Proposed Submission Core Strategy

Part (i)

In terms of calculating the annual housing requirements and 5 year housing land supply, the housing figure would be better stated as a single figure, rather than as a range. In paragraph 7.29 of the Proposed Submission Core Strategy (PSCS), the mid-point of 3,900 dwellings (average 229 dwellings per year - dpy) is referred to for "monitoring purposes", but it is unclear why a specific figure should not be referred to in the policy itself rather than the 3,700 - 4,100 range put forward. Indeed, in policy terms it is unclear why the higher level of additional housing (4,100 dwellings) should not be stated as the target figure in the policy rather than any notional mid-point in the range currently put forward by the Council. If this objection were to be accepted, then other parts of the Plan would also need to be amended.

As regards the housing numbers put forward, insufficient justification has been provided for departing on the South East (SE) Plan housing requirement of 280 dpy, i.e. the equivalent of 4,260 dwellings during the 17 year plan period between April 2011 - March 2008. The South East Plan remains part of the Statutory Development Plan.

By comparison, the PSCS puts forward the provision of 3,700 - 4,100 dwellings during the 17 year period between April 2011 and March 2028 (equal to 218 - 241 dpy) with a 3,900 dwelling mid-point (equal to 229 dph - paragraph 7.29). At the lower end of the range (218 dph), this would be a 22% reduction in housing supply compared with the SE Plan target and the mid range (229 dph) would represent a 19% reduction. Even if the top end of the range were to be achieved (241 dph), this would represent a 14% reduction in the SE Plan target.

Assuming (as the PSCS does) that the Bexhill - Hastings Link Road Scheme will be constructed within the Plan period, there appears to be no sound justification for a 14% - 22% reduction in future housing land supply in the District. The SE Plan provides a robust and tested housing requirement for the District and the PSCS should therefore, be amended to take account of this.

Other neighbouring East Sussex Authorities in producing their PSCS DPD's are also putting forward similar reasons for a reduction in the housing requirement compared to the housing targets set out in the SE Plan. Environmental, infrastructure and other reasons are also claimed in neighbouring districts for reducing the housing requirements, but unless SE Plan targets are met, there will be an increasing shortfall of future housing supply in the region as a whole.

Part (iii)

The policy contains no cross-reference to Policy OSS2 (Bexhill to Hastings Link Road and Development) and therefore, in terms of spatial distribution, Policy OSS1 provides no contingency arrangement should the Bexhill to Hastings link road scheme be delayed or shelved as a consequence of the Government's spending review. If the road scheme does not take place, then either the housing requirements figure would need to be amended or alternatively, the suggested distribution of housing in Figure 8 on page 35 of the PSCS would need to be amended to provide for potentially increased housing allocations in other areas of the District outside Bexhill.

It is understood that the Government announcement regarding the funding of the Bexhill to Hastings Link Road Scheme is imminent (see Section 9 of the Housing Provision Background Paper). The building of this road is fundamental to the Council's proposed spatial strategy. In light of this, it would have been more appropriate to suspend the PSCS until the future of the road scheme is known. As it stands, the draft plan is in limbo and Policy OSS2 introduces a significant degree of uncertainty regarding the future of the spatial strategy in the District.

If the road scheme were to be shelved or further delayed, then other alternatives should be considered for growth and development in the District if future housing needs are to be met, particularly in relation to affordable housing as part of private housing schemes (i.e. 'market led' affordable housing). If the road scheme were to be shelved, then more detailed investigation (based on the SHLAA) needs to be undertaken to consider the potential of distributing housing development to other locations such as additional small scale housing extensions at Battle and within such settlements as Burwash (which has a good range of local facilities), Netherfield (as a satellite settlement to Battle) and Westfield (as a satellite settlement to Hastings).

To simply reduce the scale of housing development in Bexhill if the road scheme were not to go ahead would have serious consequences for economic and housing development in the District and therefore, the potential impact of this upon the spatial strategy should be reassessed. Alternatively, the PSCS examination should be suspended until the outcome of the Government's spending review is known.

