan. This plan was adopted in 2006 bus is based on earlier work back as far as January 2001 when the initial Deposit Plan was published.

It is the respondent's view that by stating that development in the rural areas should follow a table which allocates Flimwell only 25 units, and all in existing allocations dating back over 20 years, the Core Strategy is potentially overly restrictive. It is therefore not justified since the Council's strategy is not considered to be the most appropriate and the respondent's proposal provides a reasonable and deliverable alternative.

The Merits of the Respondent's Proposals

The respondent wishes to draw the Council's attention to the following matters in respect of Flimwell:

i) Flimwell is in the parish of Ticehurst which is one of the two rural service centres in Rother District. The two villages are almost connected as a result of unplanned ribbon development in the 20th Century - the western edge of Flimwell being only 1.5km from the village centre in Ticehurst. The Core Strategy places the highest priority on allocating land according to where rural services are most prevalent. The respondent considers that Flimwell's proximity to Ticehurst, when compared to various other villages in the District, means that to some extent it shares the benefits of the services available in Ticehurst and therefore makes it more sustainable than many of the other villages listed.

ii) The draft Rural Areas Strategy mentions that Flimwell performs well on accessibility criteria due to its location on the A21 trunk road, and that therefore the distribution of development within the parish of Ticehurst might be an issue to revisit when site-specific allocations are made in a future development plan document. Flimwell also has an hourly bus service to Ticehurst itself, then Wadhurst Station and onto Tunbridge Wells centre, adding to the sustainability credentials of the site.

iii) Furthermore, there is a possibility that the A21 Trunk Road will bypass Flimwell, which is one of only three villages not bypassed between Tonbridge and Hastings. The bypass route is safeguarded and construction would alter the setting of the village, bringing land east of the present A21 into the village envelope and also enabling a more focussed village centre to be created.

The broad options for the Core Strategy have been satisfactorily subject to sustainability appraisal at suitable stages in their evolution, however the Core Strategy goes beyond this to effectively freeze development in certain villages at current levels. It is considered that this would unreasonably constrain the possibilities for development at Flimwell during the Plan period. It is submitted that the sustainability evidence currently available is not conclusive at this site level of detail and that land to the rear of 'Wardsdown House', Flimwell, should be allocated for a small scale housing development.

This representation is prepared on behalf of Peer Group Plc and relates to land to the rear of 'Wardsdown House', Flimwell. Whilst it is acknowledged that site specific allocations will be dealt with through the Site Allocations Development Plan Document, a brochure document providing details of the site in terms of context, ecological issues, potential access and a landscape analysis, has been submitted to inform these representations and provide the Council with background information regarding the site.

The reasons why the respondent finds the Submission Document to be unsound are explored below, however the principle reason is:

* That the document is not justified in that it is not the most appropriate strategy when considered against reasonable alternatives;

For the purposes of distributing the housing development requirement of between 3,700 and 4,100 between 2011 and 2028, the Borough Council has divided the Core Strategy into 5 development areas; Bexhill, Hastings fringes, Battle, Rye and the villages. Villages are to take between 950 and 1,000 dwellings in the 2011-2028 period. This distribution hierarchy complies with national planning policy and is broadly supported.

Various studies (e.g. the draft Rother Rural Areas Strategy 2008) have addressed the issue of how the 1,000 or so dwellings for the village categories should be distributed. The option chosen within the Core Strategy is to concentrate firstly on the rural service centres of Ticehurst and Robertsbridge, and secondly on 7 local service centres. Whilst this is the approach taken in the Core Strategy, the document concedes at paragraph 12.15 that the approach it has taken is not absolute;

"the preferred spatial development option for the villages remains 'to primarily focus on the service centres', whilst taking into account other factors. Other factors include local needs, accessibility, environmental factors, local opportunities and whether growth levels are proportionate to settlement size over the course of the plan period. Thus, the service led 'rural function of settlements' (see Table 11.1) is not the sole criteria governing the spatial pattern of development. Moreover, a village's role can be fluid over time and some villages may still enjoy a reasonable level of facilities, although falling just outside the criteria to be defined a 'service village."

The Core Strategy goes on to make a very specific number allocation of units to each individual village, albeit steering clear of making specific site allocations. The only allocation to Flimwell is for 25 dwellings which relates to existing allocations on previously developed land contained within the Rother Local Plan. This plan was adopted in 2006 bus is based on earlier work back as far as January 2001 when the initial Deposit Plan was published.

It is the respondent's view that by stating that development in the rural areas should follow a table which allocates Flimwell only 25 units, and all in existing allocations dating back over 20 years, the Core Strategy is potentially overly restrictive. It is therefore not justified since the Council's strategy is not considered to be the most appropriate and the respondent's proposal provides a reasonable and deliverable alternative.

The Merits of the Respondent's Proposals

The respondent wishes to draw the Council's attention to the following matters in respect of Flimwell:

i) Flimwell is in the parish of Ticehurst which is one of the two rural service centres in Rother District. The two villages are almost connected as a result of unplanned ribbon development in the 20th Century - the western edge of Flimwell being only 1.5km from the village centre in Ticehurst. The Core Strategy places the highest priority on allocating land according to where rural services are most prevalent. The respondent considers that Flimwell's proximity to Ticehurst, when compared to various other villages in the District, means that to some extent it shares the benefits of the services available in Ticehurst and therefore makes it more sustainable than many of the other villages listed.

ii) The draft Rural Areas Strategy mentions that Flimwell performs well on accessibility criteria due to its location on the A21 trunk road, and that therefore the distribution of development within the parish of Ticehurst might be an issue to revisit when site-specific allocations are made in a future development plan document. Flimwell also has an hourly bus service to Ticehurst itself, then Wadhurst Station and onto Tunbridge Wells centre, adding to the sustainability credentials of the site.

iii) Furthermore, there is a possibility that the A21 Trunk Road will bypass Flimwell, which is one of only three villages not bypassed between Tonbridge and Hastings. The bypass route is safeguarded and construction would alter the setting of the village, bringing land east of the present A21 into the village envelope and also enabling a more focussed village centre to be created.

The broad options for the Core Strategy have been satisfactorily subject to sustainability appraisal at suitable stages in their evolution, however the Core Strategy goes beyond this to effectively freeze development in certain villages at current levels. It is considered that this would unreasonably constrain the possibilities for development at Flimwell during the Plan period. It is submitted that the sustainability evidence currently available is not conclusive at this site level of detail and that land to the rear of 'Wardsdown House', Flimwell, should be allocated for a small scale housing development.