Object

Proposed Submission Core Strategy

Representation ID: 21006

Received: 29/09/2011

Respondent: Messrs. R. & J.C. Stapylton-Smith

Agent: DHA Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy OSS1 seeks overall housing provision of 3,700-4,100 net dwellings. This is lower than the South East Plan.

The intention to support rural service centres such as Ticehurst through the proposed development distribution is supported.

However, the draft National Planning Policy Framework requires the identification and maintenence a rolling 5-year housing supply, including an additional 20% allowance. Whilst it is recognised the NPPF is draft, it is a material consideration. The Core Strategy does not indicate whether reduced housing targets have an allowance.

Policy OSS1 is not justified as it fails to consider current Central Government approaches to delivering housing.

Full text:

Policy OSS1 seeks an overall housing provision of between 3,700 and 4,100 net dwellings during the plan period. This is much lower than the 5,600 dwellings required by the South East Plan and it is explained in detail at paragraphs 7.23 - 7.25 that the main reasons for setting a lower housing target are:
*
The South East Plan housing targets for Rother assumed the Bexhill to Hastings Link Road would be built by this point but it now transpires that the link road can not even start being built until the end of 2014. The plan targets are therefore not sustainable in light of delays in this major infrastructure route.
*
Lower national economic growth forecasts mean that the increases in build rates advocated by the South East Plan are unlikely to be fulfilled when comparing them with actual housbuilding rates over the period 1991-2011.
*
The existence of significant Environmental designations over large parts of the district which act to constrain the level of development successfully achievable.
2.1.2
The Policy also provides a commitment to allow development to facilitate the limited growth of villages that contain a range of services, which contributes to supporting vibrant, mixed rural communities and is compatible with the character and setting of the village.
2.1.3
The clear intention to support the role of rural service centres such as Ticehurst through the proposed development distribution strategy as confirmed at paragraph 7.43 is supported.
2.1.4
However, the recently published draft National Planning Policy Framework Requires Local Authorities to identify and maintain a rolling supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements. That supply should also include an additional allowance of at least 20% to ensure choice and competition in the market for land. Whilst it is recognised that the NPPF is only in draft form at present, it is a material consideration and indicates the way in which Central Government intends Local Planning Authorities to approach housing delivery. The Core Strategy Document does not indicate whether the reduced housing targets already have a built in allowance, but it is considered that the policy should demonstrate clearly that an allowance has been built in, which assuming this is not the case in the submission document, would result in a higher overall housing provision for the district.
2.1.5
It is therefore considered that Policy OSS1 is not justified as it fails to take into account current Central Government approach to providing a deliverable housing supply. The policy should be amended to clearly demonstrate a built in allowance and if necessary raise projected housing provision across the district accordingly.