MOD 7.11

It is inappropriate to limit large sustainable settlements such as Robertsbridge to meet only "local needs". This approach is contrary to NPPF which requires Plans to be positively prepared to meet its objectively assessed housing and employment needs. This should correctly include all sustainable settlements capable of helping to meet this need.

The additional sentence is supported because it acknowledges that the villages, especially the larger Rural Service Centres (such as Robertsbridge), have a greater capacity to absorb additional development than the plan has previously recognised.

Mod 7.11: MAIN MODIFICATION NOT LEGALLY COMPLIANT:
The sustainabiliy appraisal for the rural areas does not provide enough detail to state that building in any village is actually sustainable.

MAIN MODIFICATION NOT SOUND:
The number of houses being proposed for villages such as Robertsbridge have not been proven to be sustainable, in fact, on many counts, the sustainability report for the rural areas would indicate that most development is unsustainable.
No sustainability report is available for each village to make a better judgement. Without this information, RDC cannot be justified is stating that they are maximising the contribution of the villages, in fact they would be over maximising. In Robertsbridge, for example, this level of building will change the rural nature and charm of the village, resulting in the loss of historic buildings and settings, and thus is not in accordance with policy RA1 (1). No consultation has taken place with the villagers on this matter.

Retain original paragraph and do not use insertion.

As discussed previously in other modifications,7.1 states "the housing provisions seek to maximise the contribution that the villages can make to sustainable growth prejudicing their individual character and amenities, as well as those of their shared, for the most part High AONB, landscape setting".

Housing will not contribute to sustainable growth.This statement is false under NPPF guidance point 15 which reads "with clear policies that will guide how the presumption should be applied locally". This statement should be reviewed as the evidence suggested in DTZ's report shows the current imbalance between business and housing projections. Only businesses and employment can contribute in this regard and remains a guide for housing numbers needed. There has been insufficient need for this area for new business growth and clearly shows the lack of demand which the modification seeks to improve. This section should be deleted as it does not follow NPPF policy.

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 additional text to this paragraph is unsound, is an isolated modification to the Local Plan Strategy for villages and should be deleted.

Firstly it fails to comply with NPPF paragraph 54 which states the planning of housing development in the rural areas should be reflective of local needs.

Secondly, it is an isolated modification to the Strategy. It fails to comply with the unmodified Strategy policy and also the unmodified supporting text. MOD 7.11 would consequently produce a Plan which is internally inconsistent and therefore unsound.

Thirdly, the paragraph itself in its modified form is internally incoherent. The original text is compliant with the NPPF by providing for limited growth in the villages reflective of individual settlement needs. This is diametrically opposed to the proposed text insertion to maximise growth in the villages, for reasons unrelated to local needs, to contribute to the modified district-wide unit figure of 5700.

We support the amendment emphasising absolutely the words from 'without prejudicing...' These words we feel should underpin any subsequent discussion about housing numbers and we believe that they are not so respected in subsequent paragraphs of the draft plan.