MOD 12.1

The revisions to paragraph 12.13 are supported because they are 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). Further, the increased allocation for the 'villages' is supported as this acknowledges that the villages, especially the larger Rural Service Centres (such as Robertsbridge) have a greater capacity to absorb additional development than the draft plan has previously recognised.

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.

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.