The Policy will result in an under-supply of allocated housing land in the District over the Core Strategy period and has too much reliance on the delivery of the Bexhill-Hastings bypass which was exactly the same position facing the District Council during their Local Plan process. The policy does not meet regional guidance and is unsound on that basis.

The spatial distribution policy does not appear to meet the need for providing a 5 year land supply + 20% as defined in the emerging NPPF.

The spatial policy places too much emphasis on the 'traditional' centres for development where there are long-standing development constraints.

Whilst not entirely ruled out, the Core Strategy has not taken the clear opportunity to support a strategic allocation on the north-western side of Hastings. Although Hastings Borough Council favoured this strategic approach in its earlier Core Strategy, they have not pursued this in their submission CS. The constraints raised against this can be mitigated and therefore it is considered that the District Council have been too readily dismissive of this clear opportunity.

The spatial strategy policy should include a strategic housing allocation on land at Breadsell Lane certainly encompassing the northern part of that area of land. The approach should be carried out in conjunction with Hastings Borough Council because of the mutual authority interests by way of an area action plan. Such an approach would be likely to ensure the provision of sustainable and properly planned short, medium and long development including homes, jobs, community provision and infrastructure in a location that has a strong need for improvement in these areas. A positive allocation on this basis will add further weight to support the need for the Bexhill-Hastings bypass to be delivered.