Main Modifications to the Proposed Submission Core Strategy

Distribution of Rural Housing Allocations
Proposed Modifications nos. MOD 12.4 and 12.5

1. These representations (TCPS Representations No. 3), should be read in conjunction with representations submitted in response to proposed modification numbers 12.1, 12.2 and 12.4 (TCPS Representations no. 2). These representations make the case that the draft Policy RA1(v) (MOD 12.4) should be further modified to refer to "at least 1,670 additional dwellings".

2. Although not a proposed modification, the draft policy also states that new housing allocations "will be located in accordance with Figure 12, subject to refinement in light of further investigations by the Development and Site Allocation DPD and/or Neighbourhood Plans". In light of the Council's recognition of the need to increase the housing requirement generally in the District (compared to the submitted draft version of the Plan) and given that the Council has more recently accepted that additional sites might be identified as part of the Site Allocations/ Neighbourhood Plan stage, the purpose and function of Figure 12 is now questionable and should be deleted with further modifications to Policy RA1(v) as required. If retained however, it should at the very least be regarded as providing illustrative housing numbers only for each settlement in relation to column 3 (allocations) and column 4 (potential new sites).

Distribution of Rural Housing Allocations
Proposed Modifications nos. MOD 12.4 and 12.5

1. These representations (TCPS Representations No. 3), should be read in conjunction with representations submitted in response to proposed modification numbers 12.1, 12.2 and 12.4 (TCPS Representations no. 2). These representations make the case that the draft Policy RA1(v) (MOD 12.4) should be further modified to refer to "at least 1,670 additional dwellings".

2. Although not a proposed modification, the draft policy also states that new housing allocations "will be located in accordance with Figure 12, subject to refinement in light of further investigations by the Development and Site Allocation DPD and/or Neighbourhood Plans". In light of the Council's recognition of the need to increase the housing requirement generally in the District (compared to the submitted draft version of the Plan) and given that the Council has more recently accepted that additional sites might be identified as part of the Site Allocations/ Neighbourhood Plan stage, the purpose and function of Figure 12 is now questionable and should be deleted with further modifications to Policy RA1(v) as required. If retained however, it should at the very least be regarded as providing illustrative housing numbers only for each settlement in relation to column 3 (allocations) and column 4 (potential new sites).

Distribution of Rural Housing Allocations and the 2013 SHLAA update Proposed Modifications nos. MOD 12.5 and 7.7

1. These representations (TCPS Representations No. 4) should be read in conjunction with TCPS Representations nos. 2 and 3 relating to proposed modification 12.1, 12.2, 12.4 and 12.5. In these representations, the case is made for scope to increase housing land supply in villages beyond the 1,670 additional dwellings referred to in modified Policy RA1(v) (MOD 12.4) and the breakdown given in modified Figure 12 (MOD 12.5), in order to provide a potentially greater contribution to the overall supply of housing during the Plan period.

2. Furthermore, the revised number of dwellings referred to in modified Figure 12 should not be regarded as a ceiling or upper limit on the capacity of each settlement listed, as this potential will need to be reviewed and fully assessed as part of the subsequent site allocations/neighbourhood planning process. In other words, the individual village housing numbers referred to in Figure 12 should not prejudice the potential for additional land to come forward in these settlements subject to this being suitable, available and deliverable at a later stage of the plan making process.

3. lt is clear from the SHLAA update (June 2013) that the Council is now placing greater emphasis on the importance of meeting assessed need notwithstanding this, there remains scope for increasing housing supply above the proposed modified figure of 5,700 dwellings referred to in amended Policy OSS1 (MOD 7.12).

4. While the Council has recently undertaken a review of its SHLAA and this has influenced the revised housing figures put forward, there has been no opportunity for any developer or landowner to assess the Council's revised SHLAA findings and conclusions reached for each site considered (capable of accommodating 6 dwellings or more). There are a number of examples where the Council's revised SHLAA is open to challenge and individual site potential cannot be properly assessed until the site allocations (neighbourhood plan) process has been undertaken.

Distribution of Rural Housing Allocations and the 2013 SHLAA update Proposed Modifications nos. MOD 12.5 and 7.7

1. These representations (TCPS Representations No. 4) should be read in conjunction with TCPS Representations nos. 2 and 3 relating to proposed modification 12.1, 12.2, 12.4 and 12.5. In these representations, the case is made for scope to increase housing land supply in villages beyond the 1,670 additional dwellings referred to in modified Policy RA1(v) (MOD 12.4) and the breakdown given in modified Figure 12 (MOD 12.5), in order to provide a potentially greater contribution to the overall supply of housing during the Plan period.

