1. 3.5.1 Sustainability Appraisal reads "Economic recovery has become the national imperative, although it is likely that the process wtll be a lengthy and difficult one. The need to promote economic recovery is also the primary influence on policy makers, as exemplified in the National Planning Policy Framework". How will the short term effect of further increasing residential housing numbers from 119 to 155 have on economic recovery wtthout adequate employment facilities. Please note that the increase of people travelling to & from work, whether by train, car or bus adds to greenhouse gases and unsustainable travel costs for employees as wages continue to stagnate against inflationary increases. The current train season ticket cost from Robertsbridge to London is £4,500 and is set to rise 4% over the next year.

2. 5.2.1 Sustainability Appraisal reads "As previously outlined, there is a requirement to revisit the assessment of housing need. This is in the light of the even greater weight now given to the NPPF and to meeting current objectively assessed need." This has not been positively prepared as the effects of increased housing numbers to 155 as it would appear are not for immigration needs or those solely coming to the area from outside the UK, but the increase accommodates people wishing to move out of London due to the excessive expense in living there. Yet, what indication is there that those properties vacated by such people wishing to live in a rural location can be afforded by those who wish or need to live in London?

3. 5.2.9 Sustainability Appraisal reads "Careful consideration should be made to the balance of jobs to support housing growth, the capacity of the transport network to accommodate a higher housing target". There is insufficient local employment to justify increased housing numbers and the strain of increased motor vehicle usage which is already problematic, will be greatly exacerbated. The village during term times is already congested and without changes to the network structure, how will the increased vehicle numbers be safely achieved without damaging the aesthetics and characteristics of the historic village? Any such changes in road networks & housing numbers would be contrary to 6.7.7. Sustainability Appraisal which states "The key test for growth in the villages is whether it reflects the vision to retain their distinctive, individual character and qualities, as well as support local services and community "life".

4. From the NPPF, "This should be a collective enterprise. Yet, in recent years, planning has tended to exclude rather than to include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them." There has been insufficient village and locality engagement within the consultation processes which itself is complex, too restrictive and itself excludes residents from the changes that are being imposed by central & RDC governments. Are all age groups of the population adequately accommodated in terms of representation access and facility? Please note that only 31 people responded to the last consultation process for the whole of RDC. Therefore this further increase is contrary to the basic foundations of the NPPF.

5. With regard to the NPPF three dimensions to sustainable development, an environmental role - contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy", this will not be achieved due to heightened risks of flooding, increased carbon emissions from homes (which are the biggest emitters of C02) and degrades wildlife, hedge-rows and the historic environment of Robertsbridge. This would be contrary to NPPF paragraph 18: "The Government is committed to securing economic growth in order to create jobs and prosperity, building on the country's inherent strengths" & is contrary to paragraph 28 "promote the development and diversification of agricultural and other land-based rural businesses" & promote*the retention and development of local services and community facilities".

6. NPPF paragraph 14 states: "any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole". This increase of a further 36 homes on top of the existing 119 has not been shown to outweigh the benefits nor have the residents been consulted in an efficient and effective way throughout the process, a central tenet of the NPPF. Those without internet access are greatly disadvantaged - in this case charges of £5 are levied for hard copies of this consultation.
The NPPF states in point 6, 47 "identify and update annually a supply of specific deliverable11 sites sufficient to provide five years- worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land.Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land". This is in direct conflict with the underlying principles of the NPPF and clearly shows the predisposition for building increased housing numbers at the expense of rural & town communities and safeguarding existing natural & historic amenities. Furthermore point 47 goes on to say "set out their own approach to housing density to reflect local circumstances". The current process of imposing targets on communities from other bodies is against the principles of the NPPF and this point in particular. By forcing local authorities to have an annually updated supply of sites and increasing housing numbers which are encouraged to do so by financial incentives to build, the safeguards of ensuring sustainable growth (if possible) without long term detriment to the environment and local communities.

7. NPPF point 50 states "identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand". Currently there are a considerable number of houses for sale in Robertsbridge many of which have been on the market for many months. Where is the local demand for 119 -155 extra properties? Currently (2/9/13), there are 32 properties for sale within Robertsbridge and 105 within a 5 mile radius of the village. The Local Plan and modifications to the Core Strategy have not made a case for building further properties as the market is already available with properties.

8. NPPF point 55 states that "the exceptional quality or innovative nature of the design of the dwelling. Such a design should:
- be truly outstanding or innovative, helping to raise standards of design more generally in rural areas;
- reflect the highest standards in architecture;
- significantly enhance its immediate setting; and
- be sensitive to the defining characteristics of the local area."
With current market forces presently in operation, how will developers build such houses and keep the cost down of new builds so people in the area who earn on average £6.000 pa less than other areas in the South East can afford to buy them? The current average price for properties nationally is between £198,000-330,000.

9. NPPF point 69 states "safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas'. Further congestion in Robertsbridge Village centre and by the school strongly suggests dangerous road congestion leading to pedestrian & motor vehicle accidents. Increased congestion suggests negative effects on existing businesses within the area through loss of income due to limited parking and overcrowding.

10. Points 79 & 80 of the NPPF state the importance of green belt protection. By the increase in housing even to 119 then possibly 155, such spaces will be lost and damaged irreversibly. Point 80 states: ''To check the unrestricted sprawl of large built-up areas;
* To prevent neighbouring towns merging into one another;
* To assist in safeguarding the countryside from encroachment;
* To preserve the setting and special character of historic towns; and
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land".
The current increases in housing go against the fundamental principles of the NPPF Green Belt Land policy.

11. NPPF point 96 states: "take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption". This has a direct impact with point 55 of the NPPF and will adversely affect the village community.

12. NPPF point 103 states:"When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where, informed by a site-specific flood risk assessment20 following the Sequential Test, and if required the Exception Test". With the increase in housing, water run-off will add to flood risks and will adversely affect insurance premiums for those living in flood areas.

13. Paragraph 11, point 109 states: "protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability;
* Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. This is clearly not met by increased housing numbers within Robertsbridge by the extensive loss of natural areas for such housing numbers. Point 115 NPPF states "Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty". Robertsbridge is in an AONB; therefore any further housing greatly reduces its natural beauty!
The presumption of development within the NPPF and other documentation is based heavily on economic growth at the expense of sustainability (the official meaning used by Government found on the introduction of the NPPF is nebulous and ill defined). At present the housing numbers exceed the ability for the locality and the presumption of house-building is unduly weighted in favour of developers and Councils who will receive an incentive for house building. The Chartered Institution of Water and Environmental Management (CIWEM) have raised these severe problems in reducing the NPPF to a bare-bone structure which removes many safeguards found in previous NPPF documents. The increase in housing numbers therefore represents "a builder's charter to develop at the cost of wider local & environmental interests as opposed to considering economic, social & environmental factors in a balanced manner which respects the principles and recognised definitions of sustainable development and the best interests of all in society".
The average rise in property prices in the UK as defined by ONS notes and increase of £833 or 2.9% to May 2013. The increase of 155 houses in Robertsbridge is not enough to lower the over inflated house price within the UK. The rise of properties was due to banks increase in profitability with their mortgage products which rose 450% in profitability for the banks. The increase in housing supply is insufficient to bring down housing costs but is too great (155 houses) for this area to accommodate with detrimental effects for the community.
CHART UK House Prices: 1997 - 2010
Secondly house prices rose considerably faster and higher than wages. This remains severely problematic for this area and remains one reason why new build housing is unaffordable for a large percentage of people. This principle is contrary to NPPF's policy of community inclusion.

Further supporting evidence was submitted and can be found using the following link:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20618