Policy OVE1: Housing supply and delivery pending plans

Showing comments and forms 1 to 8 of 8

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 23996

Received: 20/11/2018

Respondent: Chris Horne

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Site allocations simply to meet the target build and taking no account of local infrastructure, employment opportunities and services is simply wrong.
Development yes, if it is sustainable.
This process appears to be driven by landowners seeking their own goals and not by reasoned planning processes?

Full text:

Site allocations simply to meet the target build and taking no account of local infrastructure, employment opportunities and services is simply wrong.
Development yes, if it is sustainable.
This process appears to be driven by landowners seeking their own goals and not by reasoned planning processes?

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24227

Received: 07/12/2018

Respondent: Burwash Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

The section which suggests that planning applications will be favourably considered if they contribute to the housing target until such time as Neighbourhood Plans is in force should be removed. This will only encourage developers to rush through planning applications in order to predate Neighbourhood Plans.

Full text:

The section which suggests that planning applications will be favourably considered if they contribute to the housing target until such time as Neighbourhood Plans is in force should be removed. This will only encourage developers to rush through planning applications in order to predate Neighbourhood Plans.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24265

Received: 07/12/2018

Respondent: Executors of the Estate of the late Mr F. Rumsey .

Agent: Mr Edward Handley

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Land at Sandhurst Lane, Bexhill on Sea, called Pond Field -
should be included for residential development.

We argue that the figures adopted originally by Rother within the Core Strategy Local Plan for housing provision were (and still are) expressed as an "at least' number, it is incumbent on the authorities to be proactive in seeking to identify opportunities for additional housing development and this should remain the case for Rother.

The Council have not met their annual housing supply requirements and therefore have taken account that significant weight be attributed to the benefits of new housing.

We assert that the land at Sandhurst Lane as shown in this documentation would comply with the principles outlined within emerging Policy OVE1 and would offer an opportunity to assist in exceed the provision requirements of the current Plan submission following the documented under provision of recent years.

Full text:

Land at Sandhurst Lane, Bexhill on Sea, called Pond Field - This land should be included for residential development

A map was included as part of the submission and can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=31119

National Policy Context and Housing requirements.
Paragraph 119 of the NPPF 2018 states that 'Local planning authorities, and other plan making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs' This requirement follows from the NPPF 2012 which sought to maximise development potential.
The most recent 5 year housing land supply position for Rother (set out by the Local Plan Annual Monitoring Report April 2018) states that RDC have a land supply of 3.44 years in place. The Council accepts that the under-delivery against housing requirements amounts to a 'persistent under-delivery of housing' hence, a 20% buffer should and in line with paragraph 47 of the NPPF 2012 has been applied to the Council's requirement.
Local Housing Needs
The Council consider that through the implementation of sites now approved and allocated within the DaSA Plan the trajectory for development will ensure that future completions will supplement the persistent under delivery when sites come forward. However, this takes no account of external changes to demographics or policies in the future and whilst there is now the necessity to review a Local Plan every five years it is forwarded that the site should be included within the current Plan submission.
The last full assessment of housing requirements is set out in the Hastings and Rother Strategic Housing Market Assessment: Housing Needs Assessment dated June 2013. This informed the subsequent Core Strategy Local Plan requirement to deliver 'at least 5, 700 new homes' over the 17 year plan period.
We argue that given that as the figures adopted originally by Rother within the Core Strategy Local Plan for housing provision were (and still are) expressed as an "at least' number, it is incumbent on the authorities to be proactive in seeking to identify opportunities for additional housing development and this should remain the case for Rother.
To further emphasize the need for greater provision we are also aware that the Council's Local Plan Monitoring Report April 2018 confirms that they have not met their annual housing supply requirements and therefore have taken account that significant weight be attributed to the benefits of new housing.
In setting out the reasoning for the housing provision in forthcoming years Paragraph 2.36 of
the Monitoring Report April 2018 confirms that 'Therefore, the Council resolved that pending the DaSA Local Plan and Neighbourhood Plans, sites that accord with the Core Strategy's overall development strategy and are suitable, deliverable and otherwise contribute to sustainable development, including circumstances where they are not within a development boundary, be considered favourabl '(Our emphasis) As such we welcome that this admission that housing sites that come forward should continue to be viewed favourably is acknowledged within the reasoning behind the 'Overview' Policy which refers to housing targets and provision - Policy OVE1: Housing supply and delivery pending plans.
'In view of the fact that the annualised housing requirement has not been achieved to date and that housing delivery is likely to not "catch up" on present projections, it is considered appropriate to not only have a margin of over-provision, particularly in Bexhill where there is a high reliance on a strategic site, but also to avoid unduly deferring the identification of suitable sites and to ensure that planning permissions continue to come forward in a timely manner.'
The pre-amble confirms that the historic under-provision is noted and that other sites brought forward should also be considered favourably subject to complying with other Policies. With regard to housing in settlements the secondary element of Policy OVE1 states that:-
.... planning applications will be favourably considered for development proposals in those settlements where:
(i) they contribute to meeting the housing target for that settlement and accord with the relevant spatial strategy; and
(ii) the site and development proposals are otherwise suitable having regard to other
relevant policies of the Core Strategy, including the considerations in OSS2 and OSS3, and of this Plan.
We assert that the land at Sandhurst Lane as shown in this documentation would comply with the principles outlined within emerging Policy OVE1 and would offer an opportunity to assist in exceed the provision requirements of the current Plan submission following the documented under provision of recent years.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24299

Received: 07/12/2018

Respondent: Mr and Mrs P Rigby

Agent: Jennifer Owen & Associates Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The housing requirement on which the DaSA is predicated is based on the Core Strategy which is based on ONS population predictions for 2011. The CS Inspector's conclusion that the CS was sound in 2014 was based on the premise that the Council would keep this matter under review. This has not happened and consequently the DaSA cannot be found sound in respect of housing need.
Para 8.17 notes the annualised housing requirement has not been achieved and that housing delivery is unlikely to catch up on present projections. Whilst a margin of overprovision is stated as being appropriate this is not apparent in Policy OVE1 which merely repeats the CS requirement which is inadequate for the reasons stated above.
The Council have admitted to a persistent under supply of housing and whilst the DaSA contains site allocations these have been in the public domain for a number of years and have not come forward for development. This is evidence that the Council's choice of sites for allocation is unsustainable. Consequently in accordance with NPPF 2012 an appropriate increase in net additional homes over the period to 2028 is 20% taking the total in policy OVE1 from 5,700 to 6,840.

