Policy OSS1 Overall Spatial Development Strategy

This policy is considered to be unsound.

National planning policy

Paragraph 53 of Planning Policy Statement 3 'Housing' states that:

'At a local level local planning authorities should set out in Local Development Documents their policies and strategies for delivering the level of housing provision including identifying broad locations and specific sites that will enable a continuous delivery of housing for at least 15 years from the date of adoption, taking into account of the level of housing provision set out in the Regional Spatial Strategy'

Draft National Planning Policy Framework (NPPF) paragraph 107 states:

'The Government's key housing objective is to increase significantly the delivery of new homes. Everyone should have the opportunity to live in high quality, well designed homes, which they can afford, in a community where they want to live.'

Paragraph 109 states that:

'To boost the supply of housing, local planning authorities should use an evidence base to ensure that their local plan meets the full requirements of market and affordable housing in the housing market area'

Paragraph 110 states that:

'The presumption in favour of sustainable development means that Local Plans should be prepared on the basis that objectively assessed development needs should be met, unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this framework'

The South East Plan

Policy H1 'Regional Housing Provision' of the South East Plan requires Rother to deliver an annual average of 280 dwellings per annum, 5,600 dwellings over the plan period 2006-2026.

Table 1 South East Plan Housing Requirement

Sub-Regional Housing Requirement (Sussex coast) Housing Requirement outside sub-requirement (the rest of Rother) Total District Wide Housing Requirement
dpa Total dpa Total dpa Total
Rother 200 4,000 80 1,600 280 5,600

Proposed abolition of the South East Plan

Until the Localism Bill is enacted the South East Plan provides the most up to date and independent review of housing need in the district. Therefore, and in accordance with DCLG advice of 6 July 2010 (Dear Chief Planning Officer Letter), this should be the starting point for preparing the Core Strategy.

Soundness of this Policy

Planning Policy Statement 12 'Local Spatial Planning' (PPS12) which require a Core Strategy to be 'justified, effective and consistent with national policy' regard should therefore be had to how the policies of the Core Strategy meet these tests.

Justified

Paragraph 4.36 of PPS 12 states that justification of a Core Strategy must be founded on a robust and credible evidence base.

Evidence of housing need in Rother District

Policy OSS1 seeks to reduce the Council's housing requirement by 1,900-1,500 dwellings over the plan period from the level of housing required by the South East Plan. Whilst it is important to retain the SEP target as a minimum to be met up to 2026, the evidence base, including the Council's own Strategic Market Housing Assessment (SHMA) identifies household projections to increase to 5,220 by 2026. Further, the Council's Housing Market Assessment 2005 identifies that there is a need for 593 affordable dwellings per annum in Rother. Table 2 summarises the various assessments of Rother's housing need.

Table 2: Housing requirements

SEP Housing Requirement 2006-2026 SHMA Requirement
2006-2026 Housing Market Assessment affordable housing assessment
2006-2026 Rother Draft Submission Core Strategy
2011-2028
dpa Total dpa Total dpa Total dpa total
Rother 280 5,600 261 5,220 593 11,860 137-151 3,700-4,100

In determining the level of housing provision the Council is required to take into account evidence of current and future levels of housing need as well as demand for affordable housing. Arguably given the local need for housing in Rother could justify a higher annualised requirement over and above that set out in the South East Plan.

Paragraph 7.23 of the Draft Submission Core Strategy sets out the Council's justification for planning for a substantially lower housing requirement than identified by the its own evidence base. The following reasons are cited:

* the uncertainty of the delivery of the Bexhill Link Road which will unlock potential for strategic housing allocations and the recent recession;
* the requirement for 280 dwellings per annum is unrealistic given the average rate of delivery of 245 dwellings per annum since 1991;
* the national economic climate and the resulting impact of increasing upon past build rates as unlikely and unduly optimistic; and
* the SEP target will not be met by requisite employment growth.

