MOD 7.12

We see this as excessive development. Retain original paragraph and do not use insertion.

Taylor Wimpey supports the allocation of at least 5,700 dwellings in the District over the period 2011-2028.

It also supports the proposal that development at Battle is appropriate to maintain its role as a market town.

It also supports the proposal that new housing should be located in those villages, such as Hurst Green which contain a range of services and which will contribute to supporting vibrant communities, notably in relation to service provision and local housing needs, and which is compatible with the character and setting of the settlement.

Hastings Borough Council supports the level of housing planned for over the Plan period and the inclusion of "at least" in the Policy wording which introduces flexibility and allows for further unidentified sites to come forward over the Plan period. This level of housing growth is consistent with the Plan's objective of achieving a better balance between homes and jobs whilst at the same time does not compromise the Plan's environmental protection objectives and will assist in ensuring overall sustainable development.

We wish to support the proposed amendments to the Rother District Council Submission Core Strategy in relation to MOD 7.12. It is positive that the level of housing provision has been increased (across the District as a whole and in relation to the Hastings Fringe), it is considered that this will help to ensure that the housing needs of the District will be met, as well as provide a level of housing which could aid economic growth. The level of housing now put forward is in line with the South East Plan targets, as well as the targets set by the updated Strategic Housing Market Assessment (SHMA). The SHMA (June 2013) concludes that 6,178 dwellings should be provided within Rother between the period 2011-2028, at an average of 363 dwellings per annum. As such, whilst the proposed amendments do not put forward the level of housing proposed by the SHMA, making for provision of just 5,700 dwellings (478 less than that recommended by the SHMA) it does represent a significant and more appropriate level of provision than previously drafted. With regards the level of housing now required by the Core Strategy our view is that it would help meet the development needs of the area in accordance with the National Planning Policy Framework (NPPF) and therefore would be sound.

In supporting the Policy as now drafted we also make the following comments. The Council argue that the full level of housing provision recommended by the SHMA could not be delivered due to environmental restrictions within the District which relate predominantly to the High Weald Area of Natural Beauty. A significant part of both Hastings and Rother are restricted by the AONB which limits the potential for large housing developments within the countryside. It has previously been proposed that Land at Breadsell Farm (which includes land within Hastings) could provide the only suitable option for a sustainable urban extension within these Districts. Whilst it is recognised that the wider area of land at Breadsell Farm has not been included within Hastings submission Core Strategy (due to a current Natural England objection which relates to an adjacent SSSI) it is considered that in the interests of cooperation and in order to ensure that sufficient housing is provided within the Strategic Housing Area, a more positive approach to Land at Breadsell Farm should be taken in order that it could provide a significant level of housing for both Rother and Hastings, allowing both authorities (who are currently proposing a level of housing development below what is considered to be required) to provide the full amount of housing recommended by the SHMA. In accordance with the Duty to Cooperate allocating land at Breadsell Farm would help to ensure that both Local Planning Authorities are able to meet the housing needs for this strategic area and would help to ensure that the Core Strategy can be found sound.

Shepway District Council (SDC) officers have considered the nature of the changes proposed by Rother District Council (RDC) for the Rother District Council Local Plan Core Strategy under the Schedule of Main Modifications, August 2013. I would firstly like to inform you that further to the letter from Hastings & Rother regarding housing needs (dated 19th July 2013) and Shepway's e-mail reply I can confirm Shepway District Council's Core Strategy Local Plan was found 'sound' in June 2013 by Planning Inspector Michael Hetherington, and accordingly adopted as part of Shepway's development plan on 18th September 2013.

Notwithstanding the environmental issues identified in the Shepway Core Strategy examination and covered in the aforementioned email, SDC officers recognise the increase in housing numbers proposed under the changes (specifically MOD7.12) and support, in full, appropriate measures to get up-to-date development plans in place in the sub-region; and on the basis that RDC ensures that any potential impacts upon Shepway are minimised in terms of pressure on the physical and natural environment.

SDC will seek to collaborate with RDC on future plans, most notably specifically regarding proposals that are relevant to Romney Marsh, and in accordance with the Duty to Cooperate under The Localism Act 2011. The council awaits with interest further details from RDC as to how their plans will evolve notably in the environs of Rye and how RDC will manage any arising implications.

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'

Policies OSS1and RA1

Policy OSS1 provides for at least 5,700 dwellings in Rother between 2011 and 2028. Policy RA1 deals with the rural housing provision and it plans for 1,670 houses in the rural areas across the plan period. We consider these policies to be unsound because:
1. The evidence base underpinning the OSS1 housing target is flawed and does not represent an objective assessment of need; and
2. The proposed 0SS1 housing target derived from this claimed objective assessment of need is unnecessarily constrained; and that this constrained figure unduly affects the housing provision of the rural areas in policy RA1.

We assess these two issues in detail in the following text.

Objective Assessment of Housing Need
Paragraph 47 of the National Planning Policy Framework (the 'Framework') requires authorities to use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. In order to do this, paragraph 159 of the Framework recommends that authorities prepare a Strategic Housing Market Assessment (SHMA).

