Comment

Representation ID: 28243

Received: 23/07/2024

Respondent: Rubix Estates

The Standard Method Local Housing Need (LHN) figure for Rother is 773 dpa (2023 base date) or 727 dpa (2024 base date). The Hastings & Rother Housing and Economic Development Needs Assessment (HEDNA) Update (2024) identifies an affordable housing need (net) of 325 dpa, and some 2,054 households are on the Rother Housing Register.

ONS datasets indicate that the latest median housing affordability ratio (2023) for Rother is 11.44, having risen from 8.83 in 2013, and 7.77 in 2003. The lower-quartile affordability ratio is now 12.84, rising from 10.53 in 2013 and 7.03 in 2003. Paragraph 8.21 of the Draft Local Plan cites the HEDNA’s analysis regarding housing affordability. This notes that 44% of newly forming households earn less than the amount needed to rent a lower-quartile property on the open market. Likewise, 94% earn less than the amount needed to buy a lower-quartile open market dwelling.

The level of housing need is then significant, and affordability pressures are, therefore, serious and widespread. Whilst Rother’s position is not unique, the current LHN for the district is also far higher than the adopted (out-of-date) Core Strategy requirement (averaged at 335 dpa). Moreover, the adopted Core Strategy requirement did not, in any case, fully address the scale of housing needs identified in the (now defunct) South East Plan. Notwithstanding the HEDNA’s commentary on the efficacy of the Standard Method, there can be no dispute that Rother (and the Rother-Hastings HMA) represents an area of high housing need.

Despite the above, the proposed Spatial Strategy (as presented on pages 112 and 113 of the consultation document) proposes only;
“a minimum of [5,158 to 7,287] dwellings, at an average rate of [258 to 364] per year.”

In other words, the Plan seeks to deliver between a third and just below half of the level of housing need identified through the Standard Method calculation. Moreover, the net annual need for affordable housing of 325 dpa (as identified in the HEDNA Update) is also likely to exceed the total (i.e., market and affordable) annual housing target envisaged in the Draft Local Plan.

Draft Policy HOU2 ‘Affordable Housing’ does not yet specify the percentage of affordable housing sought from market-led residential developments. However, depending on the conclusions of a future Plan-wide viability assessment, the tariff is likely to be between 30% and 50%. As such, it is self-evident that only a fraction of overall affordable housing needs will be addressed through the Plan’s current proposals.

As a separate point, and despite the analysis in the HEDNA Update (in particular, in paragraphs 6.32 to 6.49), RDC does not appear to argue that exceptional circumstances exist to justify a deviation from the Standard Method (as per NPPF paragraph 61) and the minimum Local Housing Need figure arrived through it. It is the Standard Method LHN figure that should, therefore, be taken to represent the Objective Assessment of Need.

Rather than seeking to make the case that there are exceptional circumstances justifying a departure from the Standard Method, the Council instead contends that it is constraints found within the Plan-area that prevent identified needs from being met. Indeed, in paragraphs 5.1 to 5.8, the Plan suggests that the prevalence of areas at high risk of flooding, designated habitat sites and areas of high-landscape value, means that housing needs cannot be met in full, without resulting in unacceptable impacts.

Rubix Estates recognises that parts of the Plan-area are subject to environmental constraints. However, it is not accepted that there are no further opportunities to meet housing needs either in full or at least to a much greater extent.

For example, within the HELAA (2024), the availability of a significant number of sites is listed as ‘unknown’, with these, therefore, being discounted when they might otherwise be suitable for meeting needs. Many sites are also judged to be ‘unsuitable’ when it is clear from the Site Assessment commentary (in the HELAA) that their suitability or unsuitability is finely balanced. Likewise, many sites that are judged to be potentially suitable have had their estimated capacity and/or developable area reduced when compared to the promoter’s / landowner’s estimate.

A more specific concern is that the HELAA (and, by extension, the Draft Local Plan) has taken a ‘policy-on’ approach to the evaluation of site constraints. Whilst that may be appropriate for statutory designations (e.g., National Landscape), local, non-statutory designations should be treated differently.