Although PPS3 provides for 'windfall' allowance outside the first 10 year period of the Plan, this element of housing land supply cannot be relied upon for the reasons acknowledged in paragraph 7.56 of the PSCS. If only the 'mid-point' of the housing requirement range is to be taken, then the estimated yield from small windfall sites should be discounted. It might however, be more appropriate to provide for such windfall allowance if the top end of the range in the housing requirement (i.e. 4,100 dwellings net) were to be taken as the overall housing requirement figure for the period 2011 - 2028.

In order to provide increased housing choice and to provide for any delays in anticipated housing coming forward in association with the Bexhill - Hastings link road, potential for new housing in other parts of Bexhill (such as the west of Little Common - paragraph 8.60) is supported. Nevertheless, the PSCS (and the identification of "potential broad locations for future development" shown on Map 2: Bexhill Inset Diagram) should not rule out or prejudice the potential for other urban extensions on land west of the town and this should be a matter for detailed consideration at the Site Allocations DPD stage.

It is also noted that Part (iii) of the Policy refers to "a strategic site" and Map 2: Bexhill Inset Diagram refers to a "strategic growth location" on the north eastern side of the town. There is however, no supporting text in the PSCS to define what is meant by 'strategic growth' (in terms of number of dwellings) or how much of this is dependant upon the road link scheme being implemented. As a consequence, Part (ii) of the Policy is vague, as it is not clear if the entire 2,050 - 2,250 dwellings are dependant upon the road scheme or what alternatives would be considered if this road scheme were not to materialise or if it were to be significantly delayed.

Paragraph 11.8 suggests that between 400 - 440 new dwellings might be accommodated in Battle during the Plan period. Paragraph 11.9 states that taking into account existing commitments and allocations (as well as a small element of potential windfall sites - Appendix 3), a further 100 dwellings might need to be allocated (although Appendix 3 refers to a 82 - 122 dwelling range).

If it is found that the PSCS is in conflict with the housing requirements set out in the South East Plan and/or if the Bexhill - Hastings link road scheme is delayed or shelved, there may be a need to redistribute housing growth in other parts of the District. As one of the District's three main towns, future housing growth at Battle beyond the 100 dwelling figure/82 - 122 dwelling range, should not be ruled out in such circumstances.

While Battle has environmental constraints, there remains scope for small scale housing growth at peripheral locations around the town and this is a matter that would need detailed investigation at the site allocations DPD stage and should not be prejudiced by the Core Strategy Policy.

Figure 12 (page 81) and Appendix 3 suggests that in years 10 - 15 of the Plan period (2023 - 2028) some 18% of the total housing supply in villages will come from small windfall sites (amounting to 118 dwellings). Given the considerable uncertainty of housing from this form of supply, the overall housing requirement in villages should be increased to provide a contingency against such windfall housing failing to materialise. If supply from this source were to materialise, then through annual monitoring, the release of allocated housing sites could then be held back for later release.

The range of 950 - 1,000 additional dwellings in villages (paragraph 12.13 and part (v) of the Policy) or the 975 dwelling mid-point (Appendix 3) implies a substantial reduction in the level of housing supply in rural settlements compared to the 20 year period between 1987 - 2007 when 2,300 dwellings were constructed (paragraph 12.14). This housing development has been achieved with little obvious detriment to villages or their rural settings and has been important in order to sustain village shops, public transport and community services as well as providing for housing choice and market-led affordable housing. There is insufficient justification given in the PSCS to support the claim (in paragraph 12.14) that the past rate of housing development "is an unsustainable trend", particularly in view of the high level of housing need within rural areas and the importance of rural settlements generally in contribution to overall housing supply in the District.

The relative importance of historic farm buildings in Rother District is overstated in the PSCS, as they are no different from similar historic farm buildings found elsewhere in the County, region and country as a whole. There is no national or regional policy that resists the conversion of such buildings for residential use and the proposed local Rother requirement for priority to be given to conversion for affordable housing only is wholly misconceived on a number of grounds.

