4. Housing

Showing comments and forms 1 to 4 of 4

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24094

Received: 03/12/2018

Respondent: Mr Francesco Forte

Agent: Plainview Planning Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Section 4 (housing) is not sound. The DaSA has been prepared to be in conformity with the Core Strategy, which is based on out of date evidence and no longer compliant with national policy.
The Planning Inspector assessing the Core Strategy clearly felt the Objectively Assessed Need (OAN) should be regularly reviewed.
To date, the most recent evidence is still the 2013 SHMA. The lack of an updated version runs contrary to advice provided by the Inspector.
The Council's absence of an up to date evidence base and lack of a Core Strategy review runs contrary to national policy.
Using the standard method calculation set out in the NPPF, it is clear that the District requires a significant uplift in housing provision, to 675 per annum. This should trigger a review of the Core Strategy, with implications for the spatial strategy for the whole District.
The sites within the DaSA do not go far enough to meet the OAN and there is a need for significantly greater growth than set out. Rather than pursue the DaSA, the Council needs to undertake a full review of its Core Strategy and set out all sites required to deliver its full OAN.

Full text:

Section 4 of the DaSA Local Plan, which relates to housing, is not sound as it has not been positively prepared, is not effective and is not consistent with national policy.
1.2 The fundamental issue with the DaSA is that it forms Part 2 of the Core Strategy and has been prepared to be in conformity with it, yet the Core Strategy was adopted four years ago and is based on evidence that is now over six years old and it is no longer compliant with national policy.
1.3 The DaSA should have represented an opportunity for the Council to provide a review of the Core Strategy and update the elements that are out of date, such as the housing requirement.
1.4 These points will be explained in more detailed below.
Core Strategy Background
1.5 The Objectively Assessed Need (OAN) that informed the housing requirement was based on 2011-based household projections. This produced an annual housing
requirement of 338 dwellings per annum (Policy OSSS1) over the 17-year plan period.
1.6 The Planning Inspector assessing the soundness of the Core Strategy stated in
paragraph 36 that:
36. By comparison, the SHMA 2013 notes that the 2008-based projections as used in the 'How Many Homes' model suggests an annual increase in households of 584 in Rother, compared to 338 households per annum for the 2011-based revised
projection. This is an indication that if the economy improves significantly, it may lead to higher levels of housing need and the Council will need to keep this under review to ensure that the CS is kept up to-date. However, I am satisfied that the SHMA 2013 is an acceptable assessment of housing need to inform the strategy at the present time, albeit that the figure of 13,041 across the HMA may represent the lower end of a range of potential outcomes.
1.7 The Planning Inspector clearly felt that based on the evidence available, the 338 figure represented the OAN at that time, but was also clear that a precautionary approach was required to ensure that the Core Strategy remained up to date. This would involve regularly reviewing the OAN for the District.
1.8 To date, the most recently produced SHMA or OAN is still the 2013 SHMA considered by the Planning Inspector assessing the Core Strategy. This evidence is inherently out of date as it is based on 2011-based household projections and the lack of an update version also runs contrary to the advice provided by the Planning Inspector.
National Planning Policy
1.9 Paragraph 31 of the NPPF states that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence. It states that this should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.
1.10 Paragraph 33 of the NPF states that policies in local plans and spatial development strategies should be reviewed to assess whether they need updating at least once every five years, noting that reviews should be completed no later than five years from the adoption date of a plan, and should take into account changing circumstances affecting the area, or any relevant changes in national policy. It also states that strategic policies will need updating at least once every five years if their applicable local housing need figure has changed significantly.
1.11 Regulation 10A of the Town and Country Planning (Local Planning) (England)
Regulations 2012, makes it a requirement to review all local plans every five years.
Critically, the review should not commence at the five-year mark, but be completed by then.
1.12 The Core Strategy was adopted four years ago and to date there is no evidence that the Council has undertaken a review of its strategic housing policies, as they have not updated any of the housing evidence that underpinned by the Core Strategy.
1.13 The Council's absence of an up to date evidence base and lack of a Core Strategy review runs contrary to national policy. It is not realistic that they will have completed this exercise within the 12 months.
The Standard Method
1.14 Paragraph 60 of the NPPF states that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.
1.15 The PPG states:
When should strategic policy-making authorities assess their housing need figure for
policy-making purposes?
Strategic plan-making authorities will need to calculate their local housing need figure at the start of the plan-making process. This number should be kept under review and revised where appropriate.
The housing need figure generated using the standard method may change when
National Household projections and affordability ratios are updated by the Office of
National Statistics and this should be taken into consideration by strategic policy making authorities.
Paragraph: 008 Reference ID: 2a-008-20180913
1.16 It also states:
For how long can an estimate of local housing need be relied upon once a plan is
submitted to the Planning Inspectorate?
Local housing need calculated using the standard method may be relied upon for a
period of 2 years from the time that a plan is submitted to the Planning Inspectorate
for examination.
Paragraph: 016 Reference ID: 2a-016-20180913
1.17 Using the standard method calculation for Rother District, it is clear that the District requires a significant uplift in housing provision to meet the OAN.
- Using 2016-based household projections for England, Rother District
has a requirement for 4,962 dwellings or 496.2 per annum (43,297 in
2018 and 48,259 in 2028).
- The authority's workplace-based affordability ratio is 11.04
- The adjustment factor is 0.44
- Minimum annual local housing need figure = (1 + adjustment factor) x
projected household growth
- Minimum annual local housing need figure = (1 + 0.44) x 4,692
- The resulting figure is 6756.48 or 675.7 per annum
1.18 The 675.7 minimum housing need figure is double the Core Strategy figure and in itself should trigger a review of the Core Strategy, which would have implications for the spatial strategy for the District as a whole.
Planning Implications
1.19 Whilst we accept that the Council needs to deliver strategic sites to meet the housing growth, the sites within DaSA do not go far enough to meet the OAN and there is a need for significantly greater growth than set out.
1.20 Rather than pursue the DaSA as Part 2 of the Core Strategy, the Council needs to undertake a full review of its Core Strategy and set out all sites required to deliver it full OAN.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24141