2. Furthermore, the revised number of dwellings referred to in modified Figure 12 should not be regarded as a ceiling or upper limit on the capacity of each settlement listed, as this potential will need to be reviewed and fully assessed as part of the subsequent site allocations/neighbourhood planning process. In other words, the individual village housing numbers referred to in Figure 12 should not prejudice the potential for additional land to come forward in these settlements subject to this being suitable, available and deliverable at a later stage of the plan making process.

3. lt is clear from the SHLAA update (June 2013) that the Council is now placing greater emphasis on the importance of meeting assessed need notwithstanding this, there remains scope for increasing housing supply above the proposed modified figure of 5,700 dwellings referred to in amended Policy OSS1 (MOD 7.12).

4. While the Council has recently undertaken a review of its SHLAA and this has influenced the revised housing figures put forward, there has been no opportunity for any developer or landowner to assess the Council's revised SHLAA findings and conclusions reached for each site considered (capable of accommodating 6 dwellings or more). There are a number of examples where the Council's revised SHLAA is open to challenge and individual site potential cannot be properly assessed until the site allocations (neighbourhood plan) process has been undertaken.

Figure 12: Distribution of rural housing allocations
MOD 12.5- Housing Allocations at Netherfield

1. These representations (TCPS Representations No. 5) relate to Rother District Council's proposed modification to the distribution of rural housing allocations as set out in Modified Figure 12 (MOD 12.5). These representations should also be read in conjunction with TCPS Representations nos. 2 - 4, which made the case that housing provision in villages could be modified to provide at least 1,672 dwellings and that Figure 12 should be deleted or the proposed housing allocation figures should be for illustrative purposes only in order to avoid prejudicing consideration of all potential housing sites as part of the forthcoming site allocations/neighbourhood planning process. In particular, paragraph 4 of TCPS Representations No. 4 indicates that there are examples where the Council's updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) is open to challenge as individual site potential cannot be properly assessed or open to scrutiny without the detailed site allocations process being undertaken as Part 2 of the Local Plan.

2. These representations (i.e. TCPS Representations No. 5) provide an example of potential housing land at Netherfield, which has up to now, been discounted in both the March 2010 and June 2013 versions of the Council's SHLAA. These representations relate to site no. NE2 in both versions of the SHLAA (see relevant SHLAA extracts contained in appendix 1).

3. In 2010, the Council considered the land to be poorly related to the existing built up area boundary and that other sites in Netherfield were preferable whilst in the 2013 update, the Council have added concerns about landscape views into and out of the site and potential ecology issues.

4. The Council's Rural Settlement Study (see extract contained in appendix 2) sets out the 'function' of Netherfield (which includes an assessment of local facilities and services) and its proximity to the nearby town of Battle, which is "within a five minute drive-time". The analysis indicates that there is a need for affordable housing and that there may be potential for allocation of up to 15 dwellings by 2026. Thus, although a relatively small rural settlement, it has a good range of local facilities for its size (which includes primary school and bus services) and effectively forms a satellite settlement for the higher order town of Battle (which has secondary schools, a mainline railway station, good range of retail facilities and employment provision).

5. The land the subject of site NE2 in both versions of the Council's SHLAA is not 'poorly related to the existing built up area boundary', as it is located immediately adjacent to it as shown by the annotated version of the Local Plan Inset Map no. 24 contained in appendix 3. Public views into the site are almost entirely screened by existing development and by the local topography. While to the north there is an area of ancient woodland, this is some distance away from the site and would not be adversely affected by any development proposals. Furthermore, any ecological impact could be satisfactorily mitigated on site.

6. Drawing no. 4376/1/A (contained in appendix 4) illustrates how the site might be developed to provide around 66, two, three and four bedroom dwellings including 40% (26 - 27 units) affordable accommodation. Other elements of the illustrative layout show;

i. A potential expansion of the playing field serving Netherfield C of E Primary School (which is located immediately adjacent to the site to the west) in exchange for a footpath/cycle link to the village school and shop/post office;

ii. The expansion of the village recreation ground which is located immediately to the east of the site, together with the provision of additional public car parking;

iii. The provision of amenity landscape buffers to the rear of properties that front onto Netherfield Road to the south of the site;

iv. The retention and reinforcement of existing woodland within the northern part of the site to include the retention and expansion of an existing watercourse to create a wetland habitat or expanded pond;

v. Additional woodland planting to provide a substantial landscape buffer between the potential housing area and the ancient woodland located further to the north of the site.