Full text:

The housing requirement on which the Development and Site Allocation (DaSA) Local Plan is predicated is based on the Core Strategy (CS) which was approved in 2014 but is based on earlier data, in particular the ONS population predictions for 2011. Planning Practice Guidance is quite clear that the ONS 2014 projections are those that should be used to assess housing need. The CS Inspector having considered evidence from the RTPI Research Report No1 (Jan 2014) advised that if the economy improved significantly it could lead to higher levels of housing need. The economy has improved and the publication of the 2014 ONS population data together with the Governments guidance that this should now form the basis of housing need assessment has significantly undermined the CS. The CS Inspector's conclusion that the CS was sound in 2014 was based on the premise that the Council would keep this matter under review. This has not happened and consequently it leads to the finding that the DaSA cannot be found sound in respect of housing need because the failure to review the housing requirement leads to an ineffective plan which is not justified (see Objective 1 of the SA) and does not comply with national policy as set out in NPPF.

Para 8.17 Contains an admission that the annualised housing requirement has not been achieved and that housing delivery is unlikely to catch up on present projections. Whilst a margin of overprovision is stated as being appropriate this is not apparent in Policy OVE1 which merely repeats the CS requirement which is inadequate for the reasons stated above. Whilst the words "at least" are noted in policy OVE1 this is inadequate because it is not backed up by additional allocations or policy wording to deal with the current situation where housing 5 year land supply is significantly deficient (3.44 years at April 2018) and there is a persistent under supply of dwellings being built.

The Council have admitted to a persistent under supply of housing and whilst the DaSA contains site allocations these have been in the public domain for a number of years and have not come forward for development in an area where the Council has admitted that planning permissions would have to be granted on unallocated sites because of the failure to be able to demonstrate a 5 year housing supply. This is evidence that the Council's choice of sites for allocation is unsustainable. Consequently in accordance with NPPF 2012 para 47 an appropriate increase in net additional homes over the period to 2028 is 20% taking the total in policy OVE1 from 5,700 to 6,840. This should be seen as an interim measure whilst the Council fully reviews the CS which is likely to see an increased housing requirement significantly in excess of 20%.

Similar changes will also need to be made to the SA which is also predicated on the CS.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24334

Received: 07/12/2018

Respondent: Beaulieu Homes (Southern) Ltd

Agent: Bell Cornwell

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The DaSA is being prepared as a 'daughter document' to the Core Strategy, 'filling in the gaps' left by the Core Strategy. It would have been a more pro-active approach to prepare a comprehensive Local Plan, starting from scratch and using an up to date assessment of housing need. This plan will be swiftly out of date.

The Council should be seeking to boost supply in response to the Government's new method for calculating housing need. The published information for Rother shows a housing need of 469 per annum between 2016 to 2026, based on the application of the proposed formula. The fact that Rother are not using this information is a potential issue of soundness in terms of the consistency of the emerging plan with the NPPF.

To avoid this issue, the Council should add some flexibility into the housing supply to demonstrate a willingness to proactively boost supply. This should include revising the proposed allocation BEX11 to reflect its potential as a mixed-use site including residential development of up to 54 dwellings, plus sports provision.

Policy OVE1 (Housing Supply and Delivery) is unsound as it is not positively prepared or consistent with national policy.

Full text:

07 December 2018

Dear Sirs,

Representations to the Rather District Council Development and Site Allocations Local Plan: Proposed Submission (Regulation 19)

We represent our client, Beaulieu Homes Southern Limited. Our client has been the owner of the former Sidley Sports Ground, Glover Lane, Bexhill since 2015 and is currently appealing a refusal against the redevelopment of the site for a mixed use including both housing and the re-provision of sports facilities for the community.

We have a number of submissions to this important, regulatory consultation on the Rother Site Allocations Local Plan, and focus these representations around the tests of soundness and legal compliance, as is necessary at this stage of the process.

We structure our representations as follows:

Background information on the recent history of the Sidley Sports Ground and the technical work that has been carried out to confirm its deliverability.

Comments on the Council's processes including their approach to meeting housing need, and the need for additional housing to be added to the Plan for flexibility.

Comments on the evidence base, including the Playing Pitch Strategy and the Feasibility Study that was carried out to inform the Council's future policy on the former Sidley Sports Ground.

Advice to the Council about an appropriate and justified policy direction on the former Sidley Sports
Ground.

Background

The former Sidley Sports Ground has been in the ownership of our client since 2015. This was the ground of Sidley Sports and Social Club and was previously home to Sidley United Football Club and Sidley Cricket Club. The club was privately owned and run, rather than in any community use. The site has been vacant since 2013 when Sidley Sports and Social Club (a Private Members Club) went into administration as it was not financially viable. The pitch was also of very poor quality, meaning that matches were called off due to the pitch being waterlogged. Since the Private Members Club went into administration, there have been ongoing issues of vandalism and security on the site, which have led to security fencing being erected.

Our client's most recent application at the site was in outline form, with all matters reserved for
subsequent approval. The application was for the change of use and development of part of the existing Sidley Sports Ground to residential development for up to 54 dwellings, together with the provision of a replacement sports pitch which is level and properly drained, with laid out car parking and space for a future club house and changing rooms. Whilst the site is in outline form, it was accompanied by indicative layout plans to give information about how the site could be delivered and to show that what was proposed by the application was deliverable on site. However, there is considerable flexibility to respond to other evidenced requirements through any reserved matters applications.

The site is proposed to be accessed off Glovers Lane. The application was informed and supported by technical reports and studies.

The application was refused in mid-2018 and in response to this refusal, we have lodged an appeal on behalf of our client.