Received: 05/12/2018

Respondent: Mrs Angela Kinzett

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

I object to the amount of housing in this area. I understand that housing is required and that the government sets targets. However, areas along the south coast are only able to expand to the north side of towns and should therefore have reduced quotas. Green fields which identify the area are being lost to estate after estate. The shopping areas of Hailsham, Bexhill and Sidley are in need of significant regeneration to promote town living and in the case of Bexhill to promote more tourism . There seems to be little regard for areas of deprivation, for people who want to live in the countryside or for farmers. Farm land is being gobbled up, youngsters of today are more familiar with food from takeaways than food from farms. Developers are making money because they have no regard for the quality of life in areas they propose for development. Is consultation with the local population tokenism? So many people say, 'It's a done deal! I hope not.

Full text:

I object to the amount of housing in this area. I understand that housing is required and that the government sets targets. However, areas along the south coast are only able to expand to the north side of towns and should therefore have reduced quotas. Green fields which identify the area are being lost to estate after estate. The shopping areas of Hailsham, Bexhill and Sidley are in need of significant regeneration to promote town living and in the case of Bexhill to promote more tourism . There seems to be little regard for areas of deprivation, for people who want to live in the countryside or for farmers. Farm land is being gobbled up, youngsters of today are more familiar with food from takeaways than food from farms. Developers are making money because they have no regard for the quality of life in areas they propose for development. Is consultation with the local population tokenism? So many people say, 'It's a done deal! I hope not.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24320

Received: 06/12/2018

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Although the DaSA sets out detailed policy considerations for new housing development including External Residential Areas (Policy DHG7), Extensions to Residential Gardens (Policy DHG8), Extensions, Alterations and Outbuildings (Policy DHG9), Annexes (Policy DHG10) and Accesses and Drives (Policy DHG12), no policy guidance is provided for those who might wish to construct a replacement dwelling and in particular, within countryside location outside development boundaries.

A new Policy should be introduced to provide suitable detailed guidance for those intending to construct replacement dwellings.

Full text:

Although the DaSA sets out detailed policy considerations for new housing development including External Residential Areas (Policy DHG7), Extensions to Residential Gardens (Policy DHG8), Extensions, Alterations and Outbuildings (Policy DHG9), Annexes (Policy DHG10) and Accesses and Drives (Policy DHG12), no policy guidance is provided for those who might wish to construct a replacement dwelling and in particular, within countryside location outside development boundaries.

A new Policy should be introduced to provide suitable detailed guidance for those intending to construct replacement dwellings.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24521

Received: 06/12/2018

Respondent: Bexhill Heritage

Number of people: 2

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Suburban Redevelopments - Policy omission - Need for new policy

There is a noticeable trend towards the replacement of individual dwellings by flats.

This is not new and is inevitable. Its effects have so far been moderate. As the process gathers pace its townscape effects are becoming more adverse even with the most attentive development management regime the Council can put in place.

Too often the redevelopment will result in the gardens and vegetation which softens suburban areas giving way to three and four storey buildings seeming to fill the plots and with car parking occupying much of the remaining area.

Existing development management policies, and those proposed in the plan are important in curbing the worst aspects of such redevelopments but a general policy which guides developers, aids Councillors and reassures residents would further help - the following is suggested -
"The redevelopment of one or two dwellings in sections of road largely comprising
one and two storey dwellings will normally be limited to three storeys."

