Proposed Submission Core Strategy

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Object

Proposed Submission Core Strategy

Policy OSS1 - Overall Spatial Development Strategy

Representation ID: 21111

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Part (i)-Annual housing requirements would be better stated as a single figure, rather than a range. It is unclear why a specific figure is not stated.

Insufficient justification is provided for departing from SE-Plan requirements. Assuming the Link Road is constructed, there is no justification for a reduction in housing numbers.

Other East Sussex Authorities are putting forward similar reasons for reduced housing numbers. Unless SE Plan targets are met, there will be an increasing shortfall of regional housing supply.

Part (iii)-The policy contains no cross-reference to Policy OSS2, therefore provides no contingency arrangement should the Link road be delayed/shelved.

Object

Proposed Submission Core Strategy

Policy OSS2: Bexhill to Hastings Link Road and development

Representation ID: 21112

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Government announcement regarding Link Road funding is imminent. The road is fundamental to the proposed strategy. It is appropriate to suspend the PSCS until the Link Roads future is known. Policy OSS2 introduces uncertainty.

If the road scheme were to be shelved/delayed, then alternatives should be considered to meet future housing needs. If the road scheme is shelved, then detailed investigation (SHLAA based) needs to be undertaken to consider housing potential in other locations.

Reducing Bexhill's housing development if the Link Road were shelved would have serious consequences. Alternatively, the Examination should be suspended until the outcome of Spending Review is known.

Object

Proposed Submission Core Strategy

7.57

Representation ID: 21113

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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 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.

Object

Proposed Submission Core Strategy

Policy BX3: Development Strategy

Representation ID: 21114

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

To provide increased housing choice and for delays in housing coming forward, 8.60 is supported.

Nevertheless, "potential broad locations for future development" shown on Map 2:Bexhill Inset Diagram should not rule out or prejudice potential for other urban extensions.

Part (iii) refers to "a strategic site" and Map 2:Bexhill Inset Diagram refers to a "strategic growth location" at northeast Bexhill. There is no supporting text to define 'strategic growth' or how much is Link Road dependant. Part (ii) is vague, it is unclear if the entire 2,050-2,250 dwellings are Link Road dependant or what alternatives would be considered if it was delayed/shelved.

Object

Proposed Submission Core Strategy

Policy BA1: Policy Framework for Battle

Representation ID: 21115

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

If it is found that the PSCS is in conflict with the housing requirements in the South East Plan and/or if the Link Road is delayed/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 range, should not be ruled out.

While Battle has environmental constraints, there remains scope for small-scale housing growth at peripheral locations and there should be detailed investigation in the site allocations DPD and should not be prejudiced by the Core Strategy.

Object

Proposed Submission Core Strategy

Policy RA1: Villages

Representation ID: 21116

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Figure 12 and Appendix 3 suggests that in years 10-15 of the Plan period 18% of total housing supply in villages will come from small windfall sites. Given the uncertainty from this form of supply, overall housing requirements should be increased.

The range of 950-1,000 additional dwellings in villages implies a substantial reduction in housing in rural settlements compared to the 20-year period between 1987-2007 when 2,300 dwellings were constructed. There is insufficient justification to support that the past rate of housing development "is an unsustainable trend", particularly in view of the high level of housing need within rural areas.

Object

Proposed Submission Core Strategy

Policy RA3: Development in the Countryside

Representation ID: 21117

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The relative importance of historic farm buildings in Rother is overstated they are no different from similar historic farm buildings found elsewhere. There is no national or regional policy that resists the conversion for residential use and the proposed Rother requirement for priority to be given to conversion for affordable housing is misconceived.

The costs of converting traditional farm buildings would be unviable as affordable housing.

Part i) of Policy RA4 is not consistent with national planning guidance and the emerging National Planning Framework (paragraph 113). There are no policies in the South East Plan to justify such tight control.

Object

Proposed Submission Core Strategy

Policy RA4: Traditional Historic Farm Buildings

Representation ID: 21118

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The relative importance of historic farm buildings in Rother is overstated they are no different from similar historic farm buildings found elsewhere. There is no national or regional policy that resists the conversion for residential use and the proposed Rother requirement for priority to be given to conversion for affordable housing is misconceived.

The costs of converting traditional farm buildings would be unviable as affordable housing.

Part i) of Policy RA4 is not consistent with national planning guidance and the emerging National Planning Framework (paragraph 113). There are no policies in the South East Plan to justify such tight control.

Object

Proposed Submission Core Strategy

Policy LHN2: Affordable Housing

Representation ID: 21119

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Part (v)

While it is acknowledged that there is a high level of need within the rural parts, the 40% requirement could render open market housing development as unviable. This is of significance, as housing development in rural settlements makes a significant contribution to overall housing.

While the policy enables an applicant to demonstrate viability, no clarification is provided as to the level or nature of such justification.

It is also unclear how the Council would manage financial contributions or be directed towards the provision of affordable housing.

Object

Proposed Submission Core Strategy

16.23

Representation ID: 21120

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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..

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