Housing Numbers

The Development and Site Allocations Local Plan is being prepared as a 'daughter document' to the adopted Rother Core Strategy and the approach to the Plan is that of a 'filling in the gaps' left by the Core Strategy than anything more fundamental. Whilst this is one approach to the production of Local plan documents it is not the most positive one. It would have been a more pro-active approach to prepare a comprehensive Local Plan, starting from scratch and using an up to date assessment of housing need. The emerging Plan just seeks to deliver the housing requirement set out in the Core Strategy. This sets out that the housing development target for the District as a whole is for at least 5,700 new homes to be built over the plan period, which runs from 2011-2028. The majority of these (approximately 3, 100) are to be at Bexhill. Assuming that the emerging Plan has the same time period means that it does not even cover a ten-year period and will be swiftly out of date.

In terms of the number, this is based on the Council's Strategic Housing Market Assessment (SHMA) update from 2013. Whilst this identified an objectively assessed housing need for Rother District of 6,180 dwellings to 2028, the Council chose to reduce this, citing environmental factors and that this number would, in any case be a boost to what was being provided previously.

In any case, this number is now out of date. The Council should be seeking to boost supply in response to the Government's new method for calculating housing need. The published information for Rother shows a housing need of 469 per annum between 2016 to 2026, based on the application of the proposed formula. The NPPF sets out the Government's dear objective of significantly boosting the supply of homes (para 59) and goes on to set out in paragraph 60 that the standard method for calculating need should be used unless there are 'exceptional circumstances'. The fact that Rother are not using this information is a potential issue of soundness in terms of the consistency of the emerging plan with the NPPF. To avoid this issue, the Council should add some flexibility into the housing supply to demonstrate a willingness to proactively boost supply. This should include revising the proposed allocation BEX11 (Land at Sidley Sport and Social Club, Bexhill) to reflect its potential as a mixed-use site including residential development of up to 54 dwellings, plus sports provision.

On this matter our view is that policy OVE1 (Housing Supply and Delivery) is unsound as it is not positively prepared or consistent with national policy.

Approach towards Bexhlll

The Council seeks to focus development in Bexhill, setting a requirement of 3,100 dwellings to be built in the settlement between 2011 to 2028. We support the focus of growth to Bexhill, as a highly sustainable settlement. The emerging Plan allocates development to the town, both within the town and on the edge of town, specifically three linked sites to the north of the town. However, there is scope to increase the housing provision in the Plan, as we have set out above, and one way in which to do this is to focus on sustainable opportunities within the existing settlement, such as our client's site at the former Sidley Sport and Social Club in the town. This site lies within the existing built-up area and is surrounded by medium density residential development, with good accessibility to services and facilities. Additional development in this location would avoid impacts on the protected landscape of the High Weald AONB, which covers substantial parts of the District, whilst providing much needed housing.

The Council sets out that there is a need to safeguard existing sports facilities in Bexhill, stating, in paragraph 9.14 of the Plan that opportunities for new playing pitches within Bexhill are limited due to the availability of land and the topography of the town. Policy BEX10 for Northeye provides an opportunity to provide new playing field provision alongside the redevelopment of the site; however, there is scope for additional opportunities for new pitch provision to take place as part of other site allocations on the edge of Bexhill. For example, we note that policy BEX4 allocates land at the former high school site and Drill Hall, Down Road, Bexhill, for a mixed use development creating a 'leisure destination'. The policy is currently top level and there appears to be scope to use this facility as a mechanism for the provision of additional high-quality sports pitches.

We have assessed that chapter 9 of the Plan is unsound: the approach towards Bexhill is insufficiently positive as it does not provide enough housing, it is not also effective as parts of the chapter are not deliverable (specifically BEX11).

Affordable Housing

Policy DH61 sets out the proposed approach to the provision of affordable housing. We support the principle of the policy, however to make an effective contribution to addressing the housing needs of the District, the overall number of housing allocations should be increased, in order to enable the delivery of affordable housing.

In terms of our client's site, criterion (i) of the policy applies, whereby 30% on site affordable housing must be provided on schemes of 15 or more dwellings (subject to viability). The allocation of the former Sidley sports and social club for mixed use would contribute to meeting the high requirements for affordable housing in the District by the provision of a greater than required by policy number of affordable homes.

Sustainability Appraisal

We have also assessed the Council's Sustainability Appraisal. This includes summaries of the assessments of site options and proposed policies including, as Appendix 4, an assessment of the site policy options. This table appraises two options for the former Sidley Sports and Social Club - purely housing and purely playing pitches. The SA does not appear accurate or objective in regard to its appraisal of the site, with the playing pitch option scoring higher than the provision of housing. There are several unsubstantiated instances (SA objectives 2 and 9) where the provision of housing has a cross, rather than a tick, despite more positive scoring being given to other sites for housing.

No mixed use is appraised for the site, this would have been a 'reasonable alternative' to explore further, given the owner's aspirations for the site and the planning application history. The SA is therefore flawed in this regard, as it does not assess and compare all of the realistic reasonable alternatives for the site.

Given our conclusions, our assessment is that in regard to the Sustainability Appraisal, this is not legally compliant.

Evidence Base Issues

The District Council has published a range of evidence-based studies which support the emerging Plan. Those most relevant to our client's site at Sidley are the Open Spaces, Sport and Recreation Strategy, which is very dated, published in 2006/7 and the Rother and Hastings Playing Pitch Strategy from 2016.

The Open Spaces, Sport and Recreation Strategy concludes with a quantity standard which for the Bexhill, Battle and Rye area is 2.97 hectares of outdoor sports facilities per 1,000 population. The study also concluded that the Council should plan for additional pitches in the Bexhill area. This is something that could be done through the review of the Plan, by allocating a site/sites for the provision of any additional sporting facilities that are required. This would be a justified and effective approach which responds to the evidence base.

The Playing Pitch Strategy (PPS) recommends that the Sidley Sports and Social Club site should be protected with any development leading to the replacement of facilities to at least the same or improved level of quality and facility mix. The PPS is somewhat misleading stating that the site provided 'a high quality of football provision for local residents'. This is factually incorrect, given the ongoing quality issues that were experienced in regard to the football pitch in relation to drainage and car parking. The ground did not meet the requirements for a step 7 football club (the level that Sidley United play at).

Additionally, the club was always privately owned rather than being a community facility. Our client, the site owner, offered the new facilities to Sidley United, for free. Whilst this offer made by our client was turned down by the club as it was considered unviable, our client is open to resuming discussions at any point. We note from the press (our source of local information given the lack of any engagement from the Council) that several football clubs would be interesting in using the site and our client is happy to work proactively as appropriate, with interested parties.