7. Appendix 5 contains a Transport and Sustainability Appraisal, which demonstrates how suitable access can be achieved and the alternative modes of transport available. The development of the land would not only provide potential for expanding the school playing field, but also the housing development itself would help sustain the school numbers and ensure its continued viability as a community asset. The existing school role figures indicate that there is currently projected spare capacity (see the figures contained in appendix 6).

8. lt is fully appreciated that it is not the role of the Core Strategy to identify individual housing sites, as this will be the purpose and function of a Site Allocations Plan (or Neighbourhood Plan) in due course. The point is however, that this land clearly has potential to provide a wide range of community benefits including affordable housing and a further assessment of its potential as part of the site allocations/neighbourhood planning process should not be prejudiced by either the updated SHLAA assessment (which is not a policy document) or as importantly, the housing allocation figures currently contained in Modified Figure 12 of the Core Strategy. Furthermore, the modified housing allocation figures should not prejudice a proper assessment of alternative sites at Netherfield at the later site allocations/neighbourhood planning stage.

9. At present, modified Table 12 indicates that Netherfield has potential for
48 dwellings on 'New Sites' (column 4). This appears to relates to SHLAA (2013) sites NE1, NE5A and NE11, but as also indicated in the SHLAA assessment (contained in appendix 1 attached) this land also has various constraints listed including the availability of a suitable means of access. No doubt this land will be the subject of further investigation at the site allocations/neighbourhood planning stage, but this land should also be examined in the context of the considerable public benefit that could arise if the land the subject of NE2 were to be developed instead. Sites NE1, NE5A and NE11 (if actually available and deliverable) would not offer the range of community benefits as identified by the illustrative layout contained in appendix 4 attached and this was not available to the Council at the time it produced either its original SHLAA in March 2010 or its updated SHLAA in June 2013.
Supplementary information submitted with the representation can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20687

Figure 12: Distribution of rural housing allocations
MOD 12.5- Housing Allocations at Fairlight Cove

1. These representations (TCPS Representations No. 7) relate to Rother District Council's Proposed Modification to the distribution of rural housing allocations as set out in Modified Figure 12 (MOD 12.5). These representations should also be read in conjunction with TCPS Representations nos. 2 - 4, which made the case that housing provision in villages should be modified to provide 'at least' 1,672 dwellings and that Figure 12 should be deleted or the proposed housing allocation figures should be included only for illustrative purposes in order to avoid prejudicing consideration of all potential housing sites as part of the forthcoming site allocations/neighbourhood planning process. In particular, paragraph 4 of TCPS Representations No. 4 indicates that there are examples where the Council's updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) is open to challenge as individual site potential cannot be properly assessed or open to scrutiny without the detailed site allocations process being undertaken as Part 2 of the Local Plan.

2. These representations (i.e. TCPS Representations No. 7) provide an example of possible housing land at Fairlight Cove, the subject of site no. FC2 in the Council's March 2010 and June 2013 updated versions of the SHLAA. In 2010, the Council considered the land to be suitable, deliverable and available as a potential 'green' status housing site with scope for approximately 30 dwellings. For reasons which are not clear, in the June 2013 updated version of the SHLAA, the site has been downgraded to having an 'amber' status with a reduced estimated potential for 20 dwellings (see SHLAA extracts contained in appendix 1 attached).

3. The Council's Rural Settlement Study (see extracts contained in appendix 2) sets out the function of Fairlight Cove, which has a fairly large population compared to most other Rother villages. This is likely to be a reflection of its close relationship with Hastings to the west, which has a wide range of services including a mainline railway station with direct connections to Tunbridge Wells and London. Other railway stations are about three miles away at Three Oaks and at Ore.

4. There is an existing allocated housing site within Fairlight Cove (at Fairlight Gardens), which is the subject of SHLAA site no. FC1 and Policy VL3 of the adopted Local Plan (see Inset Map no. 14 of the Local Plan's Proposals Map reproduced in appendix 2). Despite the land being allocated for at least 15 dwellings (including 40% affordable housing), the land has not been developed and no planning application has been submitted since the Local Plan was adopted in July 2006. This must give rise to some doubt as to whether this land will come forward for housing development in the future.

