Main Modifications to the Proposed Submission Core Strategy
Representation ID: 21447
Respondent: Mr Alan Miskin
Agent: DMH Stallard LLP
In general we support the policy as it positively seeks to meet the development needs of the District as it is broadly in line with the housing requirements set out within the SHMA.
However, we bear in mind that the allocation of land at Breadsell Farm could help both Rother District Council and Hastings Borough Council both meet their development needs entirely and as such there should be a duty to cooperate between the two District's and with other key stakeholders to meet this end, particulary as Breadsell Farm is the only potential strategic site outside of the AONB.
We wish to support the proposed amendments to the Rother District Council Submission Core Strategy in relation to MOD 7.12. It is positive that the level of housing provision has been increased (across the District as a whole and in relation to the Hastings Fringe), it is considered that this will help to ensure that the housing needs of the District will be met, as well as provide a level of housing which could aid economic growth. The level of housing now put forward is in line with the South East Plan targets, as well as the targets set by the updated Strategic Housing Market Assessment (SHMA). The SHMA (June 2013) concludes that 6,178 dwellings should be provided within Rother between the period 2011-2028, at an average of 363 dwellings per annum. As such, whilst the proposed amendments do not put forward the level of housing proposed by the SHMA, making for provision of just 5,700 dwellings (478 less than that recommended by the SHMA) it does represent a significant and more appropriate level of provision than previously drafted. With regards the level of housing now required by the Core Strategy our view is that it would help meet the development needs of the area in accordance with the National Planning Policy Framework (NPPF) and therefore would be sound.
In supporting the Policy as now drafted we also make the following comments. The Council argue that the full level of housing provision recommended by the SHMA could not be delivered due to environmental restrictions within the District which relate predominantly to the High Weald Area of Natural Beauty. A significant part of both Hastings and Rother are restricted by the AONB which limits the potential for large housing developments within the countryside. It has previously been proposed that Land at Breadsell Farm (which includes land within Hastings) could provide the only suitable option for a sustainable urban extension within these Districts. Whilst it is recognised that the wider area of land at Breadsell Farm has not been included within Hastings submission Core Strategy (due to a current Natural England objection which relates to an adjacent SSSI) it is considered that in the interests of cooperation and in order to ensure that sufficient housing is provided within the Strategic Housing Area, a more positive approach to Land at Breadsell Farm should be taken in order that it could provide a significant level of housing for both Rother and Hastings, allowing both authorities (who are currently proposing a level of housing development below what is considered to be required) to provide the full amount of housing recommended by the SHMA. In accordance with the Duty to Cooperate allocating land at Breadsell Farm would help to ensure that both Local Planning Authorities are able to meet the housing needs for this strategic area and would help to ensure that the Core Strategy can be found sound.