Main Modifications to the Proposed Submission Core Strategy

Search representations

Results for Town and Country Planning Solutions search

New search New search

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.1

Representation ID: 21577

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.5

Representation ID: 21578

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.6

Representation ID: 21579

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.12

Representation ID: 21580

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.13

Representation ID: 21581

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.14

Representation ID: 21582

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.15

Representation ID: 21583

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA (June 2013) states, based upon ESCC's 2011 demographic projections, there is a need for 6,180 homes in Rother (2011/2028). Within the 'HOUSING Market Area' there is a need for 13,000 homes within Rother/Hastings 2011/2028.

Within Hastings, Policy DS1 states "3,400 net new homes" will be provided 2011/2028, a shortfall of 3,460 dwellings (50.4%) compared to the need.

Rother and Hastings have a combined shortfall of 3,940.

The(June 2013) SHLAA assesses a potential supply of 6,139 dwellings over the Plan. This is 439 dwellings more than the modification of at least 5,700 dwellings, suggesting scope to increase housing provision.

Full text:

The Revised Housing Requirement
Proposed Modification Nos. MOD 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15

1. These representations (TCPS Representations No. 1), relate to Rother District Council's proposed revision to the housing requirement set out in the schedule of Main Modifications dated August 2013.

2. The updated Strategic Housing Market Assessment published in June
2013 states that, based upon East Sussex County Council's 2011 demographic projections, there is a need for 6,180 more homes in Rother District (363 dwellings per year- dpa) over the 2011 - 2028 Plan period. Within the 'HOUSING Market Area' there is a combined need for 13,000 new homes (767 dpa) needed within both Rother District and Hastings Borough (6,860 new homes- 404 dpa) over the same period.

3. Modification numbers 7.5, 7.12 and 7.13 states that "at least 5,700 dwellings (net)" will be provided within the District between 2011 - 2028. This leaves however, a shortfall of some 480 dwellings (8%) compared to the assessed need in the District.

4. Within Hastings Borough, draft Policy DS1 of the Borough Council's Proposed Submission version of 'The Hastings Planning Strategy' states that "3,400 net new homes" will be provided during the period 2011 - 2028 leaving a shortfall of some 3,460 dwellings (50.4%) compared to the assessed level of need. In the Borough Council's 'Proposed Main Modifications' published in May 2013 (which were recently the subject of a further Public Examination), there is no proposal to increase the housing supply notwithstanding the significant shortfall.

5. Thus, within both Rother District and Hastings Borough there will be a combined shortfall of some 3,940 dwellings over both Plan period compared to the assessed need. This raised two important questions; Firstly, what further scope is there for Rother District to meet more of its assessed need and secondly, what scope is there for also helping to meet some of the shortfall from neighbouring Hastings Borough (given that it is situated within the same Housing Market Area). Indeed, it is understood that the Borough Council has asked the District Council if it could accommodate some or all of this deficit (see paragraph 7 of the District Council's 'Summary Appraisal of Sustainable Housing Growth').

6. Draft Policy OSS1 of the District Council's Proposed Submission Core
Strategy (August 2011) put forward a requirement for an additional 3,700 - 4,100 dwellings (net) during the Plan period, but this has now been increased to "at least 5,700 dwellings" in the Proposed Modifications. The Council indicate that this has been achieved principally by re-evaluating the Strategic Housing Land Availability Assessment (SHLAA) in its 2013 update "largely on the basis of greater weight given to housing objectives" (MOD 7.4- para 7.22).

7. The updated (June 2013) SHLAA assesses a potential supply (at 1st April
2013) of 6,139 dwellings over the Plan period (including 275 completions between 2011 - 2013). This is 439 dwellings more that the Council's proposed modification requirement of at least 5,700 dwellings, suggesting that there is scope to increase housing provision in the District to a figure of at least 6,139 dwellings, which would be closer to the assessed housing need figure of 6,180 dwellings in the District over the Plan period. There would still be a significant housing need shortfall within the Housing Market Area, but this would help ensure that the District Council at least meets its own projected need as far as possible.