5. SHLAA site FC2 adjoins the existing built up area boundary at Fairlight Cove on three sides (to the north, west and south). It is a relatively large parcel of land of around 3.14 hectares, although the Council has assessed the land as having potential for only around 20 - 30 dwellings. The land clearly has potential to accommodate a greater number of housing units as well as having scope to include other community facilities such as allotments or public open space.

6. Modified Figure 12 (MOD 12.5) provides for 17 dwellings as an existing allocation plus 20 dwellings as 'potential new sites'. As there appear to be no other available, suitable or developable housing land at Fairlight Cove, site FE2 is a key candidate site to help meet future housing needs (including affordable housing provision). To set an arbitrary limit of 20 dwellings in Figure 12 would prejudice any potential for additional housing development on the land as part of detailed investigations and submissions at the forthcoming site allocations/neighbourhood planning stage. Given the area of land available, the land clearly has potential for providing more than just 20 dwellings.

Supplementary information submitted with this representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20685

Bexhill Development Strategy - land west of Bexhill
Proposed Modification Nos. MOD 7.13, 7.14, 8.6, 8.10, 8.11 and 8.12

1. Draft Policy OSS1 aims to focus new development at Bexhill. "lt should benefit from enhanced facilities and services which would result from further development" (paragraph 35 of the Council's 'Summary Appraisal of Sustainable Housing Growth'). The Council acknowledge that in light of the review of the assessed housing needs (based upon the County Council's projections), there is now a need to increase housing supply in the District compared to that previously proposed in the Submission Draft version of the Core Strategy.

2. Proposed MOD 7.13 now seeks to increase the housing requirement to at least 5,700 dwellings over the Plan period and MOD 7.14 and 8.12 confirms the intention to increase the housing requirement to 3,100 dwellings in Bexhill (subject to the outcome of an ongoing Transport Capacity Study). While much of this housing development is dependant upon the completion of the Hastings to Bexhill link road, MOD 8.10 indicates there is also potential at 'broad locations' around the northern and western edges of the town. Paragraph 8.59 of the Proposed Submission Core Strategy states that development "may be extended westwards adjacent to the urban area without undue impact on the wider landscape". Paragraph 8.60 also indicates that development to the west of Little Common, both north and south of Barnhom Road (A259) will also be considered with access created directly onto the A259, with the scale, timing and locations ideally being determined at the site allocations stage (MOD8.11).

3. Within this context, the updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) will be an important consideration, but until now, there has been no opportunity for developers or landowners to scrutinise the Council's conclusions in the respect of the separate sites identified.

4. As regards one of the Council's stated intentions of a broad location for housing growth being identified around the 'western edges of the town', land at the western end of Barnhorn Road (A259) would be a key consideration. The main candidate site in this respect would be SHLAA site BX50, which comprises an undeveloped parcel of land outside the High Weald Area of Outstanding Natural Beauty that is located to the west of no. 163 Bamhorn Road (see SHLAA extract contained in appendix 1 attached). The land comprises an undeveloped gap in otherwise built front frontage where public views along the A259 are screened by tall evergreen trees along the road frontage.

5. Although the land has been assessed by the Council as a 'red' site not suitable for housing development, this conclusion is open challenge and these representations (i.e. TCPS Representations No. 6) make the case that this land is suitable and should be examined in detail as to its potential at the site allocations stage.

6. The 'Technical Note' contained in appendix 2 attached demonstrates that access could be obtained to serve up to 40 dwellings on the site. The Technical Note contains an illustrative drawing no. 4377/1 showing layout of 32 dwellings on the site comprising a mix of two, three and four bedroom units that would include 40% affordable housing. The illustrative layout demonstrates the retention of trees along the road frontage and availability of space to create landscape buffers around other boundaries of the site.

7. Thus, this housing development would comprise a western extension to Bexhill and make a useful contribution to housing supply in a form that is not dependent upon the construction of the link road. The Council's recent decision to resolve to permit 275 dwellings to the north of Barnhorn Road (planning application no. RR/2012/1978/P) confirms that a new access onto the A259 can be acceptable in principle.

Supplementary information submitted with the representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20686

Bexhill Development Strategy - land west of Bexhill
Proposed Modification Nos. MOD 7.13, 7.14, 8.6, 8.10, 8.11 and 8.12

1. Draft Policy OSS1 aims to focus new development at Bexhill. "lt should benefit from enhanced facilities and services which would result from further development" (paragraph 35 of the Council's 'Summary Appraisal of Sustainable Housing Growth'). The Council acknowledge that in light of the review of the assessed housing needs (based upon the County Council's projections), there is now a need to increase housing supply in the District compared to that previously proposed in the Submission Draft version of the Core Strategy.

