MOD 8.6

It is proposed in paragraph 8.52 that the objectively assessed housing need for Bexhill (182 dwellings per annum) will place an added weight on initiatives to stimulate job growth.

'It is recognised that this [182 dwellings per annum] is well and above the average house building rate over the last 20 years and will place added weight on initiatives to stimulate job growth. Hence particular emphasis will be given to schemes that bring significant employment land.'

This is a conflation of the separate issues of job creation and meeting the identified housing need. The Council's housing requirement has been assessed as the amount of housing that can sustainably be accommodated in the district having regard to economic growth, demographic projections and household formation, in accordance with paragraph 47 of the National Planning Policy Framework (the Framework). The appropriateness of the Council's housing target for the district and Bexhill has already been assessed in the light of economic factors.

There can be no justification to either require schemes to, or favour schemes that 'bring significant employment land' over those that deliver the housing requirement identified for the district generally and Bexhill specifically. The intent of the Council not to give proper consideration to residential led or single use residential schemes that deliver the identified housing need set out in the Core Strategy is entirely contrary to the provisions of paragraph 47 of the Framework which seeks 'To boost significantly the supply of housing'.

Whilst this reference is only made in the supporting text at paragraph 8.52, it signals the Council's intention to seek employment floorspace as part of residential schemes necessary to deliver identified housing need, regardless of deliverability and viability. This modification has the propensity to delay the delivery of residential sites identified in and around Bexhill as suitable to meet the housing requirement, either in the absence of the Council's support or as a result of the employment element of a scheme being undeliverable.

To this end, the proposed modification signals a potential failure by the Council to deliver 182 dwellings per annum and also fail to produce a supply of specific deliverable sites as required by paragraph 47 of the Framework.

These modifications assume that it is necessary for the level of housing which is to be provided to be constrained in some way if the level of jobs which are created within the plan period is below the level the Council would wish to see. However, as we have previously explained in our evidence, and comments at the Examination hearings, this assumption is flawed.

The provision of housing actually helps to stimulate the economy, and housing is clearly identified as an economic driver throughout the NPPF. A greater level of housing provides accommodation for a resident work force, reducing prices, providing affordable housing, and generally making it possible for people to live close to where they work. Without new housing, local employers are more likely to relocate away from an area, as they find it more difficult to recruit staff, particularly those who are paid less.

Housing itself also helps to stimulate the creation of new jobs through the construction industry, and the secondary generation of employment through related industries.

There is no evidence which suggests that it is necessary to limit the amount of housing in order to allow the number of jobs in the area to "catch up" in some way. Neither is there any evidence which suggests that constraining the amount of housing will in some way help to stimulate the provision of new jobs, and the available evidence actually suggests quite the opposite. To restrict the level of housing based on these spurious grounds would be contrary to paragraph 47 of the NPPF. These proposed modifications should therefore be deleted.

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