MOD 12.4

Replacement Policy RA1 is supported because it is based on an increased overall housing requirement of 'at least' 5,700 additional dwellings in the period 2011-to 2028, derived from the SHMA Update: Housing Needs Assessment (June 2013), which is supported. Further, the increased allocation for the villages of 1,670 dwellings is also supported because it acknowledges that the villages, especially the larger Rural Service Centres (such as Robertsbridge) have greater capacity to absorb additional development than the draft plan has previously recognised.

The new level of housing numbers in the villages 'should not prejudice their individual character and amenities as well as their shared landscape' (Mod 7.11) MOD 7.12 also states that growth should be limited and 'compatible with the character and setting of the villages."
The increased numbers will inevitably have a negative impact on the AONB and the character of targeted villages. There will also be a disproportionate impact on villages with loss of greenfield sites and changes to the character of particular villages. As only a few villages are targeted, there has to be the construction of new estates, where villages in the past and some more recently have been required to absorb larger growth than in the urban areas.

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'

Policies OSS1 and RA1
Policy OSS1 provides for at least 5,700 dwellings in Rother between 2011 and 2028. Policy RA1 deals with the rural housing provision and it plans for 1,670 houses in the rural areas across the plan period. We consider these policies to be unsound because:
1. The evidence base underpinning the OSS1 housing target is flawed and does not represent an objective assessment of need; and
2. The proposed 0SS1 housing target derived from this claimed objective assessment of need is unnecessarily constrained; and that this constrained figure unduly affects the housing provision of the rural areas in policy RA1.

We assess these two issues in detail in the following text.

Objective Assessment of Housing Need
Paragraph 47 of the National Planning Policy Framework (the 'Framework') requires authorities to use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. In order to do this, paragraph 159 of the Framework recommends that authorities prepare a Strategic Housing Market Assessment (SHMA).

In establishing an objective assessment of housing need, the new draft National Planning Practice Guidance advises that household projections published by the Department for Communities and Local Government (DCLG) should provide the starting point estimate of overall housing need. The most up-to-date projections are the 2011-based Interim projections which were published by the DCLG in April 2013 (however, these projections are Interim projections which only run from 2011 until 2021). From here there are a number of recognised demographic forecasting models that will produce an objective assessment of need, using OCLG projections as a starting point. One such model is POPGROUP, which is owned by the Local Government Agency (with development and technical support provided by Edge Analytlcs) and is recognised as being a robust and transparent model which is and has been used by a large number of regional and local government authorities, health authorities, universities and planning consultancies. This is indeed the forecasting model that has been used by Rother District in their SHMA (June 2013) in identifying an objective assessment of housing need in the District.

Rother in their SHMA use as their starting point the DCLG 2011-based Interim household projections, which point to a need of 5,072 extra dwellings in years 2011-2021; which equates to a rate of 507 dwellings per annum. Because Rother's plan period runs from 2011 until 2028, Rother then roll forward the 2011-based figures (which only go as far as 2021) a further 7 years until their plan period end year 2028. It is concluded by the SHMA, using the 2011-based DCLG projections as a starting point over the full plan period and then forecasted through the POPGROUP demographic forecasting model, that the objective assessed housing need for Rother over the plan period of 2011-2028 is 6,180 dwellings; equating to 360 dwellings per annum.

Whilst the 2011-based household projections should be used as a starting point in identifying an objective assessment of need, caution needs to be applied in their use. These figures actually reflect a falling housing market rather than painting a picture of what is needed in the future as they project forward what has happened since 2008, during the recession. This is a period characterised by:
* A huge undersupply of new homes
* Increased overcrowding
* Asking prices remaining out of reach for first time buyers
* Restricted mortgage finances which has put the brakes on the market

We consider that it is entirely inappropriate to simply use these 2011-based Interim projections as a starting point for the whole of Rother's plan period (I.e. beyond 2021). In fact, upon their release, Edge Analytics (the technical consultancy behind POPGROUP) in their document 'CLG 2011-based Interim Household Projections: Reference Manual' advise that because of the Interim nature of the 2011-projections, a number of options should be used to forecast for the period after 2021 as it is not appropriate to simply roll forward the 2011- based Interim projections beyond 2021.

