MOD 7.14

Figure 8 should be amended to include the additional SHMA housing shortfall of at least 480-600 dwellings under "Villages" (with at least 200 new dwellings being identified at Robertsbridge). Remove at least 150 at Hastings Fringe and reduce the housing figure for Rye to 250.

The increase in the housing requirement for the 'villages' from 950-1,000 (set out in the Proposed Submission Core Strategy) to 1,670 additional dwellings, set out in Figure 8, for the period 2011-2028 is supported because this more realistically reflects the capacity of the larger villages, such as the Rural Service Centre of Robertsbridge, to accommodate additional development.

The amendment of the amount of employment land to be included for the "villages" to "at least" 10,000 sq.m. does not take account that 2 of the 3 employment sites in Marley Lane are in Sedlescombe. Only one of the three employment sites in Marley Lane is in Battle parish (Rutherfords). The importance of the Marley Lane sites to Sedlescombe parish and their contribution to the villages' total of employment land should not be under-estimated. There are two current applications for businesses on these sites ie winery and salt depot, both in the parish of Sedlescombe.

Mod 7.14: MAIN MODIFICATION NOT SOUND :
Figures for the release of business space have been changed to be 'at least' figures, but there is no supporting evidence from RDC for this requirement. An assessment of the current levels of business sites currently not used (some of them have never been used) should have been undertaken. The villages total should be a maximum as there is less scope in a village environment to find more space.
The Marley Lane sites should be correctly designated between Sedelscome PC and Battle.

Regarding villages, this is an unfair increase in dwellings, there is no employment, transport, poor broadband and this will destroy the integrity and character of our rural villages.

Taylor Wimpey generally supports the increase in dwellings as shown in figure 8.

In particular, the company supports the increase in the number of dwellings proposed for village locations from 950-1,000 up to 1,670

MOD 7.14 Not sound
To quote "at least" figures for business/employment space would seem to be rather open ended and would not allow local residents to gauge a true indication of the scale and impact of any future development, and would not give people confidence in the planning procedure.

MOD 7.8 pg33.
This deprivation of Hastings and Bexhill is caused by the marketing of everything; we have the wrong idea about growth? Building houses seems to be what everybody believes will sort the economy out, but it just delays the crash; the higher things go the further they will fall, so we should stop the problem before it starts.
We have young and elderly people suffering from mental depression, people can't save for their pensions, what do these modifications do for them?
The plans that Rother are trying to put forward can only make things worse.
The large proposed development areas such as North Bexhill off the link road need to be offered as a site where people can grow, play and live in an oasis of peace.
Work units can only cost a few thousand pounds, yet we have sea space inviting big businesses to invest in the area at rents that one can rarely afford, having paid a development value for the land, let's put out a new plan. Consider the document, 'Protect our Open Spaces', we should have a referendum on this document before the idea goes to the full council. At the Link Road enquiry I asked what the County Council were paying for the land they were compulsory purchasing; they replied 'agricultural value'.
With 10,000 unemployed and 4,000 on the housing waiting list, we should do the same for the sake of Rother and Hastings; we should look at land reform on a national scale, start here? Stack the houses, create a community farm and have an elderly people's village!
The strategy as it stands will create debt and despair. It is unsound and Hastings is the same, you are all supposed to be working together, but it would appear a few are not co-operating, are they the ones who are making the decisions?

This point also applies to MOD 7.4, pg.36 regarding Battle and Rye, MOD 11.3 pg.70 Policy BA1 for Battle.

Mod 12.5 pg81, figure 12,
The extra houses should be given to the villages (from Udimore onwards) which could all take 20 houses under the Trust scheme; villages are desperate for homes for locals, unless we build something for them they will become fully occupied by elderly residents.
If you move on 30 years, as the generations die off properties will be bought by the buy to let companies because the local people won't be able to purchase them, in turn they will be let out at outrageous rents that only drug addicts and people who receive benefits can live for, do we want that?

MOD 12.5 pg80 Policy RA1

Each village could take a number of houses under the Land Community Trusy instead of the 1 or 2 mentioned in the Rother Core Strategy Modifications.

Chapter 8 vii 'Provide for employment and housing growth'

Employment work units and shops should be pursued which are affordable for any starter businesses. If the council control the sites and sell these units for cost for new people then the council will have control to monitor these people and see what is happening within businesses, this also means that the extra land can be rented rather than put on the market to be unused or misused.

Supplementary information submitted with the representation can be found here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=20689
http://www.rother.gov.uk/CHttpHandler.ashx?id=20673

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 proposal to increase housing numbers in the villages conflicts with the NPPF and with the spatial and strategic policy objectives of the district which are unmodified.

The methodology leading to the increase in housing numbers in the villages is fundamentally flawed and unsound and wholly unrelated to policy considerations. The decision to increase housing numbers in the villages is driven exclusively by the objective of spreading the district-wide 5700 unit number.

The NPPF states at paragraph 54 that in rural areas local planning authorities should plan housing development to reflect local needs. The Local Plan Strategy spatial and strategic policy conforms with this NPPF policy. This policy has not been modified. The level of growth and the location of growth must be policy-led. Only if the level of development proposed in any village was unreflective of its local needs could a modification to its individual allocation have been justified. However, no local needs based analysis was undertaken or affected the modifications decision.

Further, the modification to village housing numbers conflicts with national policy on localism and neighbourhood planning as the Council seeks to impose a prescriptive amount of development on individual villages which is unrelated to the villages' needs in order to bind the villages at the Neighbourhood Planning stage to these levels of growth. This means a village would be compelled to provide for an amount of housing development unrelated to its local needs, in conflict with NPPF paragraph 54 and with Local Plan strategic policy, were it to comply with NPPF paragraph 184 on the amount of development. This illustrates why the modifications are unsound.

With specific regard to Catsfield, there is an additional policy reason why the proposed housing allocation is unsound. The existing settlement size was assessed in 2008 in the village settlements study as 133 households meaning it is a small village in Rother District. Plainly, the level of growth proposed for Catsfield over the plan period - 64 dwellings - is far too high and wholly disproportionate to the size of the existing settlement. An important caveat to the identification of Catsfield as a "local service" village was provided at paragraph 12.15 of the Local Plan Strategy and this text has not been deleted. This text led to the original allocation of the 7-37 range for Catsfield in Figure 12, allowing Catsfield to plan within this range for the number of dwellings required to meet its local needs, insofar as this is proportionate to its existing size and character. It is not possible for the Council to renegue upon this undertaking now, given the settlement hierarchy was consulted upon with this important caveat in place and relied upon, and in any case the undertaking is retained unmodified.

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