Main Modifications to the Proposed Submission Core Strategy

We support the Councils justification for delivering 500 new dwellings. This settlement is clearly sustainable with many services available. An increase of 500 dwellings would represent a significant increase in the housing stock (17% in Battle Parish), even though it is only a 11% increase on what has been suggested. Although Battle falls within the AONB "the SHLAA has revealed that there are sites across the town the development of which, while having some local impact on the AONB setting, could be developed"(para 49 Rother DC Summary Appraisal 2013). Given the above,the prospects of development are currently uncertain for "broad locations", which lead to uncertainty over the Council's housing future housing trajectory.

What is apparent is that without any additional landscape assessment the Council accept considerable opportunities exist within a settlement located in the AONB. Other significant sustainable settlements such as Robertsbridge therefore clearly have greater potential to deliver more housing. This would help meet the District needs but is restricted because a landscape capacity assessment of the SHLAA opportunities of these villages has not been properly undertaken. The Council's current distribution is arbitrary as it lacks the evidence upon which to judge each settlement's housing capacity.

The Councils INSERT suggests that the assessment of the SHLAA review 2013 responds to "the need to maximise opportunities for sustainable growth" It also states that this proposed level of growth is supported by the most recent Sustainability Appraisal(SA)but highlights the increasing negative impacts of development on the character of both settlements and wider countryside. This last statement however lacks the evidence to substantiate such a claim as NO new landscape capacity assessment has been undertaken to establish at what point and at what level of housing does further housing allocations significantly impact on individual settlements.

As an example the previous SA (Nov 2008) considered a Scale of Growth under Option 2 SE Plan requirements +25% (350pa)which in general is comparable with the Councils current SA on Option B3 of the Councils target of 5700(335pa)in that the SA objective 15 " Protect and enhance the high quality natural and built environment..in particular the protection of the AONB assessed both these levels of development as neutral.
However, Option B4 of the current 2013 SA, which would meet the Councils housing needs(6180) under the same objective 15 test now suggests that an additional 480 dwellings(28pa) would lead to an (x)category assessment for the plan over the medium and long term i.e. "option appears to conflict with the objective and MAY (my emphasis) result in MINOR adverse effects" There is NO evidence to assess the landscape impacts of these options and therefore the SA assessment is not robust or justified.

The assessment of other objectives compared in the current SA suggest a lack of explanation between the differing negative marks set against Option B4 compared with those of B3 with many comments remaining the same even though B4 had more x,s against objectives 6,9,10,11.

Further supporting evidence submitted can be accessed using the following links:

http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

The Councils revised Figure 12 Distribution of Rural Housing continues to lack the evidence base or appropriate analysis of the Rural Hierarchy of the Rural Area and hence continues to fail in its obligation to distribute the housing numbers capable of meeting the Districts overall housing needs.

The Rural Areas objectives (Para 12.6 Local Plan) sets out to "promote thriving rural communities"; to be demographically balanced and socially inclusive, particularly in terms of access to housing " and support sustainable local employment opportunities and the economic viability of rural communities"

Robertsbridge is classified by the Rural Settlement Study as a Rural Service Centre. It is the largest settlement in the "Rural Area",it has a mainline station,a secondary school and immediate access onto the main A21 trunk road. This has to be compared to Ticehurst and Northiam villages which have no station and no secondary school yet now has proposed a further increase in new housing from the deposit Plan of 58% and 105% respectively. The Council appear to have applied an across the board increase in housing to various villages without the proper Landscape and Sustainability appraisals.

Due to the unique characteristic of Robertsbridge and its location in the northern part of the District the settlement should be recognised as a new Sub-Area Structure. This would produce greater information and accuracy upon housing affordability and need in this area. This new Sub-Area would rightly highlight the role of this settlement strategically and identify a greater housing need and establish its economic role and potential in the District.

The Councils Spatial Development Options highlighted in the Rural Settlement Study gave a clear steer, directing development towards service centres e.g. Robertsbridge. This objective continues not to be properly investigated by the Council.

