12.18

The Council need to assess existing housing allocations and check these can be delivered against their housing trajectory.

Phasing the existing local plan allocations together with outstanding extant planning permissions to be delivered in the early part of the plan period is supported as these sites have been identified for development for some time and their technical suitabiity and sustainability merits have been established.

Phasing does not take into account financial constraints,local or global. As the recent economic downturn has proved, a site being classed as available, deliverable, sustainable etc doesn`t guarantee its` completion (or even commencement) within the ideal timeframe. The (now defunct) SE Plan requirement from 2009 to 2026 required 268 dwellings per year within Rother. In the year 2009/2010 just 95 were built. The uncertainty regarding the Bexhill Hastings Link Road has pushed the planned phasing back in the Bexhill area so, based on historical evidence, phasing as a planning tool clearly cannot be relied upon to deliver

We are concerned that the Council is relying on extant permissions to deliver required housing numbers in the earlier phases of the Plan with new allocations restricted to later phases, as described in paragraph 12.18 of the Core Strategy. In the case of my client's interests this would mean that his site, which is available now and has been considered as suitable in principle by the SHLAA could not be delivered for at least another 5-10 years.

The extant housing supply in Sedlescombe consists entirely of small schemes (just two have 6 units, the rest are all smaller than 5 units). This type of scheme does little to address housing needs as it rarely (if ever) provides for affordable housing or any other type of complementary use that would be beneficial to the village. As such, the Core Strategy is actively seeking to prevent the delivery of affordable housing in the village for the next 5-10 years. Such an approach would be contrary to the delivery of one of the top 10 strategic development issues set out in paragraph 4.2 of the Core Strategy - this being the delivery of affordable housing. This is especially significant given the historic low levels of affordable housing provision across the District with an average of 32.5 per year since 2004 (against a Local Plan target of 56 per year) and just 17 units last year .

In contrast, my client's emerging scheme will deliver affordable housing, new educational facilities, new employment opportunities and new open space - all of which have been identified as key priorities in the Council's 2008 Rural Settlements Strategy and all of which are referred to in policy RA1, with the need for employment being explicitly referred to in Figure 10. This one example serves to show that the Council's stance on the timing of delivery of new housing allocations inhibits the ability of policy RA1 to meet the future needs of the villages.

Furthermore, the inability of policy RA1 to deliver affordable housing in the rural areas conflicts with the recommendations of the Council's 2010 SHMA, which advised that "Development in the rural villages should do more to deliver affordable housing given the lack of supply of affordable homes in the area and that development economics is often more robust."

Paragraph 12.18 advises that restricting the earlier phases to the completion of committed supply and existing allocations is beneficial to the social cohesion of the villages. In the case of Sedlescombe we suggest that this is incorrect. The reliance on the committed supply (as there are no allocations) will not assist in the delivery of affordable housing, community uses or employment floorspace - indeed it will preclude the redevelopment of a site that has the potential to deliver all of these facilities.

We therefore object to the Council's intention in paragraph 12.18 to incorporate an apparent blanket application of this phased approach to housing delivery. We consider that such an approach is unjustified and potentially ineffective and as such is unsound.

To remedy this we suggest the following amendment to paragraph 12.18 (new text in bold; deleted text as strike through):

In terms of phasing, it is generally assumed that existing housing allocations (provided they have been demonstrated in the SHLAA and through Housing Monitoring as deliverable) and outstanding permissions will be developed in the earlier phases of the Plan. In villages which have seen higher levels of development new housing developments will only be permitted in the early phases of the plan period where they address the wider needs of that village. This new development will be subject to the housing targets set out in Figure 12 for the individual villages, the requirement to maintain a five year housing supply and also the additional facilities that individual schemes are capable of bringing forward that address the needs identified in policy RA1. It is considered that this will be beneficial to the social cohesion of existing villages.