The proposed text for the new paragraph 7.10 quotes selectively, and omits references to the requirement in paragraph 47 of the NPPF to meet housing needs within the housing market area. It is clear that the Council regard the housing market area as containing both the Rother and Hastings local authority areas, given the decision of these authorities to undertake a joint SHMA, and the reference later in the proposed paragraph to the shortfall in capacity in Hastings Borough. However, as drafted the paragraph doesn't make it clear why the shortfall in capacity in Hastings Borough is relevant, as it makes no reference to the need for housing in Hastings, or to the level of housing which can be delivered within that Borough.

This paragraph should be amended to make clear reference to the housing market area. It should also specify the level of housing required in the housing market area, and the level which the two authorities' emerging Local Plans are set to deliver.