8. Whilst the Council argue that "the potential for further growth elsewhere is seen as impacting increasingly, and significantly, on environmental designations, most noticeably on the conservation of the natural beauty of the High Weald AONB" (MOD 7.4- para 7.23), no background evidence has been produced to support this claim other than the generalities contained in the updated Sustainability Appraisal. Indeed, the Council also states ''the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out, hence, the requirement is expressed as a minimum for the purposes of plan making. This will be further assessed as part of the site allocations/neighbourhood planning process" (MOD 7.6- para 7.30).

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 12.1

Representation ID: 21584

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council's revised housing figure acknowledges more scope for meeting assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (& potentially Hastings fringes), there is also a need to increase the provision in rural settlements as an important contribution to need.

Notwithstanding the proposed figure of "1,670" there may be scope to increase supply within and around villages once potential sites come forward through the site allocations/neighbourhood planning.

Full text:

Rural Areas - Housing in Villages
Proposed Modification Nos. MOD -12.1, 12.2 and 12.4

1. These representations (TCPS Representations No. 2), relate to proposed modification numbers MOD 12.1, 12.2 and 12.4 and should be read in conjunction with representations (TCPS Representations no. 1) made in relation to proposed modification numbers 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15, which make the case that the Plan's housing requirement should be increased from "at least 5,700 dwellings" to "at least 6,200 dwellings': This would then also require consequential changes to paragraph 12.13 (Modification 12.1).

2. The Council's revised housing figure now acknowledges that there is more scope than previously considered for meeting the assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (as well as potentially on the Hastings fringes), there is also a need to increase the provision in (and adjoining) rural settlements so as to make an important contribution to the assessed need. MOD 12.4 proposes to amend Part (v) of Policy RA1 to increase the housing requirement in villages from 950 - 1,000 dwellings (as set out in the Proposed Submission Version of the Plan) to 1,670 dwellings.

3. Modified paragraph 7.41 (MOD 7.11) states 'the housing provision seeks to maximise the contribution that villages can make to sustainable growth without prejudicing their individual character and amenities, as well as those of their shared, for the most part High Weald AONB setting". In terms of the housing figures proposed however, modified paragraph 7.30 (MOD 7.6) states "the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out; hence the requirement is expressed as a minimum for the purpose of Plan making. These will be further assessed as part of site a/locations/neighbourhood planning processes".

4. Thus, notwithstanding the proposed modified figure of "1,670 additional dwellings" now inserted into Policy RA1(v) (MOD 12.4), there may well be scope to increase supply within and around villages once potential sites come forward as part of the subsequent site allocations/neighbourhood planning stage. Indeed, the revised (June 2013) SHLAA estimates that some 6,180 dwellings can be accommodated on potentially suitable, available and deliverable housing sites within the District, and there may well therefore, be scope to increase the potential for adding to housing in and around villages over and above 1,670 additional dwellings as part of a site allocations process.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 12.2

Representation ID: 21585

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council's revised housing figure acknowledges more scope for meeting assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (& potentially Hastings fringes), there is also a need to increase the provision in rural settlements as an important contribution to need.

Notwithstanding the proposed figure of "1,670" there may be scope to increase supply within and around villages once potential sites come forward through the site allocations/neighbourhood planning.

Full text:

Rural Areas - Housing in Villages
Proposed Modification Nos. MOD -12.1, 12.2 and 12.4

1. These representations (TCPS Representations No. 2), relate to proposed modification numbers MOD 12.1, 12.2 and 12.4 and should be read in conjunction with representations (TCPS Representations no. 1) made in relation to proposed modification numbers 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15, which make the case that the Plan's housing requirement should be increased from "at least 5,700 dwellings" to "at least 6,200 dwellings': This would then also require consequential changes to paragraph 12.13 (Modification 12.1).