2. Proposed MOD 7.13 now seeks to increase the housing requirement to at least 5,700 dwellings over the Plan period and MOD 7.14 and 8.12 confirms the intention to increase the housing requirement to 3,100 dwellings in Bexhill (subject to the outcome of an ongoing Transport Capacity Study). While much of this housing development is dependant upon the completion of the Hastings to Bexhill link road, MOD 8.10 indicates there is also potential at 'broad locations' around the northern and western edges of the town. Paragraph 8.59 of the Proposed Submission Core Strategy states that development "may be extended westwards adjacent to the urban area without undue impact on the wider landscape". Paragraph 8.60 also indicates that development to the west of Little Common, both north and south of Barnhom Road (A259) will also be considered with access created directly onto the A259, with the scale, timing and locations ideally being determined at the site allocations stage (MOD8.11).

3. Within this context, the updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) will be an important consideration, but until now, there has been no opportunity for developers or landowners to scrutinise the Council's conclusions in the respect of the separate sites identified.

4. As regards one of the Council's stated intentions of a broad location for housing growth being identified around the 'western edges of the town', land at the western end of Barnhorn Road (A259) would be a key consideration. The main candidate site in this respect would be SHLAA site BX50, which comprises an undeveloped parcel of land outside the High Weald Area of Outstanding Natural Beauty that is located to the west of no. 163 Bamhorn Road (see SHLAA extract contained in appendix 1 attached). The land comprises an undeveloped gap in otherwise built front frontage where public views along the A259 are screened by tall evergreen trees along the road frontage.

5. Although the land has been assessed by the Council as a 'red' site not suitable for housing development, this conclusion is open challenge and these representations (i.e. TCPS Representations No. 6) make the case that this land is suitable and should be examined in detail as to its potential at the site allocations stage.

6. The 'Technical Note' contained in appendix 2 attached demonstrates that access could be obtained to serve up to 40 dwellings on the site. The Technical Note contains an illustrative drawing no. 4377/1 showing layout of 32 dwellings on the site comprising a mix of two, three and four bedroom units that would include 40% affordable housing. The illustrative layout demonstrates the retention of trees along the road frontage and availability of space to create landscape buffers around other boundaries of the site.

7. Thus, this housing development would comprise a western extension to Bexhill and make a useful contribution to housing supply in a form that is not dependent upon the construction of the link road. The Council's recent decision to resolve to permit 275 dwellings to the north of Barnhorn Road (planning application no. RR/2012/1978/P) confirms that a new access onto the A259 can be acceptable in principle.

Supplementary information submitted with the representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20686

Bexhill Development Strategy - land west of Bexhill
Proposed Modification Nos. MOD 7.13, 7.14, 8.6, 8.10, 8.11 and 8.12

1. Draft Policy OSS1 aims to focus new development at Bexhill. "lt should benefit from enhanced facilities and services which would result from further development" (paragraph 35 of the Council's 'Summary Appraisal of Sustainable Housing Growth'). The Council acknowledge that in light of the review of the assessed housing needs (based upon the County Council's projections), there is now a need to increase housing supply in the District compared to that previously proposed in the Submission Draft version of the Core Strategy.

2. Proposed MOD 7.13 now seeks to increase the housing requirement to at least 5,700 dwellings over the Plan period and MOD 7.14 and 8.12 confirms the intention to increase the housing requirement to 3,100 dwellings in Bexhill (subject to the outcome of an ongoing Transport Capacity Study). While much of this housing development is dependant upon the completion of the Hastings to Bexhill link road, MOD 8.10 indicates there is also potential at 'broad locations' around the northern and western edges of the town. Paragraph 8.59 of the Proposed Submission Core Strategy states that development "may be extended westwards adjacent to the urban area without undue impact on the wider landscape". Paragraph 8.60 also indicates that development to the west of Little Common, both north and south of Barnhom Road (A259) will also be considered with access created directly onto the A259, with the scale, timing and locations ideally being determined at the site allocations stage (MOD8.11).

3. Within this context, the updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) will be an important consideration, but until now, there has been no opportunity for developers or landowners to scrutinise the Council's conclusions in the respect of the separate sites identified.

