AM34

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Object

Schedule of Additional Modifications

Representation ID: 24650

Received: 10/09/2019

Respondent: SeaChange Sussex

Representation:

The figures within the DASA should be described as illustrative.

Figure 15 should not be prescriptive. In particular policy BEX1 should not use figure 15 to incorporate requirements such as the extensive landscape buffers shown on the figure when the LPA acknowledged that it has undertaken no assessment of the impact of such extensive requirement on the deliverability of the employment land requirements of the district.

The plan should be modified to confirm that landscape buffers will be considered appropriate where they conform to statutory guidance and that viability and deliverability will be taken into account when considering the design of landscape buffers.

We would also suggest that any obligations placed upon employment allocations are reviewed once the ongoing review of demand has been completed and tested to ensure that the scale of obligations and policy burdens does not threaten development viability in accordance with NPPF (2012) paragraph 173.

Full text:

While we recognise that this modification is justified in relation to reason provided the approach taken, we would question the soundness of the reason, as highlighted by Mr Pyrah and Ms Watters to the inspector during the Examination Hearings. The figures within the DASA should be described as illustrative.

Figure 15 should not be prescriptive. In particular policy BEX1 should not use figure 15 to incorporate requirements such as the extensive landscape buffers shown on the figure when the LPA acknowledged that it has undertaken no assessment of the impact of such extensive requirement on the deliverability of the employment land requirements of the district. The severe shortage of such space across the district that has been brought to light by figures recently presented by the Rother District Council consultants which would suggest a supply of less than 48 days industrial space is currently available within the district.

The plan should be modified to confirm that landscape buffers will be considered appropriate where they conform to statutory guidance and that viability and deliverability will be taken into account when considering the design of landscape buffers. This would ensure to ensure that the plan is compliant with NPPF (2012) Paragraph 160 in term of the obligation to work closely with the business community, to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability.

We would also suggest that any obligations placed upon employment allocations are reviewed once the ongoing review of demand has been completed and tested to ensure that the scale of obligations and policy burdens does not threaten development viability in accordance with NPPF (2012) paragraph 173. This is an exercise that has not been undertaken within the preparation of this plan. The district has ongoing issues with employment space viability, and it must ensure the delivery of such space in accordance with NPPF (2012) paragraph 154.