The PPS also confirms that the current ancillary facility (with regard to competitive football) is not fit for purpose and that if the site comes back into use for football then a new ancillary facility including changing rooms and a social area would be required. Our client responded to these points through the planning application and there is plenty of scope to work with the necessary agencies to ensure that the site is delivered in accordance with the outcomes of the PPS and to meet the requirements of the football club.

The PPS scores the cricket pitch at the former Sports and Social Club site relatively poorly; scores are given for five elements of provision, only two of which are relevant to the site (outfield and changing/pavilion). The cricket pitch scores 63.3% in these two areas, giving it an overall rating of 'standard'. Given that the site had been vacant for three years at the time that the PPS was carried out, it is difficult to have much faith in the justification or effectiveness of this assessment.

Table 5 of the PPS sets out the pitch quality information in regard to football, giving a pitch score and an ancillary score. The Sidley Sports and Social Club site scores very badly, with 38.57% for the pitch and 7.69% for ancillary facilities. This gives an overall score of 'poor'.

We assess that the summary below from the PPS is also inaccurate in terms of the site being a 'previously good facility'. Given the evidence about the quality of the football pitch which is publicly available on Sidley Football Club's website, this cannot be substantiated. The ground was not fit for purpose and did not meet the minimum grading requirements of a step 7 football club.

Sidley Sports and Social Club (Gullivers): Located in the heart of Sidley, this previously good facility has currently fallen into disuse and is in a very poor condition. Until recently; the ground was home to both Sidley Cricket Club and Sldley Football Club, but financial mismanagement resulted in its sale forcing both clubs to source alternative facilities outside of Rother. The pavilion facilities and stands have suffered from arson and vandalism.

In summary, therefore, we have assessed that the PPS is internally inconsistent and does not form a sound evidence base for the Local Plan.

Sidley Sports Ground Feasibility Study

A feasibility study (prepared by 4global in partnership with LK2 Consulting) was commissioned by the Council to inform the future of the former Sidley Sports Ground. Unfortunately, our client, despite being the owner of the site and being keen to work collaboratively with the Council, was not invited to engage in the study, despite being listed as one of the 'key stakeholders' identified at paragraph 1.2 of the study. The study is evidently flawed from the outset without the engagement of the owner, who would have had a meaningful input, and there is no reference within the study to the fact that the site is not for sale.

We were not even aware of the study until the emerging site allocation document was made public. Whilst we requested a copy of the study, this was not made available to us until it was published on the Council's website. The aim of the study is to 'ascertain the future use of the site' and sets out various options for the future of the site. 3 of the options involve various levels of residential development, however, these options were not shortlisted. The reason given is that '...releasing the land for housing is not compliant with the planning policy designation afforded to the site'. However, this statement is flawed - planning policy should be informed by the evidence base, para 31 of the NPPF sets out that "The preparation (our emphasis) and review of all policies should be underpinned by relevant and up to date evidence". The study infers that a decision was already made about the use of the site, specifically regarding the potential for residential development, before the study was carried out. This is an unsound approach in terms of not being a justified strategy - it is also inconsistent with national policy.

The study sets out (based on the information from the PPS )that there is a requirement for 2 additional full-sized 3G pitches in Rather, with at least one of these being located in Bexhill. This could be located on our client's site, as demonstrated by the scheme currently at appeal. Alternatively, and as we have set out, there is scope for the emerging Plan to identify a new site for any facilities identified within the PPS, either as part of one of the other proposed allocations in the Plan (as set out within Policy BEX10) or as a separate allocation elsewhere in the Bexhill area.

The study usefully confirms that the former Sidley Sports and Social Club site cannot meet the minimum requirements of a dual use cricket and football site, information which renders part of the recent refusal on the site factually erroneous.
Whilst the study includes options for funding, these are only options at the moment and this does not give any certainty at all regarding delivery. There is no analysis of the potential of providing a scheme that is part residential and part sports uses, despite the scope for this to provide a deliverable scheme. As we have set out above, the proposal that is currently being appealed will ensure the delivery of sporting facilities at the site.

Policy BEX 11

The emerging Plan proposes to allocate the former Sidley Sports and Social Club for playing pitches (with one pitch proposed) plus ancillary 'hub' space and open space. This is considered (by the Council) to be the most viable use of the site, allegedly based on the outcomes of a feasibility study (despite the feasibility study setting out that there was already planning policy in place for the site). This completely contradicts the reasons for refusal for our client's planning application which refused the application on the basis that it did not re-provide both a full sized adult football pitch and a full sized adult cricket pitch.

Unfortunately, our client has been excluded from participating either in the Feasibility Study, or in the preparation of the policy, despite a willingness to work collaboratively with the Council. We were not even aware of the study until the emerging site allocations local plan was placed in the public domain.

However, the Council has been engaging with local sports clubs regarding the future of the site. We consider this surprising, given our client's ownership of the site and casts doubts over the Councils approach to the preparation of the Plan. Engagement with the owner of the site would have been an obvious step towards producing an effective and justified strategy and policy towards the future of the site.

In its current form, we therefore consider that policy BEX11 is unsound in terms of paragraph 35 of the NPPF, specifically in regard to the 'effective' test of soundness, given that there is no evidence that the policy is deliverable. Whilst the Feasibility Study sets out options for future funding, none of these are guaranteed, and therefore the policy fails the tests of soundness in regard to justification, effectiveness and consistency with national policy.

However, we are keen to work with the Council to address this through some minor modifications to the policy which will enable our client to successfully deliver the site, in line with the principles that the Council has set out.

We suggest these modifications below, using the traditional strikethrough to show proposed deletions and underlining to show proposed additions to the policy text:

Policy BEX11

The former Sidley Sports and Social Club, Glovers Lane, as shown on the Policies Map, is allocated for playing pitches for up to 54 dwellings a playing pitch for formal sport and appropriate ancillary uses.

