Land at Sandhurst Lane, Bexhill on Sea, called Pond Field - This land should be included for residential development

A map was included as part of the submission and can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=31119

National Policy Context and Housing requirements.
Paragraph 119 of the NPPF 2018 states that 'Local planning authorities, and other plan making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs' This requirement follows from the NPPF 2012 which sought to maximise development potential.
The most recent 5 year housing land supply position for Rother (set out by the Local Plan Annual Monitoring Report April 2018) states that RDC have a land supply of 3.44 years in place. The Council accepts that the under-delivery against housing requirements amounts to a 'persistent under-delivery of housing' hence, a 20% buffer should and in line with paragraph 47 of the NPPF 2012 has been applied to the Council's requirement.
Local Housing Needs
The Council consider that through the implementation of sites now approved and allocated within the DaSA Plan the trajectory for development will ensure that future completions will supplement the persistent under delivery when sites come forward. However, this takes no account of external changes to demographics or policies in the future and whilst there is now the necessity to review a Local Plan every five years it is forwarded that the site should be included within the current Plan submission.
The last full assessment of housing requirements is set out in the Hastings and Rother Strategic Housing Market Assessment: Housing Needs Assessment dated June 2013. This informed the subsequent Core Strategy Local Plan requirement to deliver 'at least 5, 700 new homes' over the 17 year plan period.
We argue that given that as the figures adopted originally by Rother within the Core Strategy Local Plan for housing provision were (and still are) expressed as an "at least' number, it is incumbent on the authorities to be proactive in seeking to identify opportunities for additional housing development and this should remain the case for Rother.
To further emphasize the need for greater provision we are also aware that the Council's Local Plan Monitoring Report April 2018 confirms that they have not met their annual housing supply requirements and therefore have taken account that significant weight be attributed to the benefits of new housing.
In setting out the reasoning for the housing provision in forthcoming years Paragraph 2.36 of
the Monitoring Report April 2018 confirms that 'Therefore, the Council resolved that pending the DaSA Local Plan and Neighbourhood Plans, sites that accord with the Core Strategy's overall development strategy and are suitable, deliverable and otherwise contribute to sustainable development, including circumstances where they are not within a development boundary, be considered favourabl '(Our emphasis) As such we welcome that this admission that housing sites that come forward should continue to be viewed favourably is acknowledged within the reasoning behind the 'Overview' Policy which refers to housing targets and provision - Policy OVE1: Housing supply and delivery pending plans.
'In view of the fact that the annualised housing requirement has not been achieved to date and that housing delivery is likely to not "catch up" on present projections, it is considered appropriate to not only have a margin of over-provision, particularly in Bexhill where there is a high reliance on a strategic site, but also to avoid unduly deferring the identification of suitable sites and to ensure that planning permissions continue to come forward in a timely manner.'
The pre-amble confirms that the historic under-provision is noted and that other sites brought forward should also be considered favourably subject to complying with other Policies. With regard to housing in settlements the secondary element of Policy OVE1 states that:-
.... planning applications will be favourably considered for development proposals in those settlements where:
(i) they contribute to meeting the housing target for that settlement and accord with the relevant spatial strategy; and
(ii) the site and development proposals are otherwise suitable having regard to other
relevant policies of the Core Strategy, including the considerations in OSS2 and OSS3, and of this Plan.
We assert that the land at Sandhurst Lane as shown in this documentation would comply with the principles outlined within emerging Policy OVE1 and would offer an opportunity to assist in exceed the provision requirements of the current Plan submission following the documented under provision of recent years.