Main Modifications to the Proposed Submission Core Strategy

The Councils broad strategy to focus development along the coastal part of the District is based upon an obsolete SE Plan Strategy now revoked. The Council has an obligation under its 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.

At present the best estimate for housing demand, implied from trend -based household projections, shows a requirement for 9979 dwellings in the period 2011-2028 for Rother. The equivalent figure for Hasting Council is 7493(What House Where. Rother DC SHMA 2013 suggest a figure of 6178 dwellings for its District and 6863 figure for Hasting. Assuming for the moment the Councils figures are correct they have an obligation to meet these housing needs within the administrative boundaries unless they can prove this need is being met by an adjoining authority.

A further consideration is that Hasting BC confirms it cannot meet all its assessed housing needs in its Borough. Based upon its Proposed Modifications it will fall short by some 3200 dwellings. Hasting have indeed asked Rother whether they could accommodate "some or all its current need". Rother has rejected this request based on environmental and infrastructure constraints. However, the option to meet some of the Hasting housing need has not been tested. As a fundamental component of the landscape character of a large part of Rother is that over 80% of the District falls within an AONB. It would therefore seem crucial in any assessment of housing capacity that a robust landscape assessment of all potential SHLAA sites is undertaken to judge the balance between its obligation to give "significant weight to support economic growth"(par 19 NPPF)and to meet its development needs(para 47)set against the "great weight" given to conserve the AONB(para 115). Failure by the Council to undertake a review of its landscape assessment makes the Council's claim that there is no capacity to either meet its own objectively assessed housing need or contribute to those of Hastings need unsound.

It is important to recognise that both Hasting BC and Rother DC have for some time acknowledged that these two authorities operate as a well established "Housing Market Area". It has not attempted to extend its SHMA to other adjoining authorities. It therefore falls upon these two authorities to make ever effort to meet is objectively assessed needs within its SHMA.

Further supporting evidence to this representations:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

It is wrong for the Council to purely measure its own objective of economic growth against those of its neighbouring authorities or those of the nation as a whole. Rother DC does not operate as an economic island. Its ambition to reduce net out-commuting with the implication being that a reduced housing provision would help achieve this objective is contrary to the NPPF. The NPPF sets out the need for Councils to meet their development needs within its SHMA. The Plan should be positively prepared and should include an acknowledgement that the district of Rother operates across larger economic areas than that of its own District. The suggestion that a lower level of housing provision might engineer some sort of control over reducing unemployment and increase labour force participation is ill informed and contrary to the Governments commitment to build a strong, competitive economy.

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 Hasting housing needs.

It fails to do so because it lacks the appropriate evidence in the form of a Landscape Capacity Assessment which could highlight capacity at sustainable market towns within the District. The lack of this information also impairs its robust assessment of its ability to meet its own SHMA needs.

The SA 2013 report considers two options. Option B3 figure of 5700 dwellings(335pa)and Option B4 figure of 6180 dwellings(363)which represents its current SHMA.

The additional figure of 480(28pa)required to meet the SHMA is however considered to have greater impact on the District over the plan period. However when you compare this against the Scale of Growth proposed in the Deposit Plan(SA 2008)under Option 2 (SE Plan figure of 280pa+ 25% = 350 pa)it suggest a significant impact compared to the Option B(SA 2013)figure of 335pa. Indeed the current SA suggests at the level of 335 pa many of the sustainable objectives are neutral yet in 2008 a figure of 350 pa was found to have a significant impact hence it was rejected. The SHMA 2013 report suggests a figure of 363 dwellings pa needed as a minimum to meet its housing needs. In reality this is only 480 dwellings(28pa)more than the Council now feel is sustainable. Much of the commentary made between Option B3 and B4 in the 2013 SA is exactly the same implying little if any significant change between these Options. What is needed is an assessment which attempts to define the "tipping point" in landscape capacity where housing numbers would have a " significant and demonstrable harm that would outweigh the benefits" when measured against the 3 dimensions to sustainable development: economic, social and environmental.

The insert paragraph 7.22 claims that it recognises that a higher housing figure is achievable largely by giving greater weight to meeting its housing objectives. Yet also claims that to deliver the additional 480 dwellings needed to meet its objectively assessed housing needs would be unsustainable. However the evidence for this claim is not available in particular the capacity for settlements in the AONB to contribute further towards meeting this need. This is an important component of the Councils evidence base when you appreciate the Council consider further options to expand Bexhill limited in housing market terms and has transport capacity constraints.