Proposals will be permitted where:


(i) up to 54 dwellings are provided on site including an appropriate mix of size ad types of private and affordable housing.
(ii) One full size 3G Artificial Grass Pitch (AGP) for formal sport is provided, alongside associated ancillary uses and parking facilities
(iii) Provision is made for the protection and enhancement of site's boundaries in order to enhance biodiversity and improve the relationship with neighbouring residential properties, as indicated on the Detail Map. Provision should include the translocation of reptiles and appropriate protection or mitigation for light-sensitive species in accordance with a lighting design strategy and species activity surveys;

(iv) A Community Use Agreement accompanies the application to ensure community access to the facility. The Agreement shall include details of pricing policy, hours of use, access by non-school users, management responsibilities and include a mechanism for review;

(v) Highway access is provided from Buckholt Lane, via Glovers Lane, alongside any offsite highway works to make the development acceptable in highway terms;

(vi) Linkages to the wider transport infrastructure that supports local accessibility for both cyclist and pedestrians are incorporated, including connections to the proposed Bexhill Cycle Network; and

(vii) Sustainable drainage (SuDS) is provided in accordance with Policy DENS.

Conclusion

We welcome the opportunity to comment at this key stage of the Local Plan process; however, our view is that a more positive approach is needed by the Council.

We have identified that the Plan does not take a sufficiently positive approach to allocating housing and is out of step with Government policy in this regard as it does not seek to use the Government's new method (which should be used unless there are exceptional circumstances).

Our client has an available and highly sustainable site which is available for mixed use development, including up to 54 homes. The site is in the hands of a willing developer and would go some significant way towards delivering the Council's aspirations for the former Sidley Sports and Social Club in Bexhill.

We have set out within these representations that we have concerns regarding the evidence base that underpins the emerging Plan, and that the Sustainability Appraisal is also flawed as it has not assessed obvious and realistic reasonable alternatives in regard to our client's sites.

In terms of the evidence base, there has been a specific feasibility study to assess the future of the former Sidley Sports and Social Club. Rather astonishingly, our client, the owner of the site has been excluded from participating in the study, despite a willingness to work collaboratively in this regard.

Given our client's key role in delivering the site, we have suggested some amendments to Policy BEX11 to ensure its deliverability.

We hope that these comments are useful. We are happy to work with the Council on the elements of unsoundness in the Plan that affect our client's site.
We confirm that we wish to appear at the Local Plan Examination in this regard.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24347

Received: 07/12/2018

Respondent: Stapylton-Smith Family

Agent: Mr Geoff Megarity

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The DaSA seeks to deliver the housing requirement set out in the Core Strategy, which was based on an Objectively Assessed Housing Need (OAN) of 363 dwellings p/a. The OAN is out of date. Based on data published by MHCLG and also the standard methodology, it is clear the LPA is supplying a significant amount of dwellings below their OAN. The LPA would be required to have an early review, as required by NPPF paragraph 33, as the housing need has changed significantly.
In the Local Plan Monitoring Report (April 2018), a persistent under-delivery of housing was identified. This means that the LPA must include a 20% buffer into its Five-Year Housing Land Supply.

Table 17 notes the residual requirement for Ticehurst is zero. Housing provision needs to significantly increase based on the new Housing Delivery Test, in all settlements across the district. Furthermore, the LPA will be required to supply a 20% buffer onto its Five-Year Housing Land supply which it is currently failing to do.

Policy OVE1 is unsound (NPPF paragraph 35). It has not been positively prepared to meet the identified development need; the evidence base and facts are out-of-date and it is inconsistent with National Policy.

Full text:

We have put together representations in the following documents:

1. Representations to Rother District Council Development and Site Allocations (DaSA) Local Plan: Land at Cherry Tree Field, Land at Steellands Rise and Former Agricultural Buildings at Steellands Farm, Ticehurst prepared by Bell Cornwell LLP dated December 2018

2. Indicative Layout Drawing prepared by FIBONACCI-ARCHITECTS (drawing number 6104 P60)

Within these documents we set out our representations for why the DaSA Local Plan is not sound on the basis that the evidence base that has been used for the DaSA is not considered up to date, and does not address the issues of housing under delivery and under-provision in the district. We believe that an all-encompassing review of the Development Plan is required rather than this staged approach. The DaSA is already out-of-date at Regulation 19 stage and as a standalone updated local plan document in its current state, is not able to meet the development needs of the LPA.

It is therefore considered that as the housing need for the district is not in line with the OAN and does not address the under delivery of housing that it must be considered to fail all the tests of soundness set out in NPPF paragraph 35.

This form does not allow the opportunity to clearly note the specific policies we wish to make comments on. For clarity they are:

OVE1- Housing supply and delivery pending plans
DIM2- Development Boundaries


1 INTRODUCTION

1.1 On behalf of our clients, the Stapylton-Smith Family, who are landowners of three sites in Ticehurst, we wish to submit representations to the Rother District Council Development and Site Allocations Local Plan: Proposed Submission (DaSA).

1.2 Rother District Council is carrying out a Regulation 19 consultation on the DaSA and these representations focus on the tests of soundness and legal compliance as is required at this part of the process.

1.3 We wish to promote these sites for residential-led development. Due to the proposed Ticehurst Neighbourhood Plan (TNP), which is currently being consulted on at Regulation 16 stage, the DaSA does not address the development boundaries and other designations within the village of Ticehurst. However, the DaSA addresses strategic housing targets and sets out overarching planning policies which are proposed to form part of the Local Planning Authority's (LPA) Development Plan, we wish to make representations on the Council's processes including their approach to meeting housing need, and the need for additional housing to be added to the Plan for flexibility.

1.4 These representations should be read alongside: (map attached - Indicative Layout prepared by Fibonacci Architects drawing number 6104 P60: www.rother.gov.uk/CHttpHandler.ashx?id=31141)
1.5 This document should be examined against the most recent publication of the National
Planning Policy Framework 2018 (NPPF) and Planning Policy Guidance (PPG) and the
most up-to-date policy framework.