One such option given by Edge Analytlcs is to calculate the change after 2021 from the 2008-based DCLG projections. Indeed the 2008-based projections represent a pre-recesslon period which is not characterised by the same abovementioned issues associated with the 2011-based Interim figures and therefore represent a more accurate picture of actual housing need going forward beyond 2021. With specific regard to Rother, the 2008-based projections pointed to a need of 10,757 dwellings over the period 2006-2026; which equates to 538 dwellings per annum. Clearly, this is a higher level of growth than accounted for by the 2011-based Interim projections. Furthermore, the Cambridge Centre for Housing & Planning Research (CCHPR) in their May 2013 report 'The new Household Projections and their implications for the Cheltenham Borough Council, Gloucester City Council and Tewkesbury Borough Areas' express the view that 2011-based Interim projections should only be used until 2015. Onwards from 2015, CCHPR conclude that a projection which would paint a realistic picture of housing need would be a projection which lies somewhere between the 2011-based Interim projections and a projection which represents a 'partial return to trend' scenario (i.e. a trend which gradually returns towards the
2008-based projections from the year 2015).

Although the SHMA does attempt to justify its use of using only the 2011-based Interim projections and not the 2008-based projections by stating that the 2008-based projections contained statistical inaccuracies (overestimating the population by 550 people and overestimating the number of households by 515), we do not consider on this basis that they should be plainly ignored. The fundamental point being made here is that other baseline projection scenarios which represent the realistic prospect of a return to a rate of faster growth should have been incorporated into the objective assessment; as opposed to Rother's assessment which simply uses recession-based 2011-based Interim projections and then rolls them forward to 2028, which is beyond their end period of 2021. Once a more appropriate starting polnt(s) which represented the likely return to growth had been established, only then should such figures have been forecasted using POPGROUP. This would have meant that the true objective assessment of housing need would have been higher than the SHMA identified need of 6,180 over the plan period.

Proposed Housing Target
The second point to be made here is that the actual proposed housing target of at least 5,700 dwellings over 2011-2028, as provided for by policy OSS1, is an unjustifiably constrained figure from the claimed objectively assessed need of 6,180 dwellings over the plan period. Indeed as discussed above, the assessed objective need of 6,180 is in itself an artificially constrained figure.

Policy OSS1 provides for at least 5,700 dwellings between 2011and 2028 which is made up from:
* 3,100 dwellings at Bexhill
* 100-250 dwellings at Hastings Fringes
* 475-500 dwellings at Battle
* 335-400 dwellings at Rye
* 1,670 dwellings at Rural Villages

(Whilst the actual figures here point to a maximum of 5,920, the Council believe that this upper level is subject to uncertainties, which is why the target of at least 5,700 is given.)

A 'Summary Appraisal of Sustainable Housing Growth Potential,' which was produced by the Council and attached as an appendix to a report to cabinet dated 1 July 2013, aims to justify why the claimed objective figure of 6,180 cannot be met and why the 5,700 target is appropriate. Notwithstanding other issues which are claimed to constrain development at the main settlements which we do not wish to make comment on, a main identified constraint to meeting the objectively assessed need is the presence of the High Weald Area of Outstanding Natural Beauty (AONB). It is the Council's position that the cumulative implications of further activity and populace in the AONB will impact on its character. This is particularly relevant to the provision for 1,670 dwellings at the Rural Villages. Policy RA1 deals with rural housing provision in further detail; it provides for 1,670 dwellings over the plan period located in accordance with the accompanying settlement distribution, subject to refinement in the light of further investigation via the Development and Site Allocations DPD and/or Neighbourhood Plans.

