MOD 19.1

Showing comments and forms 1 to 5 of 5

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21370

Received: 25/09/2013

Respondent: Northiam Parish Council

Representation:

NPC is concerned that the proposed release of land in Northiam cannot be balanced with supply of jobs in area. In addition the proposed release of a high proportion of Northiam's full plan quota of new dwellings on 2 sites will result in a high number of affordable units in a relatively short period which will result in a many of these dwellings being occupied by people with no local connection to the village. The village has suffered in the past with this allocation policy.

Full text:

Northiam Parish Council is concerned that the modification regarding the need to phase housing land releases to ensure a balance with the supply of jobs in the area does not meet RDC Soundness test for the following reasons:
Under the ongoing site idetification process RDC is intending to release two sites in Northiam which will provide approx 80% of the proposed village quota for the whole plan period within the first 3 years. The PC is of the opinion that a balance between that and local jobs would be impossible. It is also concerned that creating a high number of affordable units in a relatively short period of time would result in these not being allocated to those with local connections but to house those from other areas of the district.

Support

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21428

Received: 27/09/2013

Respondent: Cllr Susan Prochak

Representation:

This is a very strong indication to developers to allow assimilation of new developments and to not only supply housing, but also much needed employment.

Full text:

This is a very strong indication to developers to allow assimilation of new developments and to not only supply housing, but also much needed employment.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21454

Received: 27/09/2013

Respondent: Mr A G L Anslie

Agent: Montagu Evans

Representation:

The proposed modification is not consistent with national planning policy as it has the capacity (on a seemingly arbitrary basis) to constrain the delivery of sustainable housing development identified in the Core strategy and required by the policies of the Framework.

Full text:

Policy IM3 has been amended to include a reference at clause ii to ensure housing delivery is phased to ensure a balance with the supply of jobs.

This policy has no justification and is not founded on an evidence base. It makes no provision for the varying economic profiles of the different settlements in the district and does not take account of the need to maintain a supply of specific deliverable sites annually on a rolling five year basis - regardless of job creation - as required by the National Planning Policy Framework (the Framework).

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 Framework. The appropriateness of the Council's housing target for the district has already been assessed in the light of economic factors including job creation.

To seek to frustrate residential development coming forward in accordance with the requirements of the development plan as required by paragraph 47 of the Framework is contrary to the overarching theme of national planning policy 'to boost significantly the supply of housing'. Further, this policy has the potential to put the Council at risk of failing to identify or deliver deliverable sites sufficient to provide five years worth of housing against their housing requirements (with an additional 5% moved from later in the plan period). This policy could result in unplanned development occurring across the district, approved in the absence of a five year land supply, which may have a greater propensity to undermine the Council's planned economic strategy.

The proposed modification is not therefore consistent with national planning policy as it has the capacity (on a seemingly arbitrary basis) to constrain the delivery of sustainable housing development identified in the Core strategy and required by the policies of the Framework.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21468

Received: 27/09/2013

Respondent: Persimmon Homes South East

Agent: JB Planning Associates Ltd.

Representation:

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.

Full text:

This proposed modification assumes 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. This proposed modification should therefore be deleted.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21561

Received: 27/09/2013

Respondent: Marchfield Strategic Land Ltd

Agent: JB Planning Associates Ltd.

Representation:

Whilst the District Council's desire to encourage and provide for employment growth is understood and appreciated, the inference given by proposed Main Modification that the supply of jobs 'in the area' is obstructive, contrary to various aspects of National Planning policy as set out i the NPPF - for example the presumption in favour of sustainable development set out in paragraph 14, would not be effective in delivering growth - indeed it would act as a constraint to development, and is entirely unjustified by any evidence. Furthermore, the interpretation and application of the proposed Modification could render it unlawful.

Full text:

Whilst the District Council's desire to encourage and provide for employment growth is understood and appreciated, the inference given by proposed Main Modification that the supply of jobs 'in the area' is obstructive, contrary to various aspects of National Planning policy as set out i the NPPF - for example the presumption in favour of sustainable development set out in paragraph 14, would not be effective in delivering growth - indeed it would act as a constraint to development, and is entirely unjustified by any evidence. Furthermore, the interpretation and application of the proposed Modification could render it unlawful.