MOD A3.1

In the amended Appendix 3 Housing :Component of Housing Supply for period 2011 to 2028 the Council have made an allowance of 460 small windfall sites and 65 Rural Exemption Site Allowance giving a total of 525 unidentified sites over the plan period. The Council state that "at least 5700 dwellings" will be delivered over the plan period (yet accept that their housing need is 6180). The only way the minimum target of 5700 could be exceeded is via unidentified sites. Therefore to have around 10% of its minimum housing requirement already identified as windfall/exemption sites suggest that 5700 in reality is not a minimum housing figure as it already includes the only unidentified housing supply component over the 17 year plan period. Where else is any future housing supply likely to come from to exceed 5700 other than unidentified sites?

Replacement Appendix 3 is supported because it reflects the increased overall housing requirement of 'at least' 5,700 additional dwellings for the period 2011 to 2028. Further, Appendix 3 also reflects the increase in the allocation for the villages to 1,670 additional dwellings in the plan period, which is supported.

The plan to increase housing in Bexhill by 850 more properties than was originally allocated is a slight concern. Any proposals for development will need to satisfy the HA in terms of access to the A259 and the traffic impact. Should the core strategy be adopted the Council shall need to work with the HA to mitigate the impact on the A259.

We believe that there may be an error in Appendix 3. The table only shows a current allocation of 14 units at Battle. As far as we are aware there is no planning permission in place for residential development at the Blackfriars site, although we aware that the Council has resolved to approve application RR/2007/1896. The table should be amended to show a current allocation of at least 220 dwellings under the provisions of Policy BT2 of the 2006 Adopted Local Plan

This is one just policy option available within the.SA. It is clear from this table that Robertsbridge is being asked to accommodate far more housing than other villages, thereby impacting on its character. Therefore, there is a clear need for this to be redressed and housing numbers cut and spread across villages in Rother to avoid service centres or hubs becoming more like towns in their character and service supply.

This is against Green Belt policy with NPPF allowing urban sprawl to gather momentum at the expense of quality of life for present residents and ones in the future, impact on their housing value, unnecessary destruction of natural fields and wildlife, a basic tenet of NPPF. Flooding risk and insurance problems remain rife for such villages as Robertsbridge.

No clear financial reward for the villages in question to succumb to greater development and there has been no commitment from businesses to wish to locate in Robertsbridge and local villages.

In summing up, this Modification process, the rationalisation of planning guidance, and the broad and conflicting views expressed within the SA and NPPF and Modifications are extremely alarming.

The process is highly complex, exclusive and not available for all members of the community to access. These have legal repercussions and are against the NPPF with its desire for local inclusion in planning matters. Insufficient consultation with residents who know the area in which they live very well and the current examined documentation loses many important checks and balances to preserve the environment. It may be suggested that the Government's wish to use the construction industry as an economic recovery agent is highly flawed and has serious repercussions for the future. Housing numbers must be in line with business & employment opportunities.

Because of the pressures of increased immigration as part of the free movement of people within the EU, people living much longer than in previous generations, people living singly, the break-up of families, expensive and unsustainable housing costs and rents, lack of investment in public transport in rural areas, pressures to water supply and C02 emissions increasing due to excessive housing development, these modifications are flawed and inconsistent with common sense, safety and the preservation of natural resources for future generations. RDC & central government have not made a substantive claim that can support such excessive housing numbers.