Paragraph 5.36
We do not agree that Option 2 - 'Service Centres' is the most appropriate distribution of development for the area.

The figure of 3400 dwellings for Bexhill proposed under Option 2 is based on the assumption that the Bexhill to Hastings Link Road will go ahead as set out in the 2008 Regional Transport Programme, with work commencing in 2009/10 and finishing in 2012/13.

Paragraph 5.79 recognises that this significant growth for Bexhill is reliant upon the construction of this road. However, there is currently considerable uncertainty regarding its timing and implementation.

The cost of the scheme has more than doubled since 2004 and the Regional Transport Board is in the process of considering whether it can continue to support the scheme given the increased cost. Even if it does, it is doubtful that the road will be provided on the proposed timetable.

Paragraph 5.84 sets out the implications of any delay in the opening of the Link Road on the number of houses built.

It states that a three year delay would result in 500 fewer houses.

Paragraph 5.86 sets out a number of options or contingencies in the event of delay or cancellation of the Link Road.

We support the proposal that additional sites in other towns and villages would be allocated to maintain development levels and the recognition (Paragraph 5.87) that there may be a margin for more development than currently planned at Battle.

However the inference is that the Core Strategy would be amended after its adoption to address any shortfall. This would presumably need to be done through a review of the Core Strategy and the Site Allocations DPD which would require a new round of consultation and examination.

An alternative would be to adopt the approach which has been used by other authorities and which directly addresses the issue of infrastructure uncertainty and that is the concept of 'reserve sites' (see East Hampshire District Council et al).

We believe infrastructure delay needs to be considered now and additional sites identified that could be reserved in the event of a delay because it is highly likely that the situation on the Link Road will become clear between now and the public examination of the Core Strategy.

If a delay (or cancellation) was clear at that stage the Core Strategy may well fail to meet the Council's obligation to provide the necessary land supply upon the adoption and thus run the real risk that it is found to be unsound. The Inspector would not be able to accept an early review of the CS/Site Allocatons as an acceptable contingency plan.

The higher level of housing required to cover the possibility of infrastructure delay would not be contrary to Government aims or objectives.

Government has made it clear that it wishes to see a step change in housing delivery and that the housing figures in the draft South East Plan are considered to be minima rather than maxima not to be exceeded.

An increase of c 500 dwellings at the other towns or villages, either allocated/phased or as 'reserve sites' would cover any likely potential delay to the Link Road and associated development at Bexhill.

The proposal that such an allocation or allocations should include prioritising the higher order service centres such as Battle is supported.

In summary
The strategy proposed is considered to be unsound as it does not include any contingency plans which would address the issue of delayed (or cancelled)infrastructure.

The Council should include specific contingency plans that the Inspector can examine for soundness when considering the CS.

It is suggested that the Council consider additional allocations of c. 500 dwellings either as phased provision or as reserve sites.