MOD 7.13

Policy OSS1 (i) Object to housing figure 5700 as this does not meet the Councils objectively assessed housing needs.

(iii)(c) object to the presumption that growth in villages should be limited especially were evidence exists to suggest that the potential for growth may be greater. The Council have fundamentally failed to assess the capacity of sustainable villages (such as Robertsbridge) to accommodate greater levels of housing because it has failed to carryout the necessary investigation into the Landscape Capacity of the settlements that fall within the AONB.

Retain original paragraph, do not use insertion.

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text is welcomed but we see no necessity for the final sentence which makes reference to the South East Plan which is no longer applicable, by referencing it as a document only causes unnecessary confusion.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'

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).

Bexhill Development Strategy - land west of Bexhill
Proposed Modification Nos. MOD 7.13, 7.14, 8.6, 8.10, 8.11 and 8.12

1. Draft Policy OSS1 aims to focus new development at Bexhill. "lt should benefit from enhanced facilities and services which would result from further development" (paragraph 35 of the Council's 'Summary Appraisal of Sustainable Housing Growth'). The Council acknowledge that in light of the review of the assessed housing needs (based upon the County Council's projections), there is now a need to increase housing supply in the District compared to that previously proposed in the Submission Draft version of the Core Strategy.

2. Proposed MOD 7.13 now seeks to increase the housing requirement to at least 5,700 dwellings over the Plan period and MOD 7.14 and 8.12 confirms the intention to increase the housing requirement to 3,100 dwellings in Bexhill (subject to the outcome of an ongoing Transport Capacity Study). While much of this housing development is dependant upon the completion of the Hastings to Bexhill link road, MOD 8.10 indicates there is also potential at 'broad locations' around the northern and western edges of the town. Paragraph 8.59 of the Proposed Submission Core Strategy states that development "may be extended westwards adjacent to the urban area without undue impact on the wider landscape". Paragraph 8.60 also indicates that development to the west of Little Common, both north and south of Barnhom Road (A259) will also be considered with access created directly onto the A259, with the scale, timing and locations ideally being determined at the site allocations stage (MOD8.11).

3. Within this context, the updated (June 2013) Strategic Housing Land Availability Assessment (SHLAA) will be an important consideration, but until now, there has been no opportunity for developers or landowners to scrutinise the Council's conclusions in the respect of the separate sites identified.

4. As regards one of the Council's stated intentions of a broad location for housing growth being identified around the 'western edges of the town', land at the western end of Barnhorn Road (A259) would be a key consideration. The main candidate site in this respect would be SHLAA site BX50, which comprises an undeveloped parcel of land outside the High Weald Area of Outstanding Natural Beauty that is located to the west of no. 163 Bamhorn Road (see SHLAA extract contained in appendix 1 attached). The land comprises an undeveloped gap in otherwise built front frontage where public views along the A259 are screened by tall evergreen trees along the road frontage.

5. Although the land has been assessed by the Council as a 'red' site not suitable for housing development, this conclusion is open challenge and these representations (i.e. TCPS Representations No. 6) make the case that this land is suitable and should be examined in detail as to its potential at the site allocations stage.

6. The 'Technical Note' contained in appendix 2 attached demonstrates that access could be obtained to serve up to 40 dwellings on the site. The Technical Note contains an illustrative drawing no. 4377/1 showing layout of 32 dwellings on the site comprising a mix of two, three and four bedroom units that would include 40% affordable housing. The illustrative layout demonstrates the retention of trees along the road frontage and availability of space to create landscape buffers around other boundaries of the site.

7. Thus, this housing development would comprise a western extension to Bexhill and make a useful contribution to housing supply in a form that is not dependent upon the construction of the link road. The Council's recent decision to resolve to permit 275 dwellings to the north of Barnhorn Road (planning application no. RR/2012/1978/P) confirms that a new access onto the A259 can be acceptable in principle.

Supplementary information submitted with the representation can be found here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20686