2. The Council's revised housing figure now acknowledges that there is more scope than previously considered for meeting the assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (as well as potentially on the Hastings fringes), there is also a need to increase the provision in (and adjoining) rural settlements so as to make an important contribution to the assessed need. MOD 12.4 proposes to amend Part (v) of Policy RA1 to increase the housing requirement in villages from 950 - 1,000 dwellings (as set out in the Proposed Submission Version of the Plan) to 1,670 dwellings.

3. Modified paragraph 7.41 (MOD 7.11) states 'the housing provision seeks to maximise the contribution that villages can make to sustainable growth without prejudicing their individual character and amenities, as well as those of their shared, for the most part High Weald AONB setting". In terms of the housing figures proposed however, modified paragraph 7.30 (MOD 7.6) states "the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out; hence the requirement is expressed as a minimum for the purpose of Plan making. These will be further assessed as part of site a/locations/neighbourhood planning processes".

4. Thus, notwithstanding the proposed modified figure of "1,670 additional dwellings" now inserted into Policy RA1(v) (MOD 12.4), there may well be scope to increase supply within and around villages once potential sites come forward as part of the subsequent site allocations/neighbourhood planning stage. Indeed, the revised (June 2013) SHLAA estimates that some 6,180 dwellings can be accommodated on potentially suitable, available and deliverable housing sites within the District, and there may well therefore, be scope to increase the potential for adding to housing in and around villages over and above 1,670 additional dwellings as part of a site allocations process.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 12.4

Representation ID: 21586

Received: 26/09/2013

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council's revised housing figure acknowledges more scope for meeting assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (& potentially Hastings fringes), there is also a need to increase the provision in rural settlements as an important contribution to need.

Notwithstanding the proposed figure of "1,670" there may be scope to increase supply within and around villages once potential sites come forward through the site allocations/neighbourhood planning.

Full text:

Rural Areas - Housing in Villages
Proposed Modification Nos. MOD -12.1, 12.2 and 12.4

1. These representations (TCPS Representations No. 2), relate to proposed modification numbers MOD 12.1, 12.2 and 12.4 and should be read in conjunction with representations (TCPS Representations no. 1) made in relation to proposed modification numbers 7.1, 7.5, 7.6, 7.12, 7.13, 7.14 and 7.15, which make the case that the Plan's housing requirement should be increased from "at least 5,700 dwellings" to "at least 6,200 dwellings': This would then also require consequential changes to paragraph 12.13 (Modification 12.1).

2. The Council's revised housing figure now acknowledges that there is more scope than previously considered for meeting the assessed housing need. While this will require some additional increase in housing provision in the main towns of Bexhill, Battle and Rye (as well as potentially on the Hastings fringes), there is also a need to increase the provision in (and adjoining) rural settlements so as to make an important contribution to the assessed need. MOD 12.4 proposes to amend Part (v) of Policy RA1 to increase the housing requirement in villages from 950 - 1,000 dwellings (as set out in the Proposed Submission Version of the Plan) to 1,670 dwellings.

3. Modified paragraph 7.41 (MOD 7.11) states 'the housing provision seeks to maximise the contribution that villages can make to sustainable growth without prejudicing their individual character and amenities, as well as those of their shared, for the most part High Weald AONB setting". In terms of the housing figures proposed however, modified paragraph 7.30 (MOD 7.6) states "the possibility of further opportunities for sustainable housing (as well as employment) development arising over time cannot be ruled out; hence the requirement is expressed as a minimum for the purpose of Plan making. These will be further assessed as part of site a/locations/neighbourhood planning processes".

4. Thus, notwithstanding the proposed modified figure of "1,670 additional dwellings" now inserted into Policy RA1(v) (MOD 12.4), there may well be scope to increase supply within and around villages once potential sites come forward as part of the subsequent site allocations/neighbourhood planning stage. Indeed, the revised (June 2013) SHLAA estimates that some 6,180 dwellings can be accommodated on potentially suitable, available and deliverable housing sites within the District, and there may well therefore, be scope to increase the potential for adding to housing in and around villages over and above 1,670 additional dwellings as part of a site allocations process.

If you are having trouble using the system, please try our help guide.