Although we do recognise that a balance needs to be struck between the provision of much needed housing and the conservation of the AONB, it is our view that a higher level of housing can be accommodated in the rural areas than is planned for under policy OSS1 and subsequently policy RA1 without compromise to the AONB. On 7 May 2013 the Inspector wrote to the Council about the approach that they should be taking in respect of identifying an objective assessment of housing need:

"...the Area of Outstanding Natural Beauty (AONB) is cited by several respondents as a constraint. Paragraph 115 of the Framework indicates that great weight should be given to conserving landscape and scenic beauty in AONBs. It does not, however, include a presumption against development in an AONB and paragraph 28 seeks to support a prosperous rural economy' (our emphasis).

Whilst this letter was sent to the Council in the context of identifying an objective need, its advice is also applicable to the housing provision that results from the objectively assessed need. The Inspector here makes reference to paragraph 28 of the Framework; which seeks to support a prosperous rural economy. This paragraph needs to be read in the context of the Framework as a whole which has a clear focus on sustainable growth and a significant boost in housing supply. It is our view that more sites located in the AONB should be able to come forward and that the overall rural housing figure should be increased to reflect this. This would be more closely aligned to the Council's perceived objective assessment of need and the overall thrust of the Framework to allow sustainable development and foster a large increase in house building.

Moreover, an increase in rural housing would assist in developing 'balanced communities' if it further encourages younger people to live locally. This was a point that was made by officers in their 1 July 2013 Cabinet Report. Indeed such an approach of increasing the supply of housing in rural areas was recommended to the government by the 'Taylor Review of Rural Economy and Affordable Housing' (2008), authored by Lord Matthew Taylor of Goss Moor (also the lead reviewer of the planning guidance which has resulted in the National Planning Practice Guidance). This report states that restrictive planning policies contribute towards small rural villages becoming increasingly unsustainable and unaffordable for those who live and work there and that a large increase in housing supply is needed if this trend is to be reversed.

Conclusion
We consider that the proposed Main Modifications to the Core Strategy are unsound, with specific reference to policies OSS1and RA1. This is because:

* In identifying a starting point for an objective assessment of housing need, the Council have rolled forward the DCLG 2011-based Interim projections until 2028, which is 7 years past their 2021 end period;
* The 2011-based Interim projections represent a period characterised by the economic recession, constrained household formation and mortgage availability and do not paint a picture of what is likely to happen going forward once the economy returns to a state growth;
* Recommendations from the Cambridge Centre for Housing & Planning Research indicate that the 2011-based Interim projections should not be used after 2015; rather a projection which lies somewhere between the 2011-based Interim projections and a projection which represents a 'partial return to trend' scenario (i.e. a trend which gradually returns towards the 2008-based projections from the year 2015) should be used;
* Regardless of the soundness of the claimed objectively assessed need figure, the Coundl's proposed OSS1 housing provision of 5,700 dwellings is an unjustifiably constrained figure;
* When taking into consideration the overall thrust of the Framework and its focus on fostering sustainable development and significantly increasing house building, more sites within the AONB should be allowed for housing and the overall and rural housing figures provided by polices OSS1 and RA1 respectively should be increased to meet the Council's claimed objectively assessed need;
* More rural housing would assist with the Council's strategic objective of developing 'balanced communities' and would respond positively to the issues highlighted by the Matthew Taylor Report in respect of restrictive rural policies contributing towards rural villages becoming unsustainable.