The above suggests that there is scope to refresh the HELAA evaluation to bring forward additional sites. In this context, it must be recognised that the socioeconomic consequences of not fully meeting housing needs (and to the degree currently envisaged) will have real-world consequences. Housing affordability will worsen, and issues such as overcrowding and the suppression of household formation will fail to be addressed. Broader consequences will arise in relation to intergenerational inequality, declining social mobility and hindered economic productivity.

Overall, Rubix Estates and the landowners believe that Rother District Council has not yet reached a point where it can credibly claim that an appropriate balance has been reached between meeting housing needs and respecting the district’s environmental characteristics and constraints. As such, the proposed approach is not currently regarded as justified or positively prepared, nor does it appropriately contribute to the achieving of sustainable development.

Comment

Representation ID: 28278

Received: 23/07/2024

Respondent: Oak Tree Homes Trust

Agent: Greenhayes Planning

For comments on the Spatial Development Strategy including overall housing provision, please see paragraphs 3 - 6 in the attached Main Submission Document. The representation is registered under Q54 in the Regulation 18 draft Local Plan.

Comment

Representation ID: 28284

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

Housing Need
2.25 On page 112, the draft Local Plan sets out the overall Spatial Development Strategy. This states:
The Council will meet the local need for all forms of housing, jobs, facilities and services by strengthening Rother’s pattern of development through a landscape-led spatial development strategy that focuses on the ‘Live Well Locally’ concept. To achieve this, a minimum of [5,158 to 7,287]* dwellings, at an average rate of [258 to 364]* per year…will be constructed by the end of the Plan period in 2040.

*The final housing and employment target will be minimum figures. For the Regulation 18 consultation, the overall housing and employment figures are presented as a range, with the lower figure representing the totals of the “identified sites” (current allocations and sites with planning permission), and the upper figure representing the identified sites plus the total capacity of “potential additional sites” (sites identified in the daft HELAA as being potentially suitable, available, and achievable for development during the Local Plan period). Therefore, the range is subject to change (either by an increase or reduction).

2.26 It is understood that using the national standard method, Rother’s minimum local housing need (LHN) figure is 733 dwellings per year (2023 Base Date). This is in contrast to the adopted Core Strategy target of 355 dwellings per annum, and significantly exceeds the delivery rates of housing delivery between 2011-2028 which averages at 219 net additional dwellings per year.

2.27 The Housing and Economic Land Availability Assessment (HELAA) (Draft Regulation 18 Version – April 2024) forms part of the evidence base underpinning the Draft Local Plan. At paragraph 2.5 it states ‘the HELAA will determine the amount of land available for residential development and the resulting number of dwellings that could be accommodated in Rother over the plan period, in line with NPPF paragraph 67. This figure may be compared to the minimum local housing need (LHN) figure defined using the standard method calculation’.

2.28 The HELAA goes onto state at paragraph 7.7:
it is clear that in terms of dwellings numbers, insufficient potential has been identified to meet the local housing need (LHN) figure, calculated using the standard method calculation set out in the NPPF (discussed in section 2 above). The current standard method calculation identifies a need for 14,660 dwellings over the 20-year period of the new Local Plan (2020- 2040) (733 dwellings per annum). In contrast, as shown in Figure 4, the potential identified in the HELAA plus dwellings already constructed plus a windfall projection is between 5,158 and 7,287 dwellings over the 20-year period.

2.29 The current evidence base, therefore, indicates a significant shortfall in sites, as summarised in Table 1 (within the attached representation).

2.30 We note that the housing supply doesn’t propose to meet the LHN in full, which means that the Council should progress with the Plan on the basis of the higher housing need figures, as a minimum. Not factoring in the ‘potential addental sites’ would put the housing supply at 35.1% of the housing need. This would be at conflict with the overarching vision of the Local Plan and its Twin priorities and Spatial Objectives which we endorse. It would also fail to support the Government’s objective of significantly boosting the supply of homes.

2.31 On the basis that the Council is unable to meet its LHN, it is important that the Council plans to allocated additional land to increase its supply position, and/or work existing sites to ensure that more efficient use of land could be used where appropriate, such as the Land at Grove Farm (Phase 2), Robertsbridge, which is attributed an indicative capacity of 35 dwellings but could deliver more. At the very least, additional sites that have not been discounted within the Council’s own HELAA, such as the one to which these representations relate, should, be considered favourably and taken forward as an allocation within the emerging Local Plan where they are available and deliverable.