Full text:

Development And Site Allocations Local Plan

Representations of Bexhill Heritage
Bexhill Heritage is a new, locally-founded and based charitable organisation dedicated to the care and protection of the heritage built environment of the town. Despite its recent creation the charity has already attracted over 200 members, some professionally qualified in planning, architecture or building surveying. Bexhill Heritage has already carried out three high profile and practical projects, and has reviewed all the planning applications submitted to the Council in 2018 within Bexhill.

We have reviewed the current document and believe that the plan has been thoroughly and professionally prepared. We understand it is to be assessed by an independent person appointed by the Planning Inspectorate. We wish to make the following representations on the soundness of the plan, all of which are specific to Bexhill-

1) Lack of height restriction policy town centre and sea front

Whilst there has long been a recognition and appreciation by the Council and residents of the special qualities of the sea front and town centre, and a significant part of the town centre is covered by a Conservation Area designation, such recognition has proved insufficient. The only whole site redevelopments carried out in the last ten years have resulted in buildings which are too high to relate satisfactorily to their surroundings and they thus detract from the appearance of the vicinity. These are the eight storey buildings at the seaward end of Sackville road and in Sea road, the flats which are known as South Beach.

Thus it is clear that a specific policy is needed to guide developers, landowners, Councillors and staff and to give reassurance to the public, which restricts new buildings to a more reasonable maximum height both in the town centre and on the sea front, much of which is outside the Conservation Area.
The following policy is suggested -

"Within the Town Centre and on the sea front the redevelopment of sites will be limited to a height commensurate and compatible with adjacent buildings and the area within which the site lies. This will generally mean a maximum of four storeys".

2) Town Centre - need for policy amendment - Social Zones

The Council and the public have for many years been concerned that the Town Centre is blighted by the dominance of vehicles to the detriment of pedestrians and cyclists but little has been done to address this. There are changes afoot and the plan recognises this in para 9. 154 and mentions the potential for Social Zones. However. schemes for management / parking must have at their core the need for such social zones where pedestrians be they residents, visitors, shoppers can take pleasure in their activities freer from accompanying worries about moving traffic, dangers, noise and pollution. However, policy 8X12 - Bexhill Town Centre does not sufficiently recognise this and should be strengthened.

Accordingly the following amendment is suggested to paragraph three of BEX12 -
Insert "social zones and" after "provide" and instead of "will be supported" replace by "will be implemented".

3) Suburban Redevelopments - Policy omission - Need for new policy

There is a noticeable trend towards the replacement of individual dwellings by flats.

This is not new and is inevitable. Its effects have so far been moderate. As the process gathers pace its townscape effects are becoming more adverse even with the most attentive development management regime the Council can put in place.

Too often the redevelopment will result in the gardens and vegetation which softens suburban areas giving way to three and four storey buildings seeming to fill the plots and with car parking occupying much of the remaining area.

Existing development management policies, and those proposed in the plan are important in curbing the worst aspects of such redevelopments but a general policy which guides developers, aids Councillors and reassures residents would further help - the following is suggested -
"The redevelopment of one or two dwellings in sections of road largely comprising
one and two storey dwellings will normally be limited to three storeys."

4) Site Allocations - Land off Spindlewood Drive - Objection

Bexhill Heritage has submitted objections to the current application at this site on heritage grounds. These relate to adverse effects of the new dwellings on the setting of the "historic medieval farm complex" (para 9. 100), namely Barnhorn Manor and to the related gateway features fronting Barnhorn Road. We maintain these objections, the "care" required by the text is not reflected in the Figure 29 Detail Map.

5) Site Allocations - Land at Gulliver's Bowls Club Knole Road - Reasons Unsound Alteration Needed

It is not clear why this site is specifically allocated for sheltered housing. No such specific allocation has been placed on a site which, in or view, is far more suitable for sheltered housing given that it is close to the town library and a large supermarket - land south of Terminus Road (policy BEX8).

At Knole Road the specific allocation reduces the possibility of a development that sufficiently reflects the need for a high quality building appropriate to the setting of the listed buildings opposite.

Policy BEX5(v) calls only for the development to "not adversely affect the character of the area or the setting of the listed terrace to the south". This is insufficiently robust and BEX5(v) should be altered to read -

(i) "some 40 flats are provided of which 30% are affordable"

(v) "the design of the scheme with a maximum of 4 storeys should be of the
highest architectural quality".

Site Allocation BEX6 - land adjacent to 276 Turkey Road - amendment

Here, for the first time, at para 9.72 is a specific reference made to the "potential future redevelopment of the Cemetery Lodge site". The implication of this wording is that there is the possibility of Cemetery Lodge being demolished. We are entirely opposed to the demolition of this fine Edwardian building which our surveys have proved to be in good condition. We therefore seek the deletion of the offending final
sentence of para 9.72.

We trust the Inspector will take due notice of our representations and afford Bexhill Heritage the opportunity to appear at the Examination hearing to explain and expand upon these further, and respond to questions.