My objections to the Main Modifications relate to:
MOD 2.1 P.6
MOD 7.4 p.31
MOD 7.11 p.34
MOD 12.4 p.80

My objections are as follows:
* The Main Modifications to the plan would make it incompatible with the overall policy. They do not take account of local needs, the allocation is disproportionate in relation to other areas in the district and the numbers do not relect the real situation in terms of additional dwellings in the village.
* The numbers identified in the Modification to Figure 12 is disproportionate and not justified in relation to allocations to other areas in the district.
* The requirement in the Policy to meet local needs and ensure that development is in line with the character and sustainability of services is not reflected in the Modification to the Plan, in relation to Figure 12. Due account has not been made to:
*windfalls
*services in the village - there are no primary school places available in the village, there is no access to medical services, the roads are under severe pressure due to traffic to and from Bexhill to Battle Station (due to poor service on the line from Bexhill), there has already been a fatality, broadband link up is extremely poor due to the village being at the end of the line and the village experiences electricity supply failures quite frequently.

Supporting document Summary Appraisal of Sustainable Housing Growth Potential July 2013 states at item 55 "Officers have had further discussions with Parish Council representatives to positively pursue the scope for additional land releases".
No such consultation took place with Icklesham Parish Council, who have been unsuccessfully trying to get Rother District Councils approval to undertake an affordable housing survey since 2012.
We are concerned that opportunities may be being missed to undertake small affordable housing projects in the Rother villages, because of the lack of support & consultation by Rother District Council.
For this reason we dispute the amended housing figure of 1,670 dwellings in MOD 12.4, as we do not believe that this has been adequately researched and may therefore be understated.

I am a life long resident of Catsfield, my family have lived in the village for several generations and I have previously been Chairman of the Catsfield Parish Council. I attended the parish council meeting on Monday 23rd September.
I object to the main modifications of the Local Plan Core Strategy Document because the number of houses inserted in the document does not reflect local need and will overwhelm the village. The proposed site at the rear of the White Hart Public House is totally unsuitable for large scale development because the only access is onto the main road at a point where there are already four roads joining the main road through the village. There have been numerous accidents around the village centre, one resident was killed, due to the high volume of traffic travelling from Bexhill to Battle and the number of vehicles stopping at the village shops, turning into Church Road to go through to Crowhurst etc etc. The field itself is extremely wet and in an AONB, which we always strived to keep intact and in fact Rother Planning Authority and also Government Inspectors have supported this aim by rejecting previous applications.

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.

Robertsbridge benefits from a good selection of employment and services and REG acts to maintain and improve on the breadth and depth of activities in the village. However evidence suggests that following the largest ever developments in the village during the early 1990s, not a time of recession, the quality and depth of services particularly retail declined considerably. In the years of this recession however the quality and depth of services in the village has increased with new businesses emerging and no net loss of retail. So additional housing development does not connote sustainability.

We believe that what is needed is controlled and sensitive numbers of development occurring recognising that Robertsbridge is better able than many villages to take a share of development. However that share of development must not be an unfair share which prevents assimilation of such into the warp and weft of the village.

It also must be accompanied by an positive upgrading of facilities which will improve sustainability such as better cycle ways, bridle paths and footpaths to assist recreation and tourism, improved medical facilities at the surgery and better facilities for our dentists.

Flooding is a major concern which has not been eliminated by the flood defence work post 2000. Recent flooding which has been serious and affected different parts of the village even parts at elevated positions, needs to be addressed before any further sites and proposals are entertained. It is possible to alleviate flood risk away from the flood plain but it does need proper plans and land set aside so to do.

We also need to remove the various congestion problems in the village if we are to accept more development even the 119 additional dwellings originally envisaged. Congestion results from a number of reasons: on street parking, the use of the village as a shopping centre, the schools on George Hill, the busses serving the Community College, parking as a result of people's desire to avoid paying for parking at the Station car park, the level crossing itself. All of these make for problems currently in the village and even greater numbers of houses will only exacerbate the problem unless many measures are taken before any new development is approved.

More facilities for business needs to be allocated because without that as a backbone the community will lose its sustainability.

We also believe that RDC have been identifying sites prematurely otherwise they would not have any basis at all for suggesting a further increase in Robertsbridge numbers. Surely that is for the site selection part of the plan process, not here where it should be a matter of putting down principles of policy rather than specific numbers. We do not believe this aspect of the policy is legally compliant.

