Taylor Wimpey South East (TWSE) has land interests at "Land at Blackfriars, Battle" which is allocated for mixed use development under Saved Local Plan Policy BT2.

The DaSa reviews site allocations from the existing Local Plan and proposes new site allocations. However, the DaSa only reviews existing Local Plan site allocations/proposes new site allocations within settlements that are not subject to a Neighbourhood Plan Development Order. In these areas, it is assumed that sites will be allocated within the Neighbourhood Plans themselves.

Chapter 5 of the DaSa states:

given the need to be able to demonstrate that the DaSA and neighbourhood plans will together provide sufficient sites to meet the Core Strategy's requirements for housing and employment land, all the plans need to be in place at approximately the same time. Indeed, in view of the current pressure on housing land supply, it is vital for all communities to have plans in place as soon as practicable.

The Council will continue to support the efficient preparation of neighbourhood plans and encourage the early development of sustainable and deliverable sites in order to help contribute to both local and the District-wide housing land supply. It is not clear how RDC intends to ensure that Neighbourhood Plans are adopted at approximately the same time as the DaSa is adopted.

Whilst we acknowledge that Neighbourhood Plans will play an important role in allocating housing sites for development, and their purpose is to allow the local community to play an active role in allocating sites for development, we are concerned that, should Neighbourhood Plans not be approved prior to or alongside
the adoption of the DaSa, a "policy vacuum" will occur.

The absence of any housing allocation policies for settlements such Battle, which is expected to deliver a significant proportion of RDC's housing requirement (475-500 dwellings), could undermine RDC's ability to meet its Core Strategy housing requirement, and maintain a 5-year housing land supply, in accordance with the National Planning Policy Framework (NPPF). In this regard, it is noted that Battle Town Council does not appear to have progressed its Neighbourhood Plan since the initial Survey and Call For Sites in February 2016.

Further consideration needs to be given to the relationship between the DaSa and Neighbourhood Plans, to ensure effective policies are in place to support the delivery of housing within the plan period.