In establishing an objective assessment of housing need, the new draft National Planning Practice Guidance advises that household projections published by the Department for Communities and Local Government (DCLG) should provide the starting point estimate of overall housing need. The most up-to-date projections are the 2011-based Interim projections which were published by the DCLG in April 2013 (however, these projections are Interim projections which only run from 2011 until 2021). From here there are a number of recognised demographic forecasting models that will produce an objective assessment of need, using OCLG projections as a starting point. One such model is POPGROUP, which is owned by the Local Government Agency (with development and technical support provided by Edge Analytlcs) and is recognised as being a robust and transparent model which is and has been used by a large number of regional and local government authorities, health authorities, universities and planning consultancies. This is indeed the forecasting model that has been used by Rother District in their SHMA (June 2013) in identifying an objective assessment of housing need in the District.

Rother in their SHMA use as their starting point the DCLG 2011-based Interim household projections, which point to a need of 5,072 extra dwellings in years 2011-2021; which equates to a rate of 507 dwellings per annum. Because Rother's plan period runs from 2011 until 2028, Rother then roll forward the 2011-based figures (which only go as far as 2021) a further 7 years until their plan period end year 2028. It is concluded by the SHMA, using the 2011-based DCLG projections as a starting point over the full plan period and then forecasted through the POPGROUP demographic forecasting model, that the objective assessed housing need for Rother over the plan period of 2011-2028 is 6,180 dwellings; equating to 360 dwellings per annum.

Whilst the 2011-based household projections should be used as a starting point in identifying an objective assessment of need, caution needs to be applied in their use. These figures actually reflect a falling housing market rather than painting a picture of what is needed in the future as they project forward what has happened since 2008, during the recession. This is a period characterised by:
* A huge undersupply of new homes
* Increased overcrowding
* Asking prices remaining out of reach for first time buyers
* Restricted mortgage finances which has put the brakes on the market

We consider that it is entirely inappropriate to simply use these 2011-based Interim projections as a starting point for the whole of Rother's plan period (I.e. beyond 2021). In fact, upon their release, Edge Analytics (the technical consultancy behind POPGROUP) in their document 'CLG 2011-based Interim Household Projections: Reference Manual' advise that because of the Interim nature of the 2011-projections, a number of options should be used to forecast for the period after 2021 as it is not appropriate to simply roll forward the 2011- based Interim projections beyond 2021.

One such option given by Edge Analytlcs is to calculate the change after 2021 from the 2008-based DCLG projections. Indeed the 2008-based projections represent a pre-recesslon period which is not characterised by the same abovementioned issues associated with the 2011-based Interim figures and therefore represent a more accurate picture of actual housing need going forward beyond 2021. With specific regard to Rother, the 2008-based projections pointed to a need of 10,757 dwellings over the period 2006-2026; which equates to 538 dwellings per annum. Clearly, this is a higher level of growth than accounted for by the 2011-based Interim projections. Furthermore, the Cambridge Centre for Housing & Planning Research (CCHPR) in their May 2013 report 'The new Household Projections and their implications for the Cheltenham Borough Council, Gloucester City Council and Tewkesbury Borough Areas' express the view that 2011-based Interim projections should only be used until 2015. Onwards from 2015, CCHPR conclude that a projection which would paint a realistic picture of housing need would be a projection which lies somewhere between the 2011-based Interim projections and a projection which represents a 'partial return to trend' scenario (i.e. a trend which gradually returns towards the
2008-based projections from the year 2015).

Although the SHMA does attempt to justify its use of using only the 2011-based Interim projections and not the 2008-based projections by stating that the 2008-based projections contained statistical inaccuracies (overestimating the population by 550 people and overestimating the number of households by 515), we do not consider on this basis that they should be plainly ignored. The fundamental point being made here is that other baseline projection scenarios which represent the realistic prospect of a return to a rate of faster growth should have been incorporated into the objective assessment; as opposed to Rother's assessment which simply uses recession-based 2011-based Interim projections and then rolls them forward to 2028, which is beyond their end period of 2021. Once a more appropriate starting polnt(s) which represented the likely return to growth had been established, only then should such figures have been forecasted using POPGROUP. This would have meant that the true objective assessment of housing need would have been higher than the SHMA identified need of 6,180 over the plan period.

Proposed Housing Target
The second point to be made here is that the actual proposed housing target of at least 5,700 dwellings over 2011-2028, as provided for by policy OSS1, is an unjustifiably constrained figure from the claimed objectively assessed need of 6,180 dwellings over the plan period. Indeed as discussed above, the assessed objective need of 6,180 is in itself an artificially constrained figure.

Policy OSS1 provides for at least 5,700 dwellings between 2011and 2028 which is made up from:
* 3,100 dwellings at Bexhill
* 100-250 dwellings at Hastings Fringes
* 475-500 dwellings at Battle
* 335-400 dwellings at Rye
* 1,670 dwellings at Rural Villages

(Whilst the actual figures here point to a maximum of 5,920, the Council believe that this upper level is subject to uncertainties, which is why the target of at least 5,700 is given.)

