It is proposed in paragraph 8.52 that the objectively assessed housing need for Bexhill (182 dwellings per annum) will place an added weight on initiatives to stimulate job growth.

'It is recognised that this [182 dwellings per annum] is well and above the average house building rate over the last 20 years and will place added weight on initiatives to stimulate job growth. Hence particular emphasis will be given to schemes that bring significant employment land.'

This is a conflation of the separate issues of job creation and meeting the identified housing need. The Council's housing requirement has been assessed as the amount of housing that can sustainably be accommodated in the district having regard to economic growth, demographic projections and household formation, in accordance with paragraph 47 of the National Planning Policy Framework (the Framework). The appropriateness of the Council's housing target for the district and Bexhill has already been assessed in the light of economic factors.

There can be no justification to either require schemes to, or favour schemes that 'bring significant employment land' over those that deliver the housing requirement identified for the district generally and Bexhill specifically. The intent of the Council not to give proper consideration to residential led or single use residential schemes that deliver the identified housing need set out in the Core Strategy is entirely contrary to the provisions of paragraph 47 of the Framework which seeks 'To boost significantly the supply of housing'.

Whilst this reference is only made in the supporting text at paragraph 8.52, it signals the Council's intention to seek employment floorspace as part of residential schemes necessary to deliver identified housing need, regardless of deliverability and viability. This modification has the propensity to delay the delivery of residential sites identified in and around Bexhill as suitable to meet the housing requirement, either in the absence of the Council's support or as a result of the employment element of a scheme being undeliverable.

To this end, the proposed modification signals a potential failure by the Council to deliver 182 dwellings per annum and also fail to produce a supply of specific deliverable sites as required by paragraph 47 of the Framework.