4. As regards one of the Council's stated intentions of a broad location for housing growth being identified around the 'western edges of the town', land at the western end of Barnhorn Road (A259) would be a key consideration. The main candidate site in this respect would be SHLAA site BX50, which comprises an undeveloped parcel of land outside the High Weald Area of Outstanding Natural Beauty that is located to the west of no. 163 Bamhorn Road (see SHLAA extract contained in appendix 1 attached). The land comprises an undeveloped gap in otherwise built front frontage where public views along the A259 are screened by tall evergreen trees along the road frontage.

5. Although the land has been assessed by the Council as a 'red' site not suitable for housing development, this conclusion is open challenge and these representations (i.e. TCPS Representations No. 6) make the case that this land is suitable and should be examined in detail as to its potential at the site allocations stage.

6. The 'Technical Note' contained in appendix 2 attached demonstrates that access could be obtained to serve up to 40 dwellings on the site. The Technical Note contains an illustrative drawing no. 4377/1 showing layout of 32 dwellings on the site comprising a mix of two, three and four bedroom units that would include 40% affordable housing. The illustrative layout demonstrates the retention of trees along the road frontage and availability of space to create landscape buffers around other boundaries of the site.

7. Thus, this housing development would comprise a western extension to Bexhill and make a useful contribution to housing supply in a form that is not dependent upon the construction of the link road. The Council's recent decision to resolve to permit 275 dwellings to the north of Barnhorn Road (planning application no. RR/2012/1978/P) confirms that a new access onto the A259 can be acceptable in principle.

Supplementary information submitted with the representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20686

Bexhill Development Strategy - land west of Bexhill
Proposed Modification Nos. MOD 7.13, 7.14, 8.6, 8.10, 8.11 and 8.12

1. Draft Policy OSS1 aims to focus new development at Bexhill. "lt should benefit from enhanced facilities and services which would result from further development" (paragraph 35 of the Council's 'Summary Appraisal of Sustainable Housing Growth'). The Council acknowledge that in light of the review of the assessed housing needs (based upon the County Council's projections), there is now a need to increase housing supply in the District compared to that previously proposed in the Submission Draft version of the Core Strategy.

2. Proposed MOD 7.13 now seeks to increase the housing requirement to at least 5,700 dwellings over the Plan period and MOD 7.14 and 8.12 confirms the intention to increase the housing requirement to 3,100 dwellings in Bexhill (subject to the outcome of an ongoing Transport Capacity Study). While much of this housing development is dependant upon the completion of the Hastings to Bexhill link road, MOD 8.10 indicates there is also potential at 'broad locations' around the northern and western edges of the town. Paragraph 8.59 of the Proposed Submission Core Strategy states that development "may be extended westwards adjacent to the urban area without undue impact on the wider landscape". Paragraph 8.60 also indicates that development to the west of Little Common, both north and south of Barnhom Road (A259) will also be considered with access created directly onto the A259, with the scale, timing and locations ideally being determined at the site allocations stage (MOD8.11).

3. Within this context, the updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) will be an important consideration, but until now, there has been no opportunity for developers or landowners to scrutinise the Council's conclusions in the respect of the separate sites identified.

4. As regards one of the Council's stated intentions of a broad location for housing growth being identified around the 'western edges of the town', land at the western end of Barnhorn Road (A259) would be a key consideration. The main candidate site in this respect would be SHLAA site BX50, which comprises an undeveloped parcel of land outside the High Weald Area of Outstanding Natural Beauty that is located to the west of no. 163 Bamhorn Road (see SHLAA extract contained in appendix 1 attached). The land comprises an undeveloped gap in otherwise built front frontage where public views along the A259 are screened by tall evergreen trees along the road frontage.

5. Although the land has been assessed by the Council as a 'red' site not suitable for housing development, this conclusion is open challenge and these representations (i.e. TCPS Representations No. 6) make the case that this land is suitable and should be examined in detail as to its potential at the site allocations stage.

6. The 'Technical Note' contained in appendix 2 attached demonstrates that access could be obtained to serve up to 40 dwellings on the site. The Technical Note contains an illustrative drawing no. 4377/1 showing layout of 32 dwellings on the site comprising a mix of two, three and four bedroom units that would include 40% affordable housing. The illustrative layout demonstrates the retention of trees along the road frontage and availability of space to create landscape buffers around other boundaries of the site.

7. Thus, this housing development would comprise a western extension to Bexhill and make a useful contribution to housing supply in a form that is not dependent upon the construction of the link road. The Council's recent decision to resolve to permit 275 dwellings to the north of Barnhorn Road (planning application no. RR/2012/1978/P) confirms that a new access onto the A259 can be acceptable in principle.

Supplementary information submitted with the representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20686