MOD 7.6

The insert paragraph 7.29 and 7.30 only confirm that over the last 20 years Rother has failed to meet its objectively assessed housing needs.

The Council acknowledge that "possible opportunities for further housing over time cannot be ruled out" hence the Council has set a minimum housing target of 5700 dwellings over the Plan period. This suggests that there is already additional housing capacity available that has just not been properly assessed.

Mod 7.6: Main modification not Sound.
Please see evidence e-mail submitted under 7.4 from Keiran O'Leary from RDC. The affodable housing proposed is not going to alleviate the local housing need as most people will still not be able to afford their own home.
Where is the evidence to back the claim that more housing will generate economic growth? The construction industry may benefit, but as a large number of people working in this industry are not local i.e Eastern European, this will not help the local economy. The more houses built in this area for commuters and second homes will also take money out of the area.
A total cap for housing should be submitted by the council, it cannot be left open-ended otherwise there will be no confidence in the system and it will be open to abuse an manipulation.

Further supporting evidence was submitted alongside the representation and can be accessed using the following link:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20595

Quite impossible to achieve a 48% increase, the target should be for local need only and not projected demand from elsewhere. This will be an unfair weight stressed on our area.

We support the principle of expressing the new housing requirement as a minimum figure, as this will ensure the supply of housing will not be constrained in the future, should it prove possible to deliver a greater level of housing than the Council currently anticipate.

In this modification, you state "projected housing" supply. This suggests that the actual need for new builds may be significantly lower than projected. Such assumptions will have a detrimental effect on communities already established. (Please see 12.5 for further explanation). This increase is contrary to NPPF guidance 14 because "any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or -specific policies in this Framework indicate development should be restricted". Yet again, unclear determination made by reports & studies on behalf of RDC show that such a high increase of development is not affordable in the short or long terms and is out of balance with business to home land use. The changes to AONBs and our environment cannot be undertaken without definitive proved need and not based on projections.

We are pleased that the document no takes on board the thrust of the new LPPF document and no longer refers to the defuncy South East Plan. The increases in housing supply are welcomed which will aid to create a more prosperous local economy which will in turn be significantly beneficial to local communities.

MOD2.2 The inserted text is welcomed but we see no necessity for the final sentence which makes reference to the South East Plan which is no longer applicable, by referencing it as a document only causes unnecessary confusion. Future infrastructure investment should now be based on the new LocalPlan. The final sentence should be deleted.

MOD 7.1 The new reference to the 4,800 dwellings as set out in the South East Plan is unnecessary.

MOD 7.5 The increased supply to at least 5,700 is to be welcomed.

MOD-7.6 We seek to alter the proposed paragraph 7.30 as follows: (changes in CAPS)

7.30 This growth is justified primarily in terms of COMPLYING WITH THE NPPF TO INCREASE HOUSING SUPPLY AND contributing to the projected demand for new homes, as well as in meeting the local need for housing and the need to support economic regeneration. The possibility of further opportunities for sustainable housing (as well as employment) development arising over time is A DISTINCT POSSIBILITY; hence the requirement is expressed as a minimum QUANTUM for the purposes of plan making. These will be further assessed as part of site allocations/neighbourhood planning processes.

MOD 7.9 With regard to the additional sentence; please consider adding 'modest' prior to 'potential' and insert 'detailed' prior to 'assessment'.

MOD 7.10 Please delete the additional modification as it is not necessary.

MOD 7.12 The increased housing provision figures at 5,700 are welcome as a minimum provision.

MOD 7.13 After the words 'sites are assessed' please add 'or subject to planning applications'.

MOD 7.14 Figure 8; the increase for the Villages to have 1,670 dwellings is welcomed.

MOD 7.18. At the proposed paragraph 7.57 the Council is taking windfalls into account. In terms of making an assessment of the 5 year land supply, is the Council making an allowance for the non­ implementation of planning permissions. We suggest that a percentage figure based on evidence be used in order to have a fair methodology.

MOD 8.5. Add on to the modification 'and that this delivery rate will be monitored on an annual basis'.

MOD 8.7. Delete 'support' or 'deliver' and add on to the final sentence 'or to allocate fresh housing land via planning permissions or alternative allocations'.

MOD 8.10. Delete 'marginal but critical' for 'strategically important'.

MOD 9.1 We object to the inclusion of the modification and seek that it be deleted.

MOD 12.4. We support the additional dwelling supply.

MOD 12.6. After 'Neighbourhood Plans', please add on 'or newly approved planning permissions'

Bovis Homes Ltd have established a stake in the Trinity College owned land at North East Bexhill (Glovers/Worsham Farms) proposed in the Adopted Local Plan for strategic growth (Adopted Local Plan Allocation BX2).

Bovis Homes Ltd have carefully considered the Council's proposed modifications issued in the Schedule of Main Modifications document (August 2013) and the implications the proposed modifications have for the future development of the urban extension at North East Bexhill (Local Plan Allocation - BX2).

Bovis Homes Ltd can support the proposed modifications and consider them to be sound. In particular, Bovis Homes Ltd are in support of the modifications confirming the Council's positive approach to reflect the presumption in favour of sustainable development and its intention to deal promptly and approve development schemes that accord with the Local Plan, unless material considerations indicate otherwise (Mod 2.1).

Bovis Homes Ltd also supports the modifications confirming the funding of the Bexhill to Hastings Link Road (Mod 4.1); and understands the Council's clarifications regarding the revocation of the South East Plan and its housing targets (Mod 2.2).

Bovis Homes Ltd accepts the Council's conclusion that the housing levels should be set at a level which is considered sustainable, in terms of balancing jobs and growth and taking into account transport infrastructure and impacts on the environment etc. (Mod 7.4). Bovis Homes Ltd therefore supports the modifications increasing the amount of housing to be delivered in the District over the plan period from 3,700-4,100 to at least 5,700 dwellings between 2011 and 2028 (Mod 7.5); and the Council intention to positively support an increase in house building rates (Mod 7.6). Bovis Homes Ltd strongly supports the Council's confirmation that the revised housing figures should be considered minimum targets to achieve, rather than rigid development ceilings (Mod 7.12).

Bovis Homes Ltd particularly supports the Core Strategy's continued emphasis on focusing growth on the town of Bexhill and in particular the urban extension at North East Bexhill; and the revised housing figures for Bexhill: 3,100 dwellings (Mod 7.14).

For the record, Bovis Homes Ltd can confirm that an agreement has now been reached with Trinity College, owners of Glovers/Worsham Farms to prepare and submit a planning application for at least 1,200 homes on the BX2 site, as soon as reasonably practical. The current intention is to submit a hybrid planning application early in the second half of 2014 with the first phase of development to be considered 'in detail' in order to accelerate the delivery of homes once consent has been issued. The scheme's anticipated determination date is early 2015, and the scheme's commencement date is expected to be later in that year. The timetable is related to the construction and delivery of the Hastings to Bexhill Link Road and the recently permitted 'Gateway Road/junction', which will provide the main means of access for the residential site, and the adjacent commercial site to be delivered by Sea Change Sussex (previously SeaSpace). The development trajectory for the residential site is approximately 125 dwellings per year, subject to market conditions.

Bovis Homes Ltd are meeting with the Council's Planning Team to agree a programme to bring forward the planning application's preparation and determination in an efficient and timely manner.

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).