MOD 7.15

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Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21310

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Representation:

We object to the inclusion of Exemption Sites as contributing towards the housing figures as these will only meet the affordable needs, not overall need/housing demand. A similar argument applies to Windfall sites where there is likely to be a significant shortfall of housing. Therefore these windfalls are unlikely to meet the objectively assessed housing needs across the District.

The housing figure of 5700 is a MINIMUM. It is reasonable that this housing figure (5700) remains a minimum target that Windfall and Exemption Sites are removed given the Councils acknowledgement that it is not meeting identified housing need.

Full text:

We object to the inclusion of Exemption Sites(65 units) as contributing towards the housing figures as these will only meet the affordable needs and not overall need or housing demand especially in rural areas which are likely to be restricted due to AONB. A similar argument applies to Windfall sites (460) where there is likely to be a significant shortfall of housing windfall sites in settlements that fall within the AONB. Therefore these windfall numbers are unlikely to meet the objectively assessed housing needs across the District.

The Councils housing figure of 5700 is a MINIMUM. It is therefore reasonable to ensure that this housing figure of 5700 remains a minimum target that Windfall and Exemption Sites are removed from the housing trajectory given the Councils own acknowledgement that it is not meeting its own identified housing need set out in its SHMA.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21461

Received: 27/09/2013

Respondent: Persimmon Homes South East

Agent: JB Planning Associates Ltd.

Representation:

The reference in the footnote to the 'lower end of the range', with regard to the housing target, appears to be related to the previous proposals and not the revised housing target, and it should be deleted.

Full text:

The reference in the footnote to the 'lower end of the range', with regard to the housing target, appears to be related to the previous proposals and not the revised housing target, and it should be deleted.

Support

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21528

Received: 27/09/2013

Respondent: Reliant Building Contractors

Agent: Mark Jackson Planning (Mr Mark Jackson)

Representation:

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.

Full text:

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.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21583

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Representation:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

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).