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STEPS TOWARDS AN AGREED STATEMENT OF FACTS
                                                      And stipulations

               5.2 Documents Supporting the Application (Continued)

               The Design and Access Statement includes the following illustrations;



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               Figure 6: The ancient woodland

               The East Sussex. Communities, Economy and Transport Environment Team (In a letter to
               MSDC dated 20  June 2018) has made it clear that use of the ancient woodland in the way
                               th
               proposed is not acceptable. Besides that, there are a steep drops within the woodland and a
               SUDS pool nearby. Both make the area dangerous for young children and suggest it should be
               secured, rather that used as proposed in the application.

               5.3   Town Planning Statement: Frank Taylor
               This critical document, by a leading town planning expert, was relied on by the architects in
               the Design and Access Statement.  It initiated the “starkly urban” label for the existing site and
               the justification for the “urbs in rure” design.

                        The circular and unfitting classification of the existing site as “starkly urban” is relied
                        on to justify an urban design and over-development.

               The report also gives a misleading impression of compliance with the 2016 pre-application
               discussions with MSDD and how they have been addressed (see page 7 Table 3).

               The Statement continues:

               •  “The WH Life Improvement Centre does not form part of this application;

               •  It is not necessary to include the highway access in the application:

               •  The general character of this part of the site is starkly urban. The current, if unsightly, built
                   form does show how it is possible to have an urban character of development here
                   without affecting its wider semi-rural setting. …[with] Urbs in rure it is therefore possible
                   to achieve the most effective development of the site;

               •  A contemporary design is the best way to realise the potential of the site, including its
                   capacity to produce affordable housing;

               •  The neighbourhood plan does not specify the capacity of the site….Instead quoting an
                   approximate capacity of 50+ which is indicative of an acceptance that capacity is
                   substantial and greater numbers of units can be produced here subject to design:
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