1.6 As part of these representations, we wish to address whether the proposals meet the test of soundness set out in Paragraph 35 of the NPPF. Plans are considered sound if they are:

* Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
* Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
* Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
* Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework

2 SITE BACKGROUND
2.1 The sites consist of three plots of land in the north-eastern end of the village of Ticehurst.

2.2 The three sites are identified within the Indicative Layout drawing prepared by Fibonacci Architects. The plots of land are known as:
* Plot 1- Cherry Tree Field
* Plot 2- Agricultural Buildings at Steellands Farm
* Plot 3- Land at Steellands Rise

2.3 As previously mentioned, these plots of land are owned by one family. Plot 1 is used as an agricultural field and measures 1.46ha in area. Plot 1 is bounded by Steellands Rise to the south, the B2087 road and the Cherry Tree Inn to the east, an agricultural field to the north and the Steellands Farm to the west. The northern and western boundaries are bounded by trees and hedgerows.

2.4 Plot 2 is currently occupied by five disused and redundant farm buildings which do not make a valuable contribution to the rural area. This plot measures 1.65ha in area including the access route. This plot is accessed through a long drive-way which is accessed through Steellands Rise. To the north of the plot is a disused Thames Water pumping station which is used by people to take drugs and other anti-social behaviour.

2.5 Plot 3 is a plot of overgrown land and measures 0.14ha. The site is bounded by Steellands Rise on the north, east and west of the site, and to the south is an unadopted footpath which connects Lower Platts to the western portion of Steellands Rise, by the Ticehurst and Filmwell Church of England School (the School).

2.6 All three plots are in the High Weald Area of Outstanding Natural Beauty (AONB).

2.7 The proposals for each of the plots is to develop them for residential development. As part of these representations we have set out the individual capacity for development on each plot.

table included: www.rother.gov.uk/CHttpHandler.ashx?id=31142
2.8 Due to the location of the Plots within the AONB and that it currently sits outside the currently adopted development boundaries, there are two options relating to the allocation of sites. Should the provision of residential development be allocated to Plot 1, our client is willing to allocate, subject to viability, a higher level of affordable housing provision in Plot 2. Should it be considered that Plot 1 is unallocated, Plot 2 will include a smaller proportion of affordable, subject to viability assessments.

2.9 It is considered that Plot 3, due to its location and size makes limited contribution to the character of the AONB and is a suitable location for residential development. This is a small site which can contribute to meeting the housing reequipment. It is considered that through the development plan, under NPPF paragraph 68 (a), that it should be designated for residential development.

2.10 In terms of deliverability the Stapylton-Smith Family were landowners who acquired outline planning permission on Banky Field for residential led development and have maintained contact with the developer who purchased the site ever since. It is considered that in terms of deliverability of the sites, there is scope for further work with the developer and it is believed that there is an opportunity to work with them again to deliver these proposed homes.

3 TICEHURST NEIGHBOURHOOD PLAN

3.1 As set out above the Plots are located within Ticehurst Neighbourhood Plan Area which was designated in accordance with Regulation 7 of the Neighbourhood Planning (General) Regulations 2012, in October 2015. The TNP is currently undergoing Regulation 16 consultation managed by the LPA. This consultation, which shares similarities to the Regulation 19 consultation which is being undertaken by for the DaSA concludes on 21 December 2018.

3.2 The TNP will form part of the Development Plan once adopted and sit alongside the DaSA. The TNP and DaSA should support the strategic development needs set out in the Local Plan and positively plan to support local development.

3.3 Furthermore, as a significant amount of Background Evidence which has been used in the preparation of the TNP, particularly relating to housing numbers and the lack of Fiver Year Land Supply, that should the LPA find the DaSA to be unsound, that the TNP should also be considered to not conform with the proposed development plan and therefore the TNP would have to be modified as part of the Examination or be reviewed immediately with an updated housing delivery figure calculated.

4 REPRESENTATIONS

4.1 Our representations will be based on the proposed policies set out in the DaSA and the evidence base which is used to support it.

POLICY OVE1: HOUSING SUPPLY AND DELIVERY PENDING PLANS

4.2 To assess the strategic development needs of the LPA, all of the policies should be underpinned by relevant and up-to-date evidence as required by NPPF paragraph 31. NPPF Paragraph 31 continues to say that the evidence should be focused tightly on supporting and justifying the policies concerned and take into account relevant market signals.

4.3 Due to the manner of which the LPA has chosen to update their Local Plan by allowing the DaSA to be consulted on the basis of it addressing the strategic aims of the already adopted Core Strategy, It is not considered that this is the most positive and effective way of preparing new local plan documents.

4.4 The DaSA seeks to deliver the housing requirement set out in the Core Strategy. This sets out that the housing development target for the District as a whole is for at least 5,700 new homes to be built over the plan period, which runs from 2011-2028. This figure was based on the Council's Strategic Housing Market Assessment (SHMA) update from June 2013.

4.5 This document set out that the Objectively Assessed Housing Need (OAN) was 6,180 (363 dwellings per annum (dpa)) dwellings by 2028. The LPA decided that due to environmental concerns that they would have to reduce this number. The OAN is out of date and based on the data published by the Ministry of Housing, Communities and Local Government (MHCLG) on 14 September 2017 the LPA has an indicative housing need of 469dpa. Figures from the House Builders Federation set out that, based on the standard methodology, set out that the LPA need to deliver up to 690dpa.

4.6 As the LPA clearly are supplying a significant amount of dwellings below their OAN and based on the new figures from the standard methodology, it is considered that the LPA would be required to have an early review, as required by NPPF paragraph 33, as the housing need has changed significantly. In the Local Plan Monitoring Report published in April 2018, the LPA there was an under delivery of housing and amounts to a persistent under-delivery of housing (Paragraph 2.25 of Rother District Council- Housing Land Supply as at 1 April 2018 incorporating Housing Trajectory and Self-build and Custom House building headline data, June 2018). Since the update to the Planning Policy Guidance in the summer of 2018, failure to comply to a threshold of 85% delivery against assessed need means that an authority is guilty of 'persistent under-delivery' of housing over a three-year period and has only delivered 65.65% between 2015-2018. This is significantly below the new Planning Policy Guidance (PPG) definition of persistent under-delivery which sets out that if Local Planning Authorities fail to delivery 85% of the Objectively-Assessed Need (OAN). This means that the LPA must include a 20% buffer into its Five-Year Housing Land Supply.

