Main Modifications to the Proposed Submission Core Strategy

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Object

Main Modifications to the Proposed Submission Core Strategy

MOD 2.2

Representation ID: 21299

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils broad strategy to focus development along the coastal part of the District is based upon SE Plan -now revoked. The Council has an obligation under Duty to Cooperate to work with Local Planning authorities on "strategic priorities" which should be properly coordinated and clearly reflected in individual Local Plans.
The Councils latest response to this obligation is to send out a letter questionnaire to all neighbouring authorities. NPPF duty to cooperate requires a greater robust approach to enable Rother DC to prove it can indeed meet its objectively assessed development needs and thus prove its Plan is sound.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.1

Representation ID: 21300

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Rother need to meet its objectively assessed development needs and some of those identified for Hastings. It needs to update its landscape evidence to test its capacity to meet these needs and test these against the SHLAA and undertake a fresh Sustainability Appraisal. Until this process is complete the Plan will be unsound.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.2

Representation ID: 21301

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council must acknowledge that it operates within a much larger economic area than that of its own District and must accept that its belief that a lower housing provision would help meet its employment and economic objectives is unsound.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.4

Representation ID: 21302

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils Sustainability Appraisal 2013(SA)only considers two options; one for its housing figure of 5700; and the second for the SHMA figure of 6180. It does not consider the third option of attempting to meet some of Hastings housing needs.

It fails to do so because it lacks evidence in the form of a Landscape Capacity Assessment. This lack of information also impairs its ability to meet SHMA needs.

At present we have a Council unwilling to meet its own housing needs nor carryout the appropriate assessments that could enable it to contribute towards meeting its Strategic Housing Market needs.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.6

Representation ID: 21303

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The insert paragraph 7.29 and 7.30 only confirm that over the last 20 years Rother has failed to meet its objectively assessed housing needs.

The Council acknowledge that "possible opportunities for further housing over time cannot be ruled out" hence the Council has set a minimum housing target of 5700 dwellings over the Plan period. This suggests that there is already additional housing capacity available that has just not been properly assessed.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.7

Representation ID: 21304

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils SHLAA review is both limited and flawed (no update of landscape assessment since 2008/9 and no landscape capacity study) but acknowledge that all sites require further investigations. In practice little to no addition evidence has been provided to justify the arbitrary capacity restrictions to settlements such as Robertbridge.

The SHLAA review appears to meet only the housing figure set out in the Modification Plan and not the capacity of the District as a whole.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.8

Representation ID: 21305

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Bexhill housing capacity should be re-assessed in the light of its ability to deliver 200pa consistently over the plan period together with the question of the towns ability to overcome significant highway problems. The "Hastings Fringe" has English Nature objections and also highway problems which suggest the housing numbers put forward in this area of the Plan by the Council are not deliverable.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.9

Representation ID: 21306

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Councils housing figure for Rye is unsound. It appears to rely upon " broad locations in the SHLAA, to maintain the option, but the likely yield is much reduced; it may well be nothing" (Councils Summary Appraisal on Housing Growth July 2013). The Council suggest further opportunities for identifying housing through redevelopment schemes none of which are identified or proven to be deliverable over the plan period.

For the Council (based upon the above) to suggest that a figure of 355/400 dwellings is deliverable in Rye is unjustified as this figure has not been robustly assessed.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.11

Representation ID: 21307

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It is inappropriate to limit large sustainable settlements such as Robertsbridge to meet only "local needs". This approach is contrary to NPPF which requires Plans to be positively prepared to meet its objectively assessed housing and employment needs. This should correctly include all sustainable settlements capable of helping to meet this need.

Object

Main Modifications to the Proposed Submission Core Strategy

MOD 7.13

Representation ID: 21308

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy OSS1 (i) Object to housing figure 5700 as this does not meet the Councils objectively assessed housing needs.

(iii)(c) object to the presumption that growth in villages should be limited especially were evidence exists to suggest that the potential for growth may be greater. The Council have fundamentally failed to assess the capacity of sustainable villages (such as Robertsbridge) to accommodate greater levels of housing because it has failed to carryout the necessary investigation into the Landscape Capacity of the settlements that fall within the AONB.

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