There is a fundamental error in suggesting that the proposed development of c 160 residential dwellings on the land off Spindlewood Drive is necessary in order for RDC to meet its target of 3700 dwellings in the Bexhill area by 2028.

RDC's Housing Land Supply and Housing Trajectory document dated 1 April 2018, indicates in Appendix 7 that given the draft DaSA proposals, the Bexhill residual target of 720 will be exceeded by 17 dwellings.

However, the provision of 737 dwellings only includes a projection of 284 small site windfall dwellings over the period 1/4/2018 - 31/3/2028 (para 2.39 Figure 10). Given that this figure of 284 is exactly the same as shown in Para 2.31 Figure 8 for the period 1/4/2018-31/3/2023 for small site permissions, this infers that RDC do not expect ANY further small site permissions after 31/3/2023 (presumably because of the effects of DaSA being implemented).

This is surely disingenuous, false and illogical..

Developers do not stop developing small sites because of a political initiative such as DaSA. They will continue to seek out development opportunities and implement them.
It would seem totally appropriate therefore to assume that small site permissions will continue at their historic average of 58 (as per Figure 3 Para 2.5) for the period 2023 - 2028. Even if the reduced average assumed by RDC of 42 per annum were assumed, this would increase the developable sites (10 year supply) in Figure 10 for small site permissions from 284 to 494 (ie an increase of 210 dwelling).
Given that the majority of small site permissions take place in the Bexhill area, this implies a considerable overshoot of dwellings required for the Bexhill area of 3700.

Similarly, RDC are assuming no large site windfalls (6+ dwellings) will occur once DaSA has been approved and implemented (see para 2.4 of RDC's Housing Land Supply and Housing Trajectory document dated 1 April 2018).
This is also disingenuous and illogical. Smaller developers will continue to seek out opportunities to develop such sites throughout the period 2023-2028 and some sort of allowance should thus be included even if at a lower rate than has been seen in the recent past. A figure of at least 20 such dwellings should be included in RDC's future projections for the period 2023-2028 giving an increased projection of 100 extra dwellings.

Consequently, the need to develop the Spindlewood site is rendered redundant and should not be considered given the highly sensitive ecological features of this site being so close to the Pevensey Levels with potential serious detrimental effects to this RAMSAR, SSSI and SAC site and contrary to the Habitats Regulations.

There are far more preferable and appropriate sites throughout the Bexhill area as already identified in the DaSA document that have little or no potential prejudicial ecological impact.