Main Modifications to the Proposed Submission Core Strategy

Figure 8 should be amended to include the additional SHMA housing shortfall of at least 480-600 dwellings under "Villages" (with at least 200 new dwellings being identified at Robertsbridge). Remove at least 150 at Hastings Fringe and reduce the housing figure for Rye to 250.

We object to the inclusion of Exemption Sites(65 units) as contributing towards the housing figures as these will only meet the affordable needs and not overall need or housing demand especially in rural areas which are likely to be restricted due to AONB. A similar argument applies to Windfall sites (460) where there is likely to be a significant shortfall of housing windfall sites in settlements that fall within the AONB. Therefore these windfall numbers are unlikely to meet the objectively assessed housing needs across the District.

The Councils housing figure of 5700 is a MINIMUM. It is therefore reasonable to ensure that this housing figure of 5700 remains a minimum target that Windfall and Exemption Sites are removed from the housing trajectory given the Councils own acknowledgement that it is not meeting its own identified housing need set out in its SHMA.

We continue to raise concerns on the Council's over reliance upon the contributions of windfall sites given that a large proportion of these windfall sites historically fall within the urban areas of Bexhill, Rye and Battle. Only a very small proportion of windfall sites have been delivered in rural settlements falling within the AONB, e.g. Robertsbridge only delivered 14 dwellings over the period 2006 to 2012 i.e. around two a year. Given the level of affordability, demand and need in the northern part of the district a windfall allowance for a settlement in the AONB should not be relied upon as contributing towards meeting these community's housing needs over the plan period.

In insert paragraph 7.58 particular attention is given to the incidence of large windfall sites, which may increase the actual scale of housing growth over the plan. This is irrelevant as the Councils housing target is a minimum figure and any Windfall allowance should only apply to small sites. In other words potential sites should be identified in the SHLAA or updated in the Annual Monitoring Reports.

The Council state that the 3300 housing target for Bexhill would deliver 200pa over the remaining 15 years i.e. 3000 dwellings some 200 short of its target and 235 less than the full SHLAA capacity.

More revealing is the fact that only an average of 130 dwellings pa were built from 2001-2007, when economic conditions were clearly more favourable. In the past 12 years output of new homes in Bexhill has only exceeded 200 new homes in one year, and has exceeded 150 new homes in only 5 out of the 12 years. The Wessex Economics report on Housing Delivery at Bexhill and Hastings (June 2013) concluded that the 200 homes pa was challenging as market capacity and potential impact on sale values could lead to oversupply becoming a deterrent on high volumes of new building.

The evidence over the last 12 years backs this up. For the Council to suggest this was due to no major land releases being available over the previous 12 years suggests that Bexhill had no more than 200 units pa available with planning consent in the Bexhill area over that period. This is clearly not correct.What limited the supply of housing was market demand and affordability of new homes in Bexhill over that period. Indeed an arguement can clearly be made that large land releases controlled by one or two large house builders would actually reduce housing supply and choice within Bexhill area in the future.

The current housing trajectory shows housing completions in Bexhill increasing from 29 new homes in 2012/13 to a peak of 290 new homes in 2015/16(in just 2 years time). There is NO evidence for such a leap in delivery justifying this level of increase.

There remains real limitations to further growth in Bexhill because at this level of housing it does not reduce flows on the A259 east of the town centre, while already planned development may not leave any capacity for further flows on local roads in the area confirmed within Mott MacDonald LDF Sensitivity Assessment. (July 2013)

The council have deleted and ignored its own evidence base with the removal of the justified target of around 150 dwellings pa over the later period of the previous Plan deliverable at Bexhill which they previously acknowledged "is equivalent to the rate of house building over the past 5 years"(para8.53). Nothing has changed since the publication of their deposit plan that can justify them abandoning this rate of housing delivery at Bexhill just so it can meet a new housing target for the town.

The Council acknowledge that no evidence exists for the support of development at Breadsell Farm, yet has included a figure of 150 dwellings as a proportion for this site. Clearly the Council would prefer to a consider a site with NO supporting evidence yet fail to undertake its on Landscape Capacity Study that would deliver the evidence that might support a greater housing provision at other sustainable settlements e.g. Robertsbridge

Policy HF1 delete 100-250 net additional dwellings and re-instate 45-80. No new evidence has appeared that would justify the amended figure.

The Council acknowledge that "Given the environmental constraints surrounding Rye; the uncertainty surrounding the deliverability of existing allocations and limited opportunity within the existing built up environment it would be appropriate to adopt a range of housing to allow for some flexibility" The Council then proceed to INCREASE the housing range to 355-400.The Council accept that the redevelopment at Rock Channel is unlikely yet the area is still retained as a "broad location" to maintain the option, "but the likely yield is much reduced; it may well be nothing"( para 49 Rother DC Summary Appraisal)

The Councils INSERT suggest there is scope for further existing commercial sites for mixed use, subject to detailed assessment. However, the Council does not provide the evidence to confirm the scale or nature of these opportunities or assess how these employment sites might be replaced. Little to no reliance can be placed on this amendment. Its not positively prepared, unjustified and ineffective.

Policy RY1 (v) delete figure 355-400 in Paragraph v. This figure is not justified or effective.