Proposed Submission Development and Site Allocations (DaSA) Local Plan

Paragraph 5.40 explains that draft Policy DEC3 effectively 'supersedes' Core Strategy Policy EC3. The opportunity should therefore, have been taken to review part (iv) of the draft policy as to whether the 'cascade requirements' remain necessary and reasonable. If an employment use is demonstrated not to be viable, if after considering 'complementary enabling development' or a 'mixed use scheme', it is unlikely that 'prioritising alternative community uses' would be viable and the intention of this requirement is unclear as to its planning purpose and should therefore, be deleted.

In addition, the reference to 'affordable housing' should be deleted, as the need for this would be triggered in any event if the provision contained in Policy DHG1 were to apply to a redevelopment scheme, and the words "subject to local needs" is meaningless and should also be deleted.

The Policy should therefore, be amended after the words "if a mixed use scheme is not viable" to delete the remaining wording and replace this with "then other suitable uses will be considered including housing development".

To aid the users of the Local Plan and for ease of referencing, it would be helpful if the document could be amended to include page numbers for the individual policies listed on pages 5 - 7 and also include page numbers for the individual Inset Maps listed in page 8.

In Appendix 1 (pages 281 and 282), it would be helpful if page numbers of the Core Strategy were to be set against the individual policies referred to.

In addition, in Appendix 2 (pages 283 and 284), for the avoidance of any doubt, it would also be helpful to the users of the document if the list could be extended to include the 2006 Local Plan policies that remain 'saved' until such time as relevant Neighbourhood Plans are made that will supersede them.

Peasmarsh is an attractive and small settlement situated within a rural part of the High Weald Area of Outstanding Natural Beauty. Although the Rother Core Strategy set a target to deliver 50 additional dwellings in the settlement, some 10 of these have already been permitted at The Maltings the subject of planning application no. RR/2016/4/P, leaving a balance of 40 to be provided for at Peasmarsh prior to the end of the Plan period.

The Option and Preferred Options version of the DaSA published in December 2016 considered and assessed a number of alternative sites but settled on the preferred site now the subject of proposed Policy PEA1 as shown on Figure 54 and on Inset Map 12 for Peasmarsh for 45 dwellings (net). The proposed access (regarding the demolition of a detached residential property known as 'Pippins') is unsuitable however, as an access road in this location, immediately adjoining the other residential properties on either side (at 'Wheelers' to the east and 'Cochland Cottage' to the west) will have an unacceptable impact upon their amenities and living conditions as a result of noise disturbance and fumes from traffic turning at the new road junction and when passing along their side garden boundaries.

It is also understood that the land is the subject of surface water flooding and it remains unclear how the land could accommodate the proposed development without giving rise to further flooding or transferring the flood risk to adjoining land.

For these reasons, the proposed housing allocation is defective and is not properly justified set against the potentially better alternative available and given that suitable access cannot be achieved that does not either rely on the demolition of 'Pippins' or cause serious loss of amenity to the two neighbouring properties either side, the proposed housing allocation will not be effective in meeting the Core Strategy's housing target for the settlement and in this respect, the DaSA housing provision at Peasmarsh has not been positively prepared.

The draft Plan should therefore, be modified to delete this proposed housing site and other alternative sites should be reviewed as to their better suitability to accommodate the additional 40 dwellings required.