MOD 8.7

The Council state that the 3300 housing target for Bexhill would deliver 200pa over the remaining 15 years i.e. 3000 dwellings some 200 short of its target and 235 less than the full SHLAA capacity.

More revealing is the fact that only an average of 130 dwellings pa were built from 2001-2007, when economic conditions were clearly more favourable. In the past 12 years output of new homes in Bexhill has only exceeded 200 new homes in one year, and has exceeded 150 new homes in only 5 out of the 12 years. The Wessex Economics report on Housing Delivery at Bexhill and Hastings (June 2013) concluded that the 200 homes pa was challenging as market capacity and potential impact on sale values could lead to oversupply becoming a deterrent on high volumes of new building.

The evidence over the last 12 years backs this up. For the Council to suggest this was due to no major land releases being available over the previous 12 years suggests that Bexhill had no more than 200 units pa available with planning consent in the Bexhill area over that period. This is clearly not correct.What limited the supply of housing was market demand and affordability of new homes in Bexhill over that period. Indeed an arguement can clearly be made that large land releases controlled by one or two large house builders would actually reduce housing supply and choice within Bexhill area in the future.

The current housing trajectory shows housing completions in Bexhill increasing from 29 new homes in 2012/13 to a peak of 290 new homes in 2015/16(in just 2 years time). There is NO evidence for such a leap in delivery justifying this level of increase.

There remains real limitations to further growth in Bexhill because at this level of housing it does not reduce flows on the A259 east of the town centre, while already planned development may not leave any capacity for further flows on local roads in the area confirmed within Mott MacDonald LDF Sensitivity Assessment. (July 2013)

The council have deleted and ignored its own evidence base with the removal of the justified target of around 150 dwellings pa over the later period of the previous Plan deliverable at Bexhill which they previously acknowledged "is equivalent to the rate of house building over the past 5 years"(para8.53). Nothing has changed since the publication of their deposit plan that can justify them abandoning this rate of housing delivery at Bexhill just so it can meet a new housing target for the town.

Policy BX3 requires Bexhill to deliver 3,100 dwellings (182 dwellings per annum) to contribute to the Council's overall housing land supply. This requirement forms part of the Council's objectively assessed housing need that will form a central policy within the Council's Core Strategy. In the proposed modification the Council anticipates that the completion of the Bexhill Link Road will increase quickly to the annualised target.

However, the modification seeks to make provision for the phasing of development (through Policy IM3) in the event that the housing market does not support such a high rate of growth and/or if job creation is not being realised.

There can be no rationale for seeking to control the delivery of housing identified to meet annualised need by phasing through the site allocations document. Enshrining a phasing strategy in a site allocations development plan document to address concerns regarding the housing market does not provide flexibility should there be a change in circumstances. Further, it is the development industry that is best placed to recognise and respond to market signals in order to assist the Council in delivering its identified housing need.

In addition to seeking to respond to the housing market conditions in an inflexible development plan document, the Council also wants to control housing delivery through the same development document if job creation is not being realised. This has no basis. The Council's housing target has been identified in the light of considerations such as economic factors, demographic projections and household formation. There is no justification for the Council to further seek to control of the delivery of this identified need for considerations that have already been tested through the development plan (Core Strategy) process.

In short, there is a policy requirement for the delivery of 182 dwellings per annum in Bexhill, which has been assessed to meet identified need and there can be no justification for seeking to control the delivery of this identified need for reasons identified in the proposed modification.

Such a strategy may also result in the Council failing to comply with the requirements of Paragraph 47 of the National Planning Policy Framework (the Framework) which requires that local authorities should (inter alia):

'identify and update annually a supply of specific deliverable sites sufficient to provide five years worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period)'.

'Illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their target'

As noted, the delivery of c.182 houses per annum in Bexhill throughout the plan period is required in order to assist the Council in maintaining its five year land supply incorporating the 5% buffer. Footnote 11 of the Framework directs that sites which have long term phasing plans should not be identified within the five year land supply.

Paragraph 49 of the Framework states that the supply of housing should not be considered up-to-date if the local authority cannot demonstrate a five-year land supply of deliverable housing sites. In such cases there is a presumption in favour of sustainable development. This is a central policy of the Framework in order to ensure that sufficient, appropriate housing is delivered. The supply of housing is not contingent upon simultaneous job creation and there is no justification for seeking to control housing supply required by the development plan.

Reference to phasing housing delivery to respond to a dearth in the housing market and job creation not being realised is not consistent with the central aim of the Framework to ensure that there is supply of sites sufficient to provide five years worth of housing against the Council's requirement.

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'