4.7 As set out in table 17 the residual requirement for Ticehurst is zero. In terms of housing it is considered that the provision of housing needs to significantly increase based on the new Housing Delivery Test. This will need to increase in all settlements across the district. Furthermore, the LPA will be required to supply a 20% buffer onto its Five-Year Housing Land supply which, under the current Core Strategy and the proposed DaSA, it is failing to do.

4.8 As such it is considered that Policy OVE1 is unsound on in terms of NPPF paragraph 35 on the basis that it has not been positively prepared to meet the identified development need of the LPA; that the evidence base and facts are out-of-date and is inconsistent with National Policy.

POLICY DIM2: DEVELOPMENT BOUNDARIES

4.9 While the development boundaries have been adopted under Core Strategy Policy OSS2, the policy within the DaSA does not provide scope for any alteration to development boundaries.

4.10 It is considered that the process of preparing the DaSA as a Local Plan document which addresses the strategic policies of an out-of-date Core Strategy is clearly unsound and is not a justified approach. It is considered that the development boundaries, which are based on this evidence, should be reviewed as they currently limit the scope of the LPA to provide enough land to provide the significant increase in housing number which is clearly required. The development boundaries are already out of date as the housing number has increased. Unless they are reviewed at this stage of the process, this is going to lead to confusion and inconsistency through the development management process.

4.11 Given that the Council's current level of supply is below that required using the standard methodology any policies relating to the delivery of housing and locations of development will be out of date.

4.12 Decision making on applications must be based in line with the presumption in favour of sustainable development in line with the NPPF. The PPG states that this is undertaken to "enable the development of alternative sites to meet the policy requirement". This suggests that where there are policies that restrict development, but which are not highlighted in foot note 7 of paragraph 11 then these should be ignored.

4.13 It is therefore considered that the development boundaries across the whole district should be reviewed as the current policy and proposed DaSA is unsound based on the plan has not been positively prepared, has not been justified, is not effective, and is inconsistent with National Policy. It therefore fails to meet the tests of soundness set out in paragraph 35 of the NPPF.

5 CONCLUSIONS

OVERARCHING COMMENTS ON DASA

5.1 As set out above, the evidence base that has been used for the DaSA is not considered up to date, and does not address the issues of housing under delivery and under provision in the district. We believe that an all-encompassing review of the Development Plan is required rather than this staged approach. The DaSA is already out-of-date at Regulation 19 stage and as a standalone updated local plan document in its current state, is not able to meet the development needs of the LPA.

5.2 It is considered that all documents which are currently under consultation, including the TNP, need to be considered against accurate and up-to-date evidence to be considered sound and needs to address the assessed development needs of the district.

5.3 The three plots our client wishes to put forward supply up to 37 new homes for the district, without harming the character of the district. The plots can be brought forward with the help of a willing developer who has experience in Ticehurst.

5.4 It is therefore considered that as the housing need for the district is not in line with the OAN and does not address the under delivery of housing that it must be considered to fail all the tests of soundness set out in NPPF paragraph 35.

5.5 We hope that the above comments and assessment is useful. We are more than happy to work with the Council and members of the Ticehurst Neighbourhood Steering Committee on addressing the issues raised. We confirm that we wish to appear at the Local Plan Examination in this regard.

Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24486

Received: 07/12/2018

Respondent: Rye Conservation Society

Representation Summary:

Site Allocation Policies

Overview Policy OVE1: Housing supply and delivery pending plans.
RCS supports.

Figure 16: (Residual requirements to meet Core Strategy targets as at 1 April 2016) included:

http://www.rother.gov.uk/CHttpHandler.ashx?id=31170


RCS supports and notes adoption of lower end of Core Strategy target for Rye which it believes to be prudent given the development difficulties in Rye.

Full text:

Rye Conservation Society
Comments on Rother Development & Site Allocation Policies
Cabinet Version

November 2018

Development Policies

Resource Management

Policy DRM1: Water Efficiency

Limits daily household water consumption to no more than 110litres/person per day.
RCS supports.

Policy DRM2: Renewable Energy Developments
General support for low energy schemes where they meet other Core strategy and D&SAP policies. No support for large scale wind farms.
RCS supports.

Policy DRM3: Energy Requirements
Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floor space should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement.
RCS supports.

Communities

Policy DCO1: Retention of Sites of Social or Economic Value
18 month period to show that use is no longer a prospect of continuing use.
RCS supports.

Policy DCO2: Equestrian Developments
RCS supports.

Housing

Policy DHG1: Affordable Housing
Sets requirement for affordable housing % (Rye 305 on sites with 10 or more/. 3 hectares)
Viability still a factor although 2018 NPPF sets standard for viability threshold.
RCS supports

Policy DHG2: Rural Exception Sites
RCS supports

Policy DHG3: Residential Internal Space Standards
To adopt government space standards.
RCS strongly supports.

Policy DHG4: Accessible and Adaptable Homes.
All dwellings are required to meet M4 (2): Category 2 - Accessible and Adaptable Dwellings. This does not provide for wheel chair access but where there is an identified need on the Housing Register, sites that provide affordable housing in line with Policy DHG1, are as part of the affordable housing requirement, expected to provide 5% of the total housing requirement to meet M4 (3): Category 3 - Wheelchair Accessible Dwellings.
RCS supports.

Policy DHG5: Specialist Housing for Older People.
Supports such schemes with 'walkability' an issue.
RCS strongly supports.

Policy DHG6: Self-build and Custom House building.
Supports concept. On sites of 20 or more dwellings, provision for 5-10% of the total number of dwellings to be provided should be made available as serviced plots for self and custom house builders.

Plots should be made available and marketed through relevant marketing agencies for a period of at least 12 months. If the plots are not sold within this time period, the dwellings may be released for conventional market housing in line with the terms set out in the relevant legal agreement.

RCS supports.

Policy DHG7: External Residential Areas.
For dwellings, private rear garden spaces of at least 10 metres in length will normally be required.
Provision for car parking and safe and secure cycle storage should be made in accordance with Core Strategy Policy TR4 and East Sussex County Council's 'Guidance for Parking at New Residential Development' and 'Guidance for Parking at Non Residential Development'.
Waste and Recycling: Sufficient bin storage and collection points must be provided on all new residential developments and changes of use. Their siting and design should be considered at the outset.
RCS strongly supports.

