Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21300

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Rother need to meet its objectively assessed development needs and some of those identified for Hastings. It needs to update its landscape evidence to test its capacity to meet these needs and test these against the SHLAA and undertake a fresh Sustainability Appraisal. Until this process is complete the Plan will be unsound.

Full text:

At present the best estimate for housing demand, implied from trend -based household projections, shows a requirement for 9979 dwellings in the period 2011-2028 for Rother. The equivalent figure for Hasting Council is 7493(What House Where. Rother DC SHMA 2013 suggest a figure of 6178 dwellings for its District and 6863 figure for Hasting. Assuming for the moment the Councils figures are correct they have an obligation to meet these housing needs within the administrative boundaries unless they can prove this need is being met by an adjoining authority.

A further consideration is that Hasting BC confirms it cannot meet all its assessed housing needs in its Borough. Based upon its Proposed Modifications it will fall short by some 3200 dwellings. Hasting have indeed asked Rother whether they could accommodate "some or all its current need". Rother has rejected this request based on environmental and infrastructure constraints. However, the option to meet some of the Hasting housing need has not been tested. As a fundamental component of the landscape character of a large part of Rother is that over 80% of the District falls within an AONB. It would therefore seem crucial in any assessment of housing capacity that a robust landscape assessment of all potential SHLAA sites is undertaken to judge the balance between its obligation to give "significant weight to support economic growth"(par 19 NPPF)and to meet its development needs(para 47)set against the "great weight" given to conserve the AONB(para 115). Failure by the Council to undertake a review of its landscape assessment makes the Council's claim that there is no capacity to either meet its own objectively assessed housing need or contribute to those of Hastings need unsound.

It is important to recognise that both Hasting BC and Rother DC have for some time acknowledged that these two authorities operate as a well established "Housing Market Area". It has not attempted to extend its SHMA to other adjoining authorities. It therefore falls upon these two authorities to make ever effort to meet is objectively assessed needs within its SHMA.

Further supporting evidence to this representations:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567