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.

Further supporting evidence to support this representation can be accessed here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

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.

Insert Paragraph 7.36 refers to the SHLAA Review undertaken in 2013. The Councils review is both limited and flawed.

The Council rightly qualify its SHLAA by its limitation to available information (no update of landscape assessment since 2008/9 and no landscape capacity study) "and for the most part, draws on local knowledge of Town & Parish representatives" (para 12 Summary of Sustainable Housing Growth July 2013) 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. This town is the largest of the Rural Settlements with excellent transport links, facilities and employment. It is therefore capable of accommodating greater housing numbers beyond the 100 units proposed when compared to Battle(500). Both settlements fall within AONB. On a pure population comparison between these two settlements Robertsbridge should be capable of delivering around 200 additional dwellings subject to an appropriate landscape capacity assessment.

The Council previously in 2010 prepared their first SHLAA which rejected Land at Bishops Lane, Robertsbridge as a suitable housing site due to landscape and access constraints. At the last Examination the Council confirmed its intention to review it SHLAA which it did in 2013.It accepted at the Inquiry following submissions from our landscape consultant reports in 2007 and 2010(David Huskisson Assoc)that a review of the landscape capacity of the sustainable settlements would be undertaken. This has not been done and no evidence has been submitted to justify the Councils latest assessment of this site or others within the SHLAA. The Inspectors letter to the Council on the 7th May 2013 states that it is important to recognise that the NPPF requires authorities to meet the full objectively assessed needs for housing."Conflict with other policies in the Framework is not a reason to reduce the starting point of the full objectively assessed need". The Council cite on several occasions as a constraint the AONB. Paragraph 115 of the NPPF indicates that great weight should be given to conserving landscape and scenic beauty in AONBs. It does not, however, include a presumption against development in an AONB and paragraph 19 and 28 seeks to support a prosperous rural economy.

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.

Further submitted documents to support this representation can be accessed using the following links:
http://www.rother.gov.uk/CHttpHandler.ashx?id=20562
http://www.rother.gov.uk/CHttpHandler.ashx?id=20564
http://www.rother.gov.uk/CHttpHandler.ashx?id=20568
http://www.rother.gov.uk/CHttpHandler.ashx?id=20569
http://www.rother.gov.uk/CHttpHandler.ashx?id=20570
http://www.rother.gov.uk/CHttpHandler.ashx?id=20571
http://www.rother.gov.uk/CHttpHandler.ashx?id=20572
http://www.rother.gov.uk/CHttpHandler.ashx?id=20573
http://www.rother.gov.uk/CHttpHandler.ashx?id=20566
http://www.rother.gov.uk/CHttpHandler.ashx?id=20567

The identification of Bexhill to accommodate additional housing is assessed in the Councils "Housing Delivery in Bexhill and Hastings" and its "Transport Study" undertaken in June and July 2013.The Housing Delivery report concluded. "A number of benchmarks would indicate that it will be challenging to consistently deliver more than 200 homes pa, year in year out, both because of market capacity; and the potential impact on sales values of new homes, if the market is relatively oversupplied, since this will act as a deterrent to high volumes of new building". Bexhill has only twice in the last 20 years delivered 200 units plus pa.

The Councils LDF Sensitivity Assessment( July 2013) into the impact of various combinations of development in Bexhill Hasting area concluded that the main capacity constraint in the local Glyne Gap area is the A259 Glyne Gap link. The greater scale of housing in each of the scenarios assessed inevitably generates more traffic on the local network, which will have detrimental effects leading to some junctions on the A259 operating over capacity by 2028.For each of the scenarios assessed, congestion is visible at junctions along the major routes through the urban areas. Congestion in Bexhill occurs at some arms of junctions, notably along the A259 west of the town centre and also on a section of the A259.

The report states that there are "apparent capacity issues with the A259 west of town centre and suggests further modelling is required. That work will need to be undertaken with the Highway Agency who are responsible for the A259 west of town centre. "Subject to this,the implications for housing may be to limit the scale of housing served by the A259 west of the town centre".

Congestion in Hasting is centred along the A259 , around Baldslow and junctions along B2159 and A21 through Hollington. This combined with the English Nature objections to development at Breadsell Farm makes the Council figure of 250 dwellings unjustified and ineffective and this figure should therefore be removed.

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.

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.

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.