MOD 2.1

This paragraph is not justified as it is a virtual repeat of para 187 of the NPPF.

MOD 2.1 Main modification unsound.
There is no mention of including the residents of Rother in the process. They should be considered at each point when discussions are taking place with developers. Wrong/incorrect decisions made (especially in a village environment) would seriously detract from the rural identity and charm of the village.

Taylor Wimpey supports the positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework and the recognition on the part of the Council that a planning application that accords with the policies in the Local Plan will be dealt with promptly.

2.1 states "The Council will always work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area". This presumption of development of green-field sites and in areas of AONB will not be supported by long term economic growth. There have been no definitive indications of employers actively seeking to base themselves in Robertsbridge and there has been no report issued by RDC showing such employment growth in Robertsbridge. Within the Conservatives Green Paper 2010, they suggest that the short term end to the current recession will be aided by the Construction industry and these modifications follow on that train of thought. The problems that exist within the UK housing market are low stagnant wages, over-inflated house prices and excessive rents. Mortgages are out of the reach now of the average UK salary being £16,034 pa (ONS) with a loan to value rate of 80%. Without strong & stable employment, house prices including rented accommodation will be severely restrictive for most UK households. Renting averages in TN32 postcodes ranges from 1 bedroom houses at £576 pcm, 2 bedroom at £713 pcm and 3-4 bedroom houses from £1,048- £1,500 (ONS & Home Market statistics) Central government and the Council have not made a clear & reasonable economic reason for such increases in house supply which is contrary to the NPPF.
MP Greg Clark writes "In part, people have been put off from getting involved because planning policy itself has become so elaborate and forbidding - the preserve of specialists, rather than people in communities. This National Planning Policy Framework changes that. By replacing over a thousand pages of national policy with around fifty, written simply and clearly, We are allowing people and planning"
The current modifications and government agenda are exclusive in its design since only 40% of development is for affordable (housing association) and therefore is not sustainable in the long term and will only seek to exacerbate the stresses already seen in the economy & environment. Definitive proof must be provided to show water supply, flooding and the associated costs to individual households have been addressed. At present they have not.

The main modifications are not legally compliant as the plan does not align with national policy. Neither does the plan reflect the local Catsfield Plan. The main modifications do not reflect local needs, so are not justified. The plan is not sound as the proposed allocation for Catsfield is disproportionate to other villages. The way in which numbers of dwellings have been dispersed across the district results in the plan not meeting the objectives of the overall policy.

We are pleased that the document now takes on board the thrust of the new NPPF document and no longer refers to the defunct South East Plan.The increases to housing supply are welcomed which will aid to create a more prosperous local economy which in turn will be significantly beneficial to local communities.

MOD 2.1 This is welcomed and supported as it gives the correct national planning policy framework its correct status.

Bovis Homes Ltd have established a stake in the Trinity College owned land at North East Bexhill (Glovers/Worsham Farms) proposed in the Adopted Local Plan for strategic growth (Adopted Local Plan Allocation BX2).

Bovis Homes Ltd have carefully considered the Council's proposed modifications issued in the Schedule of Main Modifications document (August 2013) and the implications the proposed modifications have for the future development of the urban extension at North East Bexhill (Local Plan Allocation - BX2).

Bovis Homes Ltd can support the proposed modifications and consider them to be sound. In particular, Bovis Homes Ltd are in support of the modifications confirming the Council's positive approach to reflect the presumption in favour of sustainable development and its intention to deal promptly and approve development schemes that accord with the Local Plan, unless material considerations indicate otherwise (Mod 2.1).

Bovis Homes Ltd also supports the modifications confirming the funding of the Bexhill to Hastings Link Road (Mod 4.1); and understands the Council's clarifications regarding the revocation of the South East Plan and its housing targets (Mod 2.2).

Bovis Homes Ltd accepts the Council's conclusion that the housing levels should be set at a level which is considered sustainable, in terms of balancing jobs and growth and taking into account transport infrastructure and impacts on the environment etc. (Mod 7.4). Bovis Homes Ltd therefore supports the modifications increasing the amount of housing to be delivered in the District over the plan period from 3,700-4,100 to at least 5,700 dwellings between 2011 and 2028 (Mod 7.5); and the Council intention to positively support an increase in house building rates (Mod 7.6). Bovis Homes Ltd strongly supports the Council's confirmation that the revised housing figures should be considered minimum targets to achieve, rather than rigid development ceilings (Mod 7.12).

Bovis Homes Ltd particularly supports the Core Strategy's continued emphasis on focusing growth on the town of Bexhill and in particular the urban extension at North East Bexhill; and the revised housing figures for Bexhill: 3,100 dwellings (Mod 7.14).

For the record, Bovis Homes Ltd can confirm that an agreement has now been reached with Trinity College, owners of Glovers/Worsham Farms to prepare and submit a planning application for at least 1,200 homes on the BX2 site, as soon as reasonably practical. The current intention is to submit a hybrid planning application early in the second half of 2014 with the first phase of development to be considered 'in detail' in order to accelerate the delivery of homes once consent has been issued. The scheme's anticipated determination date is early 2015, and the scheme's commencement date is expected to be later in that year. The timetable is related to the construction and delivery of the Hastings to Bexhill Link Road and the recently permitted 'Gateway Road/junction', which will provide the main means of access for the residential site, and the adjacent commercial site to be delivered by Sea Change Sussex (previously SeaSpace). The development trajectory for the residential site is approximately 125 dwellings per year, subject to market conditions.

Bovis Homes Ltd are meeting with the Council's Planning Team to agree a programme to bring forward the planning application's preparation and determination in an efficient and timely manner.

My objections to the Main Modifications relate to:
MOD 2.1 P.6
MOD 7.4 p.31
MOD 7.11 p.34
MOD 12.4 p.80

My objections are as follows:
* The Main Modifications to the plan would make it incompatible with the overall policy. They do not take account of local needs, the allocation is disproportionate in relation to other areas in the district and the numbers do not relect the real situation in terms of additional dwellings in the village.
* The numbers identified in the Modification to Figure 12 is disproportionate and not justified in relation to allocations to other areas in the district.
* The requirement in the Policy to meet local needs and ensure that development is in line with the character and sustainability of services is not reflected in the Modification to the Plan, in relation to Figure 12. Due account has not been made to:
*windfalls
*services in the village - there are no primary school places available in the village, there is no access to medical services, the roads are under severe pressure due to traffic to and from Bexhill to Battle Station (due to poor service on the line from Bexhill), there has already been a fatality, broadband link up is extremely poor due to the village being at the end of the line and the village experiences electricity supply failures quite frequently.

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.