The reasons that the Council gives for requiring a significantly reduced level of housing is contrary to the findings of its own evidence base. This points to the need to accommodate an additional 5,220 households up to 2026 and its affordable housing need is twice the South East Plan requirement of 5,600 dwellings to 2026. Further, the Council's own evidence of annual completion rates since 1991 (245 dwellings on average) demonstrates that the demand for housing in the district to be significantly greater than for which the Council intends to require.

Whilst there remains uncertainty regarding the delivery of the Bexhill Link Road which is acknowledged, the Council's suggestion that the economic climate should have a bearing on housing provision to 2028 cannot be justified nor can the correlation between housing growth and employment. These matters are considered turn.

The Core Strategy seeks to plan for strategic housing requirement over a 17 year plan period. Over the past 20 years significantly higher completions have been achieved than the Council now proposes, a period which encompasses several economic cycles including a recession. The acute need for affordable housing (referred to in Paragraph 15.10 of the Draft Submission Core Strategy) points to prolonged constrained supply of housing particularly in the northern part of the district.

Section 3 of the Draft Submission Core Strategy identifies two key challenges for the Council, the low economic activity rate, and comparatively low earnings in the district when compared to the South East as a region (paragraph 3.12) and the high house prices across much of the district (paragraph 3.14).

The Council is seeking to address the low economic activity rate by planning for an additional 100,000sqm of employment floorspace up to 2028. Applying the Employment Densities Guide (2nd edition 2010) this could yield c.2,800 new jobs. Yet it simultaneously seeks to reduce housing supply by over 30% the level considered appropriate by both the South East Plan and its own SHMA, this will fail comprehensively to increase supply both in line with its own job creation aspirations or address the acknowledged affordability problems within the district.

The failure of Policy OSS1 to reflect the South East Plan or its own evidence base in respect of housing delivery is not justified. The Council's past 20 years of completion rates, an average of 245 dwellings per annum, the SHMA household projection figure of 5,220 dwellings up to 2026, the acute affordability problems in the district and the Council's economic aspiration to create c.2800 demonstrates that there is greater demand for housing than it proposes to plan for. Therefore in respect of housing provision Policy OSS1 is not justified.

Effective

The proposal to reduce the housing requirement for the district fails to represent the most appropriate strategy when considered against the alternatives namely a higher annualised rate of growth in order to meet demand.

The Council cites the slow down in the economy as a determining factor in the significant reduction in housing requirement. Yet this plan seeks to set the Council's planning strategy for the next 20 years. The Council's own evidence of past completion rates shows peaks and troughs in housing delivery reflecting a natural economic fluctuation, but its annualised average over the past 20 years is significantly higher than the housing requirement proposed. This strategy is therefore insufficiently flexible to accommodate changing circumstances, specifically resurgence in the economy and therefore fails this test of soundness.

Consistency with National Planning Policy

Policy OSS1 fails to comply with either adopted or emerging national planning policy in respect of housing provision. It is acknowledged that there is an expectation that the South East Plan will cease to set the housing provision requirements for Rother. However both adopted and emerging housing policies require a continuous supply of housing to meet identified need.

The Council has undertaken an assessment of its own market and affordable housing need in accordance with emerging and adopted housing policy. Policy OSS1 comprehensively fails to propose a level of housing that will deliver a continuous supply of housing that will meet the Council's own identified need. Further the policy actively seeks to reduce housing delivery based on past completions over a 20 year period. This approach is entirely contrary to emerging national planning policy which sets out to increase housing supply, and in this case no credible evidence has been provided that shows that its own assessment of need cannot be delivered.

Conclusions

Policy OSS1 fails to meet the three tests of soundness set out in PPS12 in respect of housing delivery.

The housing requirement policy fails to reflect either the level of housing need required by the South East Plan or that the Council's own evidence base determines required for both market and affordable housing. Further the proposed level of housing is substantially lower than the level of housing that has been delivered in the district annually since 1991.

The Council has not provided credible justification for reducing its housing requirement by over 30% the level that is judged necessary by the South East Plan, the SHMA and evidence of past completions. The Council cites the recession as a reason for substantially reducing its housing requirement however the Core Strategy seeks to plan for the next 20 years and the housing requirement proposed is not sufficiently flexible to accommodate resurgence in the economy.