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CLERK'S BRIEFING NOTE 3-12

CORE STRATEGY DPP's REPRESENTATIONS 2011

 

1. The Core Strategy is the key planning document within the Local Development Framework (the LDF includes many background documents). It will set the overall vision and general distribution of development for the district up to 2028. It identifies broad locations for future housing and other development needs, including for employment, shopping and community facilities, but not specific sites. These will follow in a separate document called the Development and Site Allocations Plan Document.

2. The Core Strategy has been compiled from the views of many who have helped shape the document through consultations and events. Hundreds of representations were made on previous iterations of the Core Strategy.

3. On 19/08/11, the Core Strategy in its final draft was published by Rother DC and a 12-week period for representations ended on 11/11/11. All representations made can be seen online. In making representations, consultees were asked to consider whether the Draft Core Strategy was Justified; Effective; Consistent; Procedurally and Legally competent.

4. The main issues raised by representations are due to be reported to Cabinet on 20/02/11 (or maybe later) and following approval the draft will be subject to a Public Inquiry in front of an Inspector before being adopted.

5. During the latest consultation period, DPP and John Keeling were working on their development plan for the land adjacent to Street Farm in Brede Lane. They met the Parish Council on 01/11/11. It is noted that DPP made several representations on the Core Strategy on behalf of John Keeling and would like to present their case to the Inspector in due course as follows:-

  1. Policy RA1(v): Villages. This policy states that "in order to meet housing needs and ensure the continued vitality of villages, the provision of 950-1,000 additional dwellings (comprising both existing commitments and new allocations) in villages over the Plan period 2011 to 2028. This will be located in accordance with Figure 12, subject to refinement in the light of further investigations via the Development and Site Allocations DPD and/or Neighbourhood Plans."

    1. DPP made the following comments (summarised):
      1. They are encouraged to see exact housing numbers are flexible especially as their client's emerging proposal could deliver more than the anticipated figures for Sedlescombe as a whole. [NB Sedlescombe's figures are shown as 33 commitments (this figure should be 28), 8-25 proposed new allocations; 41-58 total new housing 2011-2028.]
      2. They do not support the lowering of the original target derived from the South East Plan figures. [NB Sedlescombe's housing targets have in fact been raised. When the South East Plan was in operation, 0-10 houses were expected to be built in Sedlescombe in the Plan period.]
      3. They believe that Rother's approach to housing targets is fundamentally flawed in that it plans for under provision and have serious misgivings about Rother's ability to deliver sustainable development given this overt plan for under provision.
      4. They believe that in rural villages access to affordable housing and a good range of services is essential to maintain viability and vitality. [NB Sedlescombe already has 15.8% of its housing stock as affordable social housing to rent, the second highest percentage in Rother District.]
      5. They believe that restricting housing growth in villages will ultimately undermine the health of individual villages and inhibit other forms of development such as employment. [Housing growth must be considered in conjunction with the existing infrastructure and facilities.]
      6. They go on to be more specific about their client's development plan which they say will
        1. Provide a "much-needed" replacement pre-school facility. [NB No figures have been provided to show that the pre-school facility for local children is required, nor the proposed size, and that it will not just increase traffic coming into the area from surrounding towns and villages rather than meeting a local need.]
        2. Provide enhanced primary school facilities. [NB Apart from a small playing field, no other primary school facilities are currently being proposed.]
        3. Provide employment uses. [All workshop uses create additional traffic along a route which is already congested at certain times of day.]
        4. Provide public open space. [NB No public open space is currently being proposed.]

        However they say these non-residential uses will not be delivered by a smaller scheme (ie less than 40-45 houses) and therefore the benefits of these uses for the village will be lost. [NB It is only the pre-school facility that will be subsidised by the houses as the primary school playing fields and the public open space could be gifted to the school/village as has happened in the past. The employment workshops would, presumably, be self-supporting.]

      7. They believe that the housing numbers included for Sedlescombe will frustrate Rother's intention to maintain the vitality and viability of the Village.
      8. They are asking for the housing target to be increased to at least 60 (ie up from 41 which ought to be adjusted to 36 to correct some errors made by Rother in their calculations) or to change the wording to make these the minimum number of houses that will be built.

  2. Policy RA1(iv). This policy states "Support for community, recreational and educational facilities that provide social and community benefits to villages (including village/community halls and recreation areas). This may include provision of improvements to existing village halls or new halls, as well as support for further community resource centres/hubs, where appropriate."

    1. DPP made the following comments:
      1. They believe this wording does not sufficiently reflect the importance of education and potentially could prevent provision of educational facilities being granted sufficient weight in the decision making process.
      2. John Keeling is "passionate" about the continued preservation and enhancement of Sedlescombe Primary School.
      3. They state that the Rural Settlements Study (2008) identified that even without any new housing in the village, the school will soon be close to capacity. [This does not take account of the fact that 63% of the children currently attending Sedlescombe School come from outside the Village and that boundaries could be adjusted by the Education Authority.]
      4. They state that the school and the LEA have identified the need for the school to develop a seventh classroom in the future. [The school already has a seventh classroom. They would like one built on to the existing school rather than to be in temporary accommodation but it does not appear as if there are any plans to extend the school further.]
      5. They want to see a policy included that actively promotes additional educational facilities in the Village of Sedlescombe. [The LEA's current policy of extending the school beyond its site's capacity and over-providing school places considering the small percentage of local children who attend the school has only brought congestion, danger and unpleasantness to the roads around the school. Any attempt at further expansion of the school on the current site is likely to be strongly resisted by the Parish Council unless parking provision can be provided at the same time.]
  3. Para 12.18 states "In terms of phasing, it is generally assumed that existing housing allocations (provided they have been demonstrated in the SHLAA and through Housing Monitoring as deliverable) and outstanding permissions will be developed in the earlier phases of the Plan. In villages which have seen higher levels of development in the first few years of the plan period or have existing commitments in the pipeline, any new and additional allocations will normally be phased in the latter part of the plan period to ensure a balanced rate of development. It is considered that this will be beneficial to the social cohesion of existing villages. The Council will also be mindful of the need to demonstrate a '5-year supply' of housing."

    1. DPP doesn't agree that new allocations should be restricted to later phases as this would mean that their client's site which is available now and "has been considered as suitable in principle by the SHLAA" could not be delivered for at least another 5-10 years. As Sedlescombe's developments in the pipeline are small they are unlikely to deliver affordable housing. [NB The SHLAA development sites have not been considered properly yet and the Street Farm site is currently outside the development boundary. Sedlescombe already has 15.8% of its stock as affordable social housing to rent and a recent planning application by Amicus Horizon Housing Associations is planning an additional nine affordable homes at East View Terrace. DPP told the Parish Council that it was not its intention to provide the recommended percentage of social housing on the Street Farm site but would be looking to build mainly larger homes.]
    2. According to DPP, the Core Strategy is actively seeking to prevent the delivery of affordable housing in the village for the next 5-10 years in contrast to their scheme which will provide affordable housing, new educational facilities, new employment opportunities and new open space.

P J Raymond
Clerk/RFO
8 January 2012