This modifications sets to find ways of increasing numbers in villages which for Rother means villages in AONB, so the NPPF criteria apply. It does not appear than RDC have applied this in simply increasing numbers so the higher original allocations get more. RDC have effectively put the cart before the horse and studied and identified specific sites in the villages where numbers have been increased. It seems wrong in principle to have an overall policy which effectively prejudges any site selection process which should happen afterwards, as these individual village numbers are so specific and must perforce relate to identified sites by RDC. Therefore the whole principle of identifying numbers for each village is clearly unsound whether they are stay the same in the modification or in many cases now an increased number.
In light of the increases suggested for certain villages the only possible way to achieve such numbers would be to create large estates which are totally out of keeping with the principles of AONB let alone environmental and cultural constraints within individual villages.

Rural Areas - Housing in Villages
Proposed Modification Nos. MOD -12.1, 12.2 and 12.4

1. These representations (TCPS Representations No. 2), relate to proposed modification numbers MOD 12.1, 12.2 and 12.4 and should be read in conjunction with representations (TCPS Representations no. 1) made in relation to proposed modification numbers 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15, which make the case that the Plan's housing requirement should be increased from "at least 5,700 dwellings" to "at least 6,200 dwellings': This would then also require consequential changes to paragraph 12.13 (Modification 12.1).

2. The Council's revised housing figure now acknowledges that there is more scope than previously considered for meeting the assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (as well as potentially on the Hastings fringes), there is also a need to increase the provision in (and adjoining) rural settlements so as to make an important contribution to the assessed need. MOD 12.4 proposes to amend Part (v) of Policy RA1 to increase the housing requirement in villages from 950 - 1,000 dwellings (as set out in the Proposed Submission Version of the Plan) to 1,670 dwellings.

3. Modified paragraph 7.41 (MOD 7.11) states 'the housing provision seeks to maximise the contribution that villages can make to sustainable growth without prejudicing their individual character and amenities, as well as those of their shared, for the most part High Weald AONB setting". In terms of the housing figures proposed however, modified paragraph 7.30 (MOD 7.6) 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 purpose of Plan making. These will be further assessed as part of site a/locations/neighbourhood planning processes".

4. Thus, notwithstanding the proposed modified figure of "1,670 additional dwellings" now inserted into Policy RA1(v) (MOD 12.4), there may well be scope to increase supply within and around villages once potential sites come forward as part of the subsequent site allocations/neighbourhood planning stage. Indeed, the revised (June 2013) SHLAA estimates that some 6,180 dwellings can be accommodated on potentially suitable, available and deliverable housing sites within the District, and there may well therefore, be scope to increase the potential for adding to housing in and around villages over and above 1,670 additional dwellings as part of a site allocations process.

Distribution of Rural Housing Allocations
Proposed Modifications nos. MOD 12.4 and 12.5

1. These representations (TCPS Representations No. 3), should be read in conjunction with representations submitted in response to proposed modification numbers 12.1, 12.2 and 12.4 (TCPS Representations no. 2). These representations make the case that the draft Policy RA1(v) (MOD 12.4) should be further modified to refer to "at least 1,670 additional dwellings".

2. Although not a proposed modification, the draft policy also states that new housing allocations "will be located in accordance with Figure 12, subject to refinement in light of further investigations by the Development and Site Allocation DPD and/or Neighbourhood Plans". In light of the Council's recognition of the need to increase the housing requirement generally in the District (compared to the submitted draft version of the Plan) and given that the Council has more recently accepted that additional sites might be identified as part of the Site Allocations/ Neighbourhood Plan stage, the purpose and function of Figure 12 is now questionable and should be deleted with further modifications to Policy RA1(v) as required. If retained however, it should at the very least be regarded as providing illustrative housing numbers only for each settlement in relation to column 3 (allocations) and column 4 (potential new sites).