The costs of converting traditional farm buildings (and in particular listed buildings) would not be viable for use as affordable housing. There is no evidence that registered social housing providers would be willing to take on such schemes or willing to finance or maintain such housing, as is invariably such buildings are likely to relate to individual properties in relatively isolated rural locations away from main settlements and services.

Part (iii) (b) of Policy RA3 and part (i) of Policy RA4 are not consistent with any national planning guidance contained in PPS3, PPS4 or PPS7 and is inconsistent with the emerging National Planning Framework Document (see paragraph 113). There are no policies in the South East Plan (which remains part of the Statutory Development Plan) to justify such a tight control over potential residential use of rural buildings. Indeed, the highly restricted nature of the policy flies in the face of Government announcements relating to the potential relaxation of controls regarding the re-use of commercial buildings (see for example the recent consultation on proposals to amend the Use Classes Order in this respect and also the March 2011 HM Treasury report "The Plan for Growth", paragraphs 1.34, 2.22 - 2.23 and page 49). These elements of draft Policies RA3 and RA4 should therefore, be deleted or substantially revised in relation to open market residential re-use of rural buildings.

The relative importance of historic farm buildings in Rother District is overstated in the PSCS, as they are no different from similar historic farm buildings found elsewhere in the County, region and country as a whole. There is no national or regional policy that resists the conversion of such buildings for residential use and the proposed local Rother requirement for priority to be given to conversion for affordable housing only is wholly misconceived on a number of grounds.

The costs of converting traditional farm buildings (and in particular listed buildings) would not be viable for use as affordable housing. There is no evidence that registered social housing providers would be willing to take on such schemes or willing to finance or maintain such housing, as is invariably such buildings are likely to relate to individual properties in relatively isolated rural locations away from main settlements and services.

Part (iii) (b) of Policy RA3 and part (i) of Policy RA4 are not consistent with any national planning guidance contained in PPS3, PPS4 or PPS7 and is inconsistent with the emerging National Planning Framework Document (see paragraph 113). There are no policies in the South East Plan (which remains part of the Statutory Development Plan) to justify such a tight control over potential residential use of rural buildings. Indeed, the highly restricted nature of the policy flies in the face of Government announcements relating to the potential relaxation of controls regarding the re-use of commercial buildings (see for example the recent consultation on proposals to amend the Use Classes Order in this respect and also the March 2011 HM Treasury report "The Plan for Growth", paragraphs 1.34, 2.22 - 2.23 and page 49). These elements of draft Policies RA3 and RA4 should therefore, be deleted or substantially revised in relation to open market residential re-use of rural buildings.

Part (v)

While it is acknowledged that there is a high level of need for affordable housing within the rural parts of the district, the 40% requirement of schemes of 5 dwellings or more (or the financial equivalent of 40% affordable housing on sites of 5 dwellings or less) could render open market housing development as being unviable. This is of significance, as the district has a rural character with only 3 principal towns (Bexhill, Battle and Rye) and therefore housing development in rural settlements makes a significant contribution to overall housing supply in the District.

While part of the policy enables an applicant to demonstrate viability in relation to the provision of affordable housing, no clarification is provided as to the level or nature of such justification to satisfy the Council in this respect.

It is also unclear how the Council would manage the financial contribution (part (iv)(b) of the Policy) or how this would be directed towards the provision of affordable housing on other sites that might be specifically allocated for affordable housing, as there is no cross-reference or link to draft Policy LHN4 (Sites for wholly or substantially affordable housing).

Part (iv)

It is not clear how priority would be established for assessing alternative uses of redundant employment sites/premises in relation to community uses, affordable housing and market housing. Furthermore, paragraph 16.23 draws attention to Policy HO2 "regarding the priority of economic potential, rather than affordable housing potential in such situations", however there appears to be no policy HO2 in either part (iii) of the PSCS (Spatial Strategies) or part (iv) (Core Policies) of the PSCS. Therefore, stronger justification and clarification is needed or alternatively, this element of the policy should be deleted..