Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21549

Received: 27/09/2013

Respondent: Mr & Miss Parker

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council should clearly distinguish between the objectively assessed needs of the local population and the regional housing need, in accordance with the consultant's advice and under the NPPF.

The SA has rejected the application by Hastings Borough Council to develop housing in Rother to offset Hastings' shortfall. However, this 6100 figure nor the modified housing number of 5700 is supported by the objectively assessed evidence of Rother's housing need based on its social and economic factors.

Full text:

The NPPF requires the Council to provide for the objectively assessed housing needs of the local population and does not require the Council to make provision for regional housing needs (paragraph 159). The Council should clearly distinguish between the objectively assessed needs of the local population and the regional housing need, in accordance with the consultant's independent advice and the nature of the Council's obligation under the NPPF. Neither the modification nor the decision-making process leading to the modification appears to make a distinction.

The Sustainability Appraisal presented to the Council in support of the modified housing numbers on 8 July 2013 states the Council has rejected the application by Hastings Borough Council to develop housing in Rother to offset Hastings' shortfall (paragraph 3.4.7). The Council's decision to increase housing numbers to 5700 was therefore based on the assumption that 6100 additional dwellings were required by Rother District to meet its own objective assessed housing needs and this figure was unrelated to Hastings' shortfall. However, neither this 6100 figure nor the modified housing number of 5700 is supported by the objectively assessed evidence of Rother's housing need based on its social and economic factors.

The summary of the consultant's findings in the Sustainability Appraisal is also unclear and advice material to the decision-making process was omitted from the report and not followed.

The modified net additional district housing figure of 5700 is therefore unjustified and the decision-making process was not legally compliant.

There is a consequential objection to all modifications which are related to the modified district-wide housing figure which are modifications: MOD 7.5, 7.6, 7.7, 7.12, 7.13, 7.14, 7.15, 7.16, 7.18, A3.1, as well as the settlement specific number modifications and in particular the villages related number modifications MODs: 12.1, 12.4 and 12.5.