Main Modifications to the Proposed Submission Core Strategy
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Main Modifications to the Proposed Submission Core Strategy
MOD 2.1
Representation ID: 21563
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The final sentence of the modification should be deleted. Nowhere in legislation not even in NPPF requires the Council to be 'proactive' in working with applicants. That clearly upsets the balance that LPAs have as their duty to handle applications. NPPF talks of acting positively which is not the same thing at all .Nor is there legislation which enshrines as a principle that' proposals can be approved wherever possible' without any caveats conditions or cautions.
The final sentence of the modification should be deleted. Nowhere in legislation not even in NPPF requires the Council to be 'proactive' in working with applicants. That clearly upsets the balance that LPAs have as their duty to handle applications. NPPF talks of acting positively which is not the same thing at all .Nor is there legislation which enshrines as a principle that 'proposals can be approved wherever possible' without any caveats conditions or cautions.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 7.9
Representation ID: 21564
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The final clause in this proposal is unbelievably vague and cannot stand as a policy. What assessment process; what criteria for assessment? lt is no help as guidance, and RDC needs to consider what criteria if any could be used to identify possible development in these towns and put it to public scrutiny not keep it secret until it has thought of something.
The final clause in this proposal is unbelievably vague and cannot stand as a policy. What assessment process; what criteria for assessment? lt is no help as guidance, and RDC needs to consider what criteria if any could be used to identify possible development in these towns and put it to public scrutiny not keep it secret until it has thought of something.
Support
Main Modifications to the Proposed Submission Core Strategy
MOD 7.11
Representation ID: 21565
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
We support the amendment emphasising absolutely the words from 'without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.
We support the amendment emphasising absolutely the words from 'without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 7.19
Representation ID: 21566
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The addition takes no account of the actual effect of windfall sites be they small or large in a village setting. This provision should permit the LPA to count windfall sites against any pre-set allocation for any particular village so that the village does not have to accept its housing allocation PLUS any windfalls in addition which may be granted during the plan period.
The addition takes no account of the actual effect of windfall sites be they small or large in a village setting. This provision should permit the LPA to count windfall sites against any pre-set allocation for any particular village so that the village does not have to accept its housing allocation PLUS any windfalls in addition which may be granted during the plan period.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 8.1
Representation ID: 21567
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The deletion of this provision flies in the face of evidence which has been made available in relation to the BHLR. Stopping trains will not harm timetabling. There will be a clear need for such given the growth in shopping provision at the site and evidence from rail use in a similar situation at Meadowhall would suggest it is a valuable public utility and extremely sustainable.
The deletion of this provision flies in the face of evidence which has been made available in relation to the BHLR. Stopping trains will not harm timetabling. There will be a clear need for such given the growth in shopping provision at the site and evidence from rail use in a similar situation at Meadowhall would suggest it is a valuable public utility and extremely sustainable.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 12.2
Representation ID: 21568
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
This modification pushes more development towards the villages which are in AONB rather than seeking development on the coast where there is infrastructure to cope with additional development. Villages are not equipped to cope with the impact of 'maximised' opportunities for development and NPPF paras 114, 115, 116 and 120 do not support this approach. It also does not sit with MOD 7.11.
This modification pushes more development towards the villages which are in AONB rather than seeking development on the coast where there is infrastructure to cope with additional development. Villages are not equipped to cope with the impact of 'maximised' opportunities for development and NPPF paras 114, 115, 116 and 120 do not support this approach. It also does not sit with MOD 7.11.
Support
Main Modifications to the Proposed Submission Core Strategy
MOD 12.3
Representation ID: 21569
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
We support this policy since the new legislation will remove employment space which is absolutely required if villages are to remain or even become sustainable. Without work in a village the village will die. As a sub text the new legislation permitting change of use needs changing for all villages locations.
We support this policy since the new legislation will remove employment space which is absolutely required if villages are to remain or even become sustainable. Without work in a village the village will die. As a sub text the new legislation permitting change of use needs changing for all villages locations.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 12.4
Representation ID: 21570
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC.
In light of the increases for certain villages the only way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.
This modifications sets to find ways of increasing numbers in villages which for Rother means villages in AONB, so the NPPF criteria apply. It does not appear than RDC have applied this in simply increasing numbers so the higher original allocations get more. RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong in principle to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC. Therefore the whole principle of identifying numbers for each village is clearly unsound whether they are stay the same in the modification or in many cases now an increased number.
In light of the increases suggested for certain villages the only possible way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 12.5
Representation ID: 21571
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC.
In light of the increases for certain villages the only way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.
This modifications sets to find ways of increasing numbers in villages which for Rother means villages in AONB, so the NPPF criteria apply. It does not appear than RDC have applied this in simply increasing numbers so the higher original allocations get more. RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong in principle to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC. Therefore the whole principle of identifying numbers for each village is clearly unsound whether they are stay the same in the modification or in many cases now an increased number.
In light of the increases suggested for certain villages the only possible way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.
Object
Main Modifications to the Proposed Submission Core Strategy
MOD 12.6
Representation ID: 21572
Received: 27/09/2013
Respondent: Rother and Hastings CPRE
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Please see our comments on Mod 7.11 (see below) which are relevant here and the whole mod needs re-writing to ensure that windfall sites in villages ARE counted towards the allocations each village has.
Mod 7.11: We support the amendment emphasising absolutely the words from ' without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.
Please see our comments on Mod 7.11 (see below) which are relevant here and the whole mod needs re-writing to ensure that windfall sites in villages ARE counted towards the allocations each village has.
Mod 7.11: We support the amendment emphasising absolutely the words from ' without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.
