Part (i)

In terms of calculating the annual housing requirements and 5 year housing land supply, the housing figure would be better stated as a single figure, rather than as a range. In paragraph 7.29 of the Proposed Submission Core Strategy (PSCS), the mid-point of 3,900 dwellings (average 229 dwellings per year - dpy) is referred to for "monitoring purposes", but it is unclear why a specific figure should not be referred to in the policy itself rather than the 3,700 - 4,100 range put forward. Indeed, in policy terms it is unclear why the higher level of additional housing (4,100 dwellings) should not be stated as the target figure in the policy rather than any notional mid-point in the range currently put forward by the Council. If this objection were to be accepted, then other parts of the Plan would also need to be amended.

As regards the housing numbers put forward, insufficient justification has been provided for departing on the South East (SE) Plan housing requirement of 280 dpy, i.e. the equivalent of 4,260 dwellings during the 17 year plan period between April 2011 - March 2008. The South East Plan remains part of the Statutory Development Plan.

By comparison, the PSCS puts forward the provision of 3,700 - 4,100 dwellings during the 17 year period between April 2011 and March 2028 (equal to 218 - 241 dpy) with a 3,900 dwelling mid-point (equal to 229 dph - paragraph 7.29). At the lower end of the range (218 dph), this would be a 22% reduction in housing supply compared with the SE Plan target and the mid range (229 dph) would represent a 19% reduction. Even if the top end of the range were to be achieved (241 dph), this would represent a 14% reduction in the SE Plan target.

Assuming (as the PSCS does) that the Bexhill - Hastings Link Road Scheme will be constructed within the Plan period, there appears to be no sound justification for a 14% - 22% reduction in future housing land supply in the District. The SE Plan provides a robust and tested housing requirement for the District and the PSCS should therefore, be amended to take account of this.

Other neighbouring East Sussex Authorities in producing their PSCS DPD's are also putting forward similar reasons for a reduction in the housing requirement compared to the housing targets set out in the SE Plan. Environmental, infrastructure and other reasons are also claimed in neighbouring districts for reducing the housing requirements, but unless SE Plan targets are met, there will be an increasing shortfall of future housing supply in the region as a whole.

Part (iii)

The policy contains no cross-reference to Policy OSS2 (Bexhill to Hastings Link Road and Development) and therefore, in terms of spatial distribution, Policy OSS1 provides no contingency arrangement should the Bexhill to Hastings link road scheme be delayed or shelved as a consequence of the Government's spending review. If the road scheme does not take place, then either the housing requirements figure would need to be amended or alternatively, the suggested distribution of housing in Figure 8 on page 35 of the PSCS would need to be amended to provide for potentially increased housing allocations in other areas of the District outside Bexhill.