The Councils SHLAA review(2013)continues to rely upon evidence that is out of date or inappropriate i.e. landscape assessments made on SHLAA sites are based upon a study inappropriate to assess the capacity of various settlements to accommodate further housing. The Landscape studies undertaken in 2008/9 were so broad that the assessment of individual sites could not be properly considered. The study's analysis was often quite sweeping and often contrary views were expressed with no explicit justification.

With particular reference to the landscape assessment of Robertsbridge the landscape zones appeared to be arbitrarily defined with little obvious rationale and given the importance of the AONB lacked basic details, such as contours and landforms which do not appear to have played any part in the definitions of the zones. Given that over 80% of Rother falls within the AONB any landscape assessment should include a consideration of capacity especially if the Council wishes to meet its District housing need.

A Rural Settlement Study should properly set out the basis for a sustainable housing distribution hierarchy based upon services and facilities available and the role of individual settlements within the Rural Area.

The Council should also update and review its Housing Needs Survey(2005) and rightly identify Robertsbridge as a new Sub Area Structure with its immediate rural hinterland i.e. Salehurst, Hurst Green and Burwash (this may of course include other settlements across the Tunbridge Wells border).

Subject to a proper Landscape Capacity Assessment Robertsbridge is clearly a sustainable settlement occupying a strategic location in the northern part of the District with excellent accessibility to varying modes of transport(A21 and mainline station) offering great potential for economic growth. The Council currently do not have the evidence available that would suggest only a further 100 new dwellings would be justified over the next 15 years i.e. 10pa

When you compare this figure against that proposed for Battle (a settlement also in the AONB)of 500 this represents a 10% increase on its current population. A similar 10% increase for Robertbridge would yield a figure of 234 new homes over the plan period. The submitted SHLAA sites suggest this figure could be achieved without significant harm to the village setting in the AONB.

Further supporting evidence submitted can be accessed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

It is inappropriate to include previously unidentified large sites(6 dwellings and over)as contributing towards "Potential new sites" prior to adoption of the Plan as the Council consider the target of 5700 as a minimum. Any sites granted consent prior to the Plans adoption are clearly windfall sites that fall within this unidentified category and therefore should be viewed as such and not used to reduce the Councils minimum target. This approach should also apply to developments of less than 6 dwellings and "Exemption sites"

Policy EC2 in the Deposit Plan clearly sets out in paragraph its objective of (iii) "Improving the supply and range of small-medium sized sites, in towns and villages which act as local service centres, particular those that have good strategic accessibility(i.e. to the A21 road and rail corridor)"This objective should remain. This paragraph gives clear guidance on the strategic sustainable criteria over where employment sites should be directed. Indeed, settlements should be rightly identified where appropriate employment targets can be meet. The proposed amendment provides no strategic guidance for employment especially in the Rural Area i.e. Robertsbridge. This is inconsistent with NPPF paragraph 19 which state "Significant weight should be placed on the need to support economic growth through the planning system" The NPPF (para 28) state that planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development.

The Employment Strategy and Land Review suggested a provision of 10,000sq m for Battle(a settlement
in the AONB)yet no employment provision is set for the largest sustainable rural settlement-Robertsbridge. An overall target of 10,000sq m is set for the Rural Areas but this does not set out any proper strategic guidance or sequential approach based on individual settlement sustainability i.e. priority to sustainable towns and villages.

The Council appear to have deleted its previous paragraph (iii) purely because it did offer strategic guidance "in towns and villages which act as local service centres, particularly those that have good strategic accessibility(i.e. to the A21 and rail corridor)". This does appear to point towards Robertsbridge as a suitable sustainable settlement for further employment provision.

In the amended Appendix 3 Housing :Component of Housing Supply for period 2011 to 2028 the Council have made an allowance of 460 small windfall sites and 65 Rural Exemption Site Allowance giving a total of 525 unidentified sites over the plan period. The Council state that "at least 5700 dwellings" will be delivered over the plan period (yet accept that their housing need is 6180). The only way the minimum target of 5700 could be exceeded is via unidentified sites. Therefore to have around 10% of its minimum housing requirement already identified as windfall/exemption sites suggest that 5700 in reality is not a minimum housing figure as it already includes the only unidentified housing supply component over the 17 year plan period. Where else is any future housing supply likely to come from to exceed 5700 other than unidentified sites?