Core Strategy Consultation on Strategy Directions 2008

The Strategy as a whole does not do enough to address the need for affordable housing in the District.
Paragraph 5.50 acknowledges that Rother has one of the highest house price/earnings ratios in the Region. The Council should seek to do more to redress the need for affordable housing. The annual target of 92 affordable homes (paragraph 10.10) is too low - the Rother District Housing Need Survey 2005 showing that 256 additional affordable housing units are needed per annum, with a strong need in the Rye area.
Paragraph 101.0 confirms that the Council's Housing Strategy relies on the majority of affordable housing being delivered through the Section 106 mechanism.
The importance of providing for affordable housing to support balanced, inclusive and vibrant communities is acknowledged at paragraph 10.7.
The Strategy should provide for more housing in line with Distribution Option 5 - Housing Needs Based - and the Vision should reflect an objective to respond positively to housing needs in the District by planning to do much more to meet the known housing needs and contribute to the development of balanced communities throughout the District.
Text of the Strategy associated with this Box should be amended accordingly.

The Aims and Objectives should refer to the need for affordable housing.
Objective (ii) should refer simply to building sustainable, balanced communities - the development of a balanced community not being defined simply by the relationship between homes and jobs, but including housing needs.
Objectives should not be expressed in a manner that may be interpreted as relegating housing needs to a second tier consideration as in the case of Objective (v) as drafted.
Text of the Strategy associated with this Box should be amended accordingly.

Acknowledging that the SE Plan figure of 5,600 dwellings is a minimum (paragraph 5.7) and that Rye is located within the "Sussex Coast" part of Rother the Preferred Strategy should provide for more housing at Rye to reflect Option 5 - Housing Needs Based figure of 1,100 dwellings. The need for affordable housing in Rye is acknowledged as a contributory factor to poor social and economic conditions (paragraph 8.9). There is a significant need for affordable housing in Rye (paragraph 8.22).
An average provision of 55 dwellings per annum over the 20 year period should not be too stretching a target with potential for redevelopment within the built area, the housing commitments already in Rye (including the planning permission at Udimore Road and the potential to increase housing numbers on and adjoining that site) and the Council's proposals at Rock Channel. Such development would further the objective to plan for balanced communities and support the market town role of Rye and "improve economic and social circumstances" (Box 1 Vision for Rother in 2026) and need not damage the Councils conservation and environmental objectives. The extent to which the town could accommodate such scale of development could then be assessed in detailed studies leading to the production of the Site Allocations DPD.

With reference to paragraph 5.61 the Strategy should acknowledge that there is an opportunity at, and adjoining, the current Local Plan residential allocation at Udimore Road, Rye to achieve more dwellings than the 135 benefitting from the grant of planning permission. The approved access could accommodate such development and there are no overriding environmental issues that outweigh the benefits of making best use of this residential commitment including the delivery of affordable housing that should be considered an important objective in furthering the aim to improve the economic and social well-being of Rye

With reference to paragraph 5.66 the proposal that the approximate development level for Rye in the twenty year period 2006-26 should be confined to 450 dwellings is inadequate (see comments under Box 3). It is less than the commitment led Option 4 figure of 475 (paragraph 5.36) and less than the District-wide distribution options in Section 5 that suggest approximately 500 dwellings (paragraph 8.26).
The Strategy does not contain the evidence referred to in paragraph 8.25 on which the case for the lower figure of 450 dwellings is advanced. There is no evidence to support the proposal not to provide for a range of housing numbers at Rye "subject to detailed investigation of potential sites" as the Strategy provides for with dwelling numbers at Bexhill, the Hastings Fringes and Rye, or as the Strategy proposes with employment provision at Rye.

With reference to paragraph 5.87 there is scope at Rye to accommodate more than the 450 dwellings in the 20 year period 2006-2026 as proposed at paragraph 5.66. This paragraph fails to acknowledge that land to the west of Rye is not covered by national designations (see paragraphs 8.31 - 8.33).

The Strategy should provide a clear plan to address any shortfall in housing supply arising from delay or cancellation of the Link Road. This should be triggered on any predicted shortfall without need to review the Strategy with the consequent delay and uncertainty associated with that practice (that is likely only to exacerbate the housing supply problem that, as paragraph 5.8 confirms, has been a factor in Rother for many years).

The definition of development boundaries should acknowledge planning permissions on green-field sites.

Reference should be made to the importance of the provision of affordable housing (and thereby housing generally given the importance of the Section 106 mechanism in the provision of affordable housing - paragraph 10.10 refers) in improving social and economic conditions (paragraph 8.9) and hence in achieving the stated aim of improving the economic and social well-being of Rye.

With regard to paragraphs 8.31 - 8.33 the recent appeal decision permitting the residential development of the Local Plan allocation at Udimore Road, Rye has established that this is a sustainable location where there are no overriding landscape, infrastructure or traffic constraints that outweigh the need to make best use of suitable land for development (see comments under paragraph 5.61). The respondent owns a total of more than 11 hectares of land at Udimore Road of which the area to be developed for housing pursuant to the planning permission granted on appeal in 2008 is limited to 3.8 hectares. Further detailed work is not required here to determine impacts. Existing work has shown that land to the west and south of the Local Plan allocation RY5 is suitable for development. The Strategy should acknowledge this fact and identify this as a preferred location.