2.32 ‘SAL0022: Land at Grove Farm (Phase 2), Robertsbridge’, the site to which these representations relate, counts towards one of the ‘potential additional sites’ outlined in Table 1. Within the HELAA this site is assessed as being potentially suitable, potentially available and potentially deliverable, subject to further assessment or investigation. The initial assessment states ‘While it is located within the High Weald National Landscape (HWNL), the site has few other environmental constraints and could form a logical extension to the permitted development, in a sustainable location within walking distance of services and public transport links in Robertsbridge’.

2.33 Further detail on the suitability and development capacity of this site are provided in Chapter 3. To summarise this is one example of a site which should be taken forward as an allocation within the emerging Local Plan in order to increase the Council’s Housing Supply Position which currently falls significantly behind housing need.

Comment

Representation ID: 28285

Received: 23/07/2024

Respondent: The Rector and Scholars of Exeter College

Agent: Bidwells

Proposed Development Strategy
2.34 Having established the housing targets for the Local Plan period, the Draft goes that the focus for growth will be in the following broad locations:
● West and North Bexhill to consolidate Bexhill as the most sustainable town, within the capacities of the existing transport network;
● clusters of villages based around the towns of Battle and Rye which act as key transport hubs;
● settlements on radial routes connected to the main urban areas of Bexhill and Hastings, allowing sensitive development in locations that rely on the larger towns for services and facilities;
● development at Hastings Fringes, providing sensitive growth; urban intensification and redevelopment across the district in appropriate and sustainable brownfield site locations;
● sensitive development in other rural settlements of the district; and
● in the longer-term, sensitive growth along the A21 Corridor.

Delivering the Spatial Strategy
2.35 Rother’s proposed development strategy has been split into five spatial sub-areas, which align with the focus areas of growth presented above. Each of these spatial sub-areas has their own vision statement and identified distribution of development. The five sub-areas comprise:
• Bexhill;
• Hastings Fringes and settlements that radially link to Hastings;
• Battle and its cluster of connected settlements;
• Rye and its cluster of connected settlements; and
• Northern Rother – the settlements in the north-east of the district.

2.36 In all five-sub areas there is open countryside, which relates to those areas outside of villages with development boundaries and includes farmland, woodland, hamlets and scattered development.

Comment

Representation ID: 28292

Received: 23/07/2024

Respondent: Dennis Thomas Builders Ltd

Agent: Greenhayes Planning

For comments on the Spatial Development Strategy including overall housing provision, please see paragraphs 3 - 5 in the attached Main Submission Document. The representation is registered under Q54 in the Regulation 18 draft Local Plan.

Comment

Representation ID: 28336

Received: 23/07/2024

Respondent: Transport Futures East Sussex

General points:

There should be a strong component of public housing for rent; a strong component of truly affordable housing; a comprehensive cycle network that includes chldrens’ routes to school; 20mph default limits in all residential streets and dsitributor roads where appropriate (it will sometimes be appropriate). An absence of flared junctions and ‘cyclops’ roundabouts if a roundabout is deemed necessary.

Bus services under the new administration can be franchised by the transport authority. There could be some creative dialogues around services that RDC/ESCC feels might be improved by new/enhanced or extended routes.

It remains to be seen whether or not developers will still be able to renege on agreements around any form of planning gain. New policies will emerge that might benefit the community.

Comment

Representation ID: 28407

Received: 23/04/2025

Respondent: Gladman Developments

The NPPF requires the standard method to be used unless exceptional circumstances justify
an alternative approach. We agree that there are no exceptional circumstances which
would warrant a different approach than the standard method being used as the starting
point for considering the housing requirement for Rother.

Recognising that the housing targets of the district significantly increase when using the
standard methodology as opposed to the adopted approach using an objective assessment,
every effort should be made to deliver the minimum housing requirement as determined by
the standard methodology.

Gladman strongly support the need for more housing in Rother for a variety of reasons
including addressing the current housing crisis, meeting housing need, providing affordable
housing and to support employment growth. Gladman would request that the Councils
fully considers all of the issues when determining the housing requirement.