MOD 2.2

The Councils broad strategy to focus development along the coastal part of the District is based upon an obsolete SE Plan Strategy now revoked. The Council has an obligation under its Duty to Cooperate to work with Local Planning authorities on "strategic priorities" which should be properly coordinated and clearly reflected in individual Local Plans.
The Councils latest response to this obligation is to send out a letter questionnaire to all neighbouring authorities. NPPF duty to cooperate requires a greater robust approach to enable Rother DC to prove it can indeed meet its objectively assessed development needs and thus prove its Plan is sound.

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

MOD2.2 The inserted text is welcomed but we see no necessity for the final sentence which makes reference to the South East Plan which is no longer applicable, by referencing it as a document only causes unnecessary confusion. Future infrastructure investment should now be based on the new LocalPlan. The final sentence should be deleted.

MOD 7.1 The new reference to the 4,800 dwellings as set out in the South East Plan is unnecessary.

MOD 7.5 The increased supply to at least 5,700 is to be welcomed.

MOD-7.6 We seek to alter the proposed paragraph 7.30 as follows: (changes in CAPS)

7.30 This growth is justified primarily in terms of COMPLYING WITH THE NPPF TO INCREASE HOUSING SUPPLY AND contributing to the projected demand for new homes, as well as in meeting the local need for housing and the need to support economic regeneration. The possibility of further opportunities for sustainable housing (as well as employment) development arising over time is A DISTINCT POSSIBILITY; hence the requirement is expressed as a minimum QUANTUM for the purposes of plan making. These will be further assessed as part of site allocations/neighbourhood planning processes.

MOD 7.9 With regard to the additional sentence; please consider adding 'modest' prior to 'potential' and insert 'detailed' prior to 'assessment'.

MOD 7.10 Please delete the additional modification as it is not necessary.

MOD 7.12 The increased housing provision figures at 5,700 are welcome as a minimum provision.

MOD 7.13 After the words 'sites are assessed' please add 'or subject to planning applications'.

MOD 7.14 Figure 8; the increase for the Villages to have 1,670 dwellings is welcomed.

MOD 7.18. At the proposed paragraph 7.57 the Council is taking windfalls into account. In terms of making an assessment of the 5 year land supply, is the Council making an allowance for the non­ implementation of planning permissions. We suggest that a percentage figure based on evidence be used in order to have a fair methodology.

MOD 8.5. Add on to the modification 'and that this delivery rate will be monitored on an annual basis'.

MOD 8.7. Delete 'support' or 'deliver' and add on to the final sentence 'or to allocate fresh housing land via planning permissions or alternative allocations'.

MOD 8.10. Delete 'marginal but critical' for 'strategically important'.

MOD 9.1 We object to the inclusion of the modification and seek that it be deleted.

MOD 12.4. We support the additional dwelling supply.

MOD 12.6. After 'Neighbourhood Plans', please add on 'or newly approved planning permissions'

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.