Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21302

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils Sustainability Appraisal 2013(SA)only considers two options; one for its housing figure of 5700; and the second for the SHMA figure of 6180. It does not consider the third option of attempting to meet some of Hastings housing needs.

It fails to do so because it lacks evidence in the form of a Landscape Capacity Assessment. This lack of information also impairs its ability to meet SHMA needs.

At present we have a Council unwilling to meet its own housing needs nor carryout the appropriate assessments that could enable it to contribute towards meeting its Strategic Housing Market needs.

Full text:

The Councils Sustainability Appraisal 2013(SA)only considers two options; one for its housing figure of 5700; and the second for the SHMA figure of 6180. It does not consider the third option of attempting to meet some of Hasting housing needs.

It fails to do so because it lacks the appropriate evidence in the form of a Landscape Capacity Assessment which could highlight capacity at sustainable market towns within the District. The lack of this information also impairs its robust assessment of its ability to meet its own SHMA needs.

The SA 2013 report considers two options. Option B3 figure of 5700 dwellings(335pa)and Option B4 figure of 6180 dwellings(363)which represents its current SHMA.

The additional figure of 480(28pa)required to meet the SHMA is however considered to have greater impact on the District over the plan period. However when you compare this against the Scale of Growth proposed in the Deposit Plan(SA 2008)under Option 2 (SE Plan figure of 280pa+ 25% = 350 pa)it suggest a significant impact compared to the Option B(SA 2013)figure of 335pa. Indeed the current SA suggests at the level of 335 pa many of the sustainable objectives are neutral yet in 2008 a figure of 350 pa was found to have a significant impact hence it was rejected. The SHMA 2013 report suggests a figure of 363 dwellings pa needed as a minimum to meet its housing needs. In reality this is only 480 dwellings(28pa)more than the Council now feel is sustainable. Much of the commentary made between Option B3 and B4 in the 2013 SA is exactly the same implying little if any significant change between these Options. What is needed is an assessment which attempts to define the "tipping point" in landscape capacity where housing numbers would have a " significant and demonstrable harm that would outweigh the benefits" when measured against the 3 dimensions to sustainable development: economic, social and environmental.

The insert paragraph 7.22 claims that it recognises that a higher housing figure is achievable largely by giving greater weight to meeting its housing objectives. Yet also claims that to deliver the additional 480 dwellings needed to meet its objectively assessed housing needs would be unsustainable. However the evidence for this claim is not available in particular the capacity for settlements in the AONB to contribute further towards meeting this need. This is an important component of the Councils evidence base when you appreciate the Council consider further options to expand Bexhill limited in housing market terms and has transport capacity constraints.

At present we have a Council unwilling to meet its own housing needs nor carryout the appropriate assessments that could enable it to contribute towards meeting its Strategic Housing Market needs.

Further supporting evidence to support this representation can be accessed here: 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