Policy DHG8: Extensions to Residential Gardens.
RCS supports.

Policy DHG9: Extensions, Alterations and Outbuildings.
RCS supports.

Policy DHG10: Annexe.
RCS supports.

Policy DHG11: Boundary Treatments.
RCS supports.

Policy DHG12: Accesses and Drives.
RCS supports but notes that no specific mention is made of the need to deal adequately with rainwater run off.

Economy

Policy DEC1: Shopfronts, Signage and Advertising.
RCS generally supports but is concerned that the extent of permitted development rights relating to advertising/sign is at odds with thrust of policy, as has been shown in Rye. Would like to see permitted advertising rights suspended in Conservation Areas.

Policy DEC2: Holiday Sites.
RCS supports.

Policy DEC3: Existing Employment Sites and Premises.
Where continued employment use of a site/premises is demonstrated not to be viable, permitting complementary enabling development as part of an overall scheme to make most effective use of the property for employment purposes; and if a mixed use scheme is not viable, prioritising alternative community uses, affordable housing (where affordable housing would be sought in line with Policy DHG1) and then market housing, subject to local needs.
RCS supports.

Environment

Policy DEN1: Maintaining Landscape Character.
RCS supports.

Policy DEN2: The High Weald Area of Outstanding Natural Beauty (AONB).
RCS supports.

Policy DEN3: Strategic Gaps.
Strategic gap between Rye and Rye Harbour identified. Within these Gaps, development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive and not detract from the openness of the area. Enhancement of the Gaps through effective landscape management which strengthens and reinforces their significance as protected landscape areas will be supported.
RCS supports.

Policy DEN4: Biodiversity and Green Space.
Development proposals should support the conservation of biodiversity and multi-functional green spaces in accordance with Core Strategy Policy EN5. Larger developments of more than 2 hectares or 50 dwellings (whichever is the smaller) should produce a Green Infrastructure masterplan as part of their proposals.
RCS supports.

Policy DEN5: Sustainable Drainage.

RCS supports but would like to see requirement for all new water courses to be open accept for access requirements and for 'daylighting' where appropriate of existing culverts stated in policy not just in supporting text.

Policy DEN6: Land Stability.

General policy which does not identify Point Hill area as potential problem area.
RCS supports.

Policy DEN7: Environmental Pollution.
RCS strongly supports.
Implementation

Policy DIM1: Comprehensive Development.
RCS still has concerns as to the exact circumstances which will require a 'comprehensive' approach. How will this apply to Rock Channel, where there are two co incident sites, Bourne's and Jempsons? Will Martello (Bourne's) have to produce a 'fictitious ' master plan for both sites even though Jempson's may not be developed in the near future or will it be sufficient to show that suitable access has been maintained.
Policy need to be clarified as to where and how it is applied.

Policy DIM2: Development Boundaries.
RCS supports.

Site Allocation Policies

Overview Policy OVE1: Housing supply and delivery pending plans.
RCS supports.

Figure 16 identifies an updated residual requirement for additional homes on new sites of 6+ dwellings in each of the towns as at 1st April 2018

Figure 16: (Residual requirements to meet Core Strategy targets as at 1 April 2016) included:

http://www.rother.gov.uk/CHttpHandler.ashx?id=31170


RCS supports and notes adoption of lower end of Core Strategy target for Rye which it believes to be prudent given the development difficulties in Rye.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24587

Received: 07/12/2018

Respondent: Persimmon Homes Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst the motive underpinning policy OVE1 is understood, it is considered that to plan for a shortfall against the Core Strategy requirements will not result in a plan which is positively prepared, justified, effective or consistent with National Policy, and will create a degree of uncertainty as to whether the housing requirements will actually be met. This is particularly relevant given the historic undersupply of housing in Rother District against the Core Strategy requirements.

RDC should therefore seek to plan for the full Core Strategy requirements, with a sufficient overprovision to account for the documented historic undersupply and for sites that do not come forward, or that are developed for a lower amount of units, as per the requirements of the NPPF (2012).

The ethos behind this policy is supported, in that it seeks to ensure the allocation of sites which will help to address the identified need within the District. However technical amendments to the policy are sought, as it would be pertinent for the Council to take the opportunity to meet the residual Core Strategy requirement through the allocation of further sites in the DaSA and not to rely on other provisions in the Plan.

Full text:

7.12. Policy OVE1 states that:

Housing sites sufficient to meet the Core Strategy requirement of at least 5,700 net additional homes over the period to 2028 will be met by allocations and other provisions in this Plan and Neighbourhood Plans.

No phasing restrictions will be imposed on development allocations, other than for site-specific, normally infrastructure, reasons.

Until such time as a Neighbourhood Plan for the relevant settlement with an outstanding Core Strategy housing requirement is in force, planning applications will be favourably considered for development proposals in those settlements where

i. they contribute to meeting the housing target for that settlement and accord with the relevant spatial strategy; and

ii. the site and development proposals are otherwise suitable having regard to other relevant policies of the Core Strategy, including the considerations in OSS2 and OSS3, and of this Plan.

7.13. Whilst the motive underpinning policy OVE1 is understood, it is considered that to plan for a shortfall against the Core Strategy requirements will not result in a plan which is positively prepared, justified, effective or consistent with National Policy, and will create a degree of uncertainty as to whether the housing requirements will actually be met. This is particularly relevant given the historic undersupply of housing in Rother District against the Core Strategy requirements, highlighted by RDC's current five year housing land supply of just 3.44 years' as set out in the April 2018 AMR.

7.14. RDC should therefore be mindful of this and seek to plan for the full Core Strategy requirements for the District, with a sufficient overprovision to account for the documented historic undersupply within the District and for sites that do not come forward, or that are developed for a lower amount of units than initially envisaged, as per the requirements of the NPPF (2012).

7.15. The ethos behind this policy is supported, in that it seeks to ensure the allocation of a number of sites which will help to address the identified need within the District. However technical amendments to the policy are sought, as it would be pertinent for the Council to take the opportunity to meet the residual Core Strategy requirement through the allocation of further sites in the DaSA and not to rely on other provisions in the Plan.

7.16. It is in this context that this representation has been prepared, with specific regard to Site BEX3c, which has been included in the draft Site allocations shown in the DaSA