A 'Summary Appraisal of Sustainable Housing Growth Potential,' which was produced by the Council and attached as an appendix to a report to cabinet dated 1 July 2013, aims to justify why the claimed objective figure of 6,180 cannot be met and why the 5,700 target is appropriate. Notwithstanding other issues which are claimed to constrain development at the main settlements which we do not wish to make comment on, a main identified constraint to meeting the objectively assessed need is the presence of the High Weald Area of Outstanding Natural Beauty (AONB). It is the Council's position that the cumulative implications of further activity and populace in the AONB will impact on its character. This is particularly relevant to the provision for 1,670 dwellings at the Rural Villages. Policy RA1 deals with rural housing provision in further detail; it provides for 1,670 dwellings over the plan period located in accordance with the accompanying settlement distribution, subject to refinement in the light of further investigation via the Development and Site Allocations DPD and/or Neighbourhood Plans.

Although we do recognise that a balance needs to be struck between the provision of much needed housing and the conservation of the AONB, it is our view that a higher level of housing can be accommodated in the rural areas than is planned for under policy OSS1 and subsequently policy RA1 without compromise to the AONB. On 7 May 2013 the Inspector wrote to the Council about the approach that they should be taking in respect of identifying an objective assessment of housing need:

"...the Area of Outstanding Natural Beauty (AONB) is cited by several respondents as a constraint. Paragraph 115 of the Framework indicates that great weight should be given to conserving landscape and scenic beauty in AONBs. It does not, however, include a presumption against development in an AONB and paragraph 28 seeks to support a prosperous rural economy' (our emphasis).

Whilst this letter was sent to the Council in the context of identifying an objective need, its advice is also applicable to the housing provision that results from the objectively assessed need. The Inspector here makes reference to paragraph 28 of the Framework; which seeks to support a prosperous rural economy. This paragraph needs to be read in the context of the Framework as a whole which has a clear focus on sustainable growth and a significant boost in housing supply. It is our view that more sites located in the AONB should be able to come forward and that the overall rural housing figure should be increased to reflect this. This would be more closely aligned to the Council's perceived objective assessment of need and the overall thrust of the Framework to allow sustainable development and foster a large increase in house building.

Moreover, an increase in rural housing would assist in developing 'balanced communities' if it further encourages younger people to live locally. This was a point that was made by officers in their 1 July 2013 Cabinet Report. Indeed such an approach of increasing the supply of housing in rural areas was recommended to the government by the 'Taylor Review of Rural Economy and Affordable Housing' (2008), authored by Lord Matthew Taylor of Goss Moor (also the lead reviewer of the planning guidance which has resulted in the National Planning Practice Guidance). This report states that restrictive planning policies contribute towards small rural villages becoming increasingly unsustainable and unaffordable for those who live and work there and that a large increase in housing supply is needed if this trend is to be reversed.

Conclusion
We consider that the proposed Main Modifications to the Core Strategy are unsound, with specific reference to policies OSS1and RA1. This is because:

* In identifying a starting point for an objective assessment of housing need, the Council have rolled forward the DCLG 2011-based Interim projections until 2028, which is 7 years past their 2021 end period;
* The 2011-based Interim projections represent a period characterised by the economic recession, constrained household formation and mortgage availability and do not paint a picture of what is likely to happen going forward once the economy returns to a state growth;
* Recommendations from the Cambridge Centre for Housing & Planning Research indicate that the 2011-based Interim projections should not be used after 2015; rather a projection which lies somewhere between the 2011-based Interim projections and a projection which represents a 'partial return to trend' scenario (i.e. a trend which gradually returns towards the 2008-based projections from the year 2015) should be used;
* Regardless of the soundness of the claimed objectively assessed need figure, the Coundl's proposed OSS1 housing provision of 5,700 dwellings is an unjustifiably constrained figure;
* When taking into consideration the overall thrust of the Framework and its focus on fostering sustainable development and significantly increasing house building, more sites within the AONB should be allowed for housing and the overall and rural housing figures provided by polices OSS1 and RA1 respectively should be increased to meet the Council's claimed objectively assessed need;
* More rural housing would assist with the Council's strategic objective of developing 'balanced communities' and would respond positively to the issues highlighted by the Matthew Taylor Report in respect of restrictive rural policies contributing towards rural villages becoming unsustainable.

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.

On behalf of my client's, owners of land off Ferry Road and Cyprus Place Rye, we support the Main Modifications to the Proposed Submission Core Strategy. These revised modifications appear to have more fully addressed the need to objectively address the needs for housing in the District.

However, it is not entirely clear in the evidence to what extent consultation has taken place with adjoining authorities as suggested by the Inspector to then draft the modifications and revise the housing targets and it is suggested that the Council provide information in this regard.
Paragraph 47 of the Framework refers when dealing with the housing market area.

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).