Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24587

Received: 07/12/2018

Respondent: Persimmon Homes Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst the motive underpinning policy OVE1 is understood, it is considered that to plan for a shortfall against the Core Strategy requirements will not result in a plan which is positively prepared, justified, effective or consistent with National Policy, and will create a degree of uncertainty as to whether the housing requirements will actually be met. This is particularly relevant given the historic undersupply of housing in Rother District against the Core Strategy requirements.

RDC should therefore seek to plan for the full Core Strategy requirements, with a sufficient overprovision to account for the documented historic undersupply and for sites that do not come forward, or that are developed for a lower amount of units, as per the requirements of the NPPF (2012).

The ethos behind this policy is supported, in that it seeks to ensure the allocation of sites which will help to address the identified need within the District. However technical amendments to the policy are sought, as it would be pertinent for the Council to take the opportunity to meet the residual Core Strategy requirement through the allocation of further sites in the DaSA and not to rely on other provisions in the Plan.

Full text:

7.12. Policy OVE1 states that:

Housing sites sufficient to meet the Core Strategy requirement of at least 5,700 net additional homes over the period to 2028 will be met by allocations and other provisions in this Plan and Neighbourhood Plans.

No phasing restrictions will be imposed on development allocations, other than for site-specific, normally infrastructure, reasons.

Until such time as a Neighbourhood Plan for the relevant settlement with an outstanding Core Strategy housing requirement is in force, 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.

7.13. Whilst the motive underpinning policy OVE1 is understood, it is considered that to plan for a shortfall against the Core Strategy requirements will not result in a plan which is positively prepared, justified, effective or consistent with National Policy, and will create a degree of uncertainty as to whether the housing requirements will actually be met. This is particularly relevant given the historic undersupply of housing in Rother District against the Core Strategy requirements, highlighted by RDC's current five year housing land supply of just 3.44 years' as set out in the April 2018 AMR.

7.14. RDC should therefore be mindful of this and seek to plan for the full Core Strategy requirements for the District, with a sufficient overprovision to account for the documented historic undersupply within the District and for sites that do not come forward, or that are developed for a lower amount of units than initially envisaged, as per the requirements of the NPPF (2012).

7.15. The ethos behind this policy is supported, in that it seeks to ensure the allocation of a number of sites which will help to address the identified need within the District. However technical amendments to the policy are sought, as it would be pertinent for the Council to take the opportunity to meet the residual Core Strategy requirement through the allocation of further sites in the DaSA and not to rely on other provisions in the Plan.

7.16. It is in this context that this representation has been prepared, with specific regard to Site BEX3c, which has been included in the draft Site allocations shown in the DaSA