Main Modifications to the Proposed Submission Core Strategy

The proposed text for the new paragraph 7.10 quotes selectively, and omits references to the requirement in paragraph 47 of the NPPF to meet housing needs within the housing market area. It is clear that the Council regard the housing market area as containing both the Rother and Hastings local authority areas, given the decision of these authorities to undertake a joint SHMA, and the reference later in the proposed paragraph to the shortfall in capacity in Hastings Borough. However, as drafted the paragraph doesn't make it clear why the shortfall in capacity in Hastings Borough is relevant, as it makes no reference to the need for housing in Hastings, or to the level of housing which can be delivered within that Borough.

This paragraph should be amended to make clear reference to the housing market area. It should also specify the level of housing required in the housing market area, and the level which the two authorities' emerging Local Plans are set to deliver.

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We note in our representation on proposed modification 12.6 that the additional text which is proposed to follow Figure 12 would seek to restrict the level of development in the rural area if 'previously unidentified' sites were to come forward in advance of a site allocations DPD.

We understand that these 'previously unidentified' sites would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.

We support the principle of expressing the new housing requirement as a minimum figure, as this will ensure the supply of housing will not be constrained in the future, should it prove possible to deliver a greater level of housing than the Council currently anticipate.

The reference in the footnote to the 'lower end of the range', with regard to the housing target, appears to be related to the previous proposals and not the revised housing target, and it should be deleted.

The reference in the footnote to the 'lower end of the range', with regard to the housing target, appears to be related to the previous proposals and not the revised housing target, and it should be deleted.

The additional sentence, taken with the preceding text, implies that the level of development being planned for may be restricted in the future. This is inconsistent with the proposal that the housing target should be a minimum figure (proposed modification 7.6). The proposed housing figure has in any case only been limited due to the Council's belief that there may be limited capacity for development within the District. The Council's evidence shows that there is a need for more housing tom be delivered within the housing market area than has been proposed in these modifications.

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We understand that the 'previously unidentified' sites referred to here would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.

These modifications assume that it is necessary for the level of housing which is to be provided to be constrained in some way if the level of jobs which are created within the plan period is below the level the Council would wish to see. However, as we have previously explained in our evidence, and comments at the Examination hearings, this assumption is flawed.

The provision of housing actually helps to stimulate the economy, and housing is clearly identified as an economic driver throughout the NPPF. A greater level of housing provides accommodation for a resident work force, reducing prices, providing affordable housing, and generally making it possible for people to live close to where they work. Without new housing, local employers are more likely to relocate away from an area, as they find it more difficult to recruit staff, particularly those who are paid less.

Housing itself also helps to stimulate the creation of new jobs through the construction industry, and the secondary generation of employment through related industries.

There is no evidence which suggests that it is necessary to limit the amount of housing in order to allow the number of jobs in the area to "catch up" in some way. Neither is there any evidence which suggests that constraining the amount of housing will in some way help to stimulate the provision of new jobs, and the available evidence actually suggests quite the opposite. To restrict the level of housing based on these spurious grounds would be contrary to paragraph 47 of the NPPF. These proposed modifications should therefore be deleted.

We support the proposed increase in the level of development in the villages in the rural area, and particularly the focus of the larger quantum of development in the most sustainable settlements, such as Northiam. Consistent with our representations on other modifications, and the Council's proposed modification 7.6, the footnotes to the table should make it clear that the housing targets are themselves minima.

The additional text which is proposed to follow Figure 12 would seek to restrict the level of development in the rural area if 'previously unidentified' sites were to come forward in advance of a site allocations DPD. This proposed modification appears to be inconsistent with the new housing target, which is a minimum figure (proposed modification 7.6), and which has only been limited due to the Council's belief that there may be limited capacity for development within the District. The Council's evidence shows that there is a need for more housing tom be delivered within the housing market area than has been proposed in these modifications.

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We understand that the 'previously unidentified' sites referred to here would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.

This proposed modification assumes that it is necessary for the level of housing which is to be provided to be constrained in some way if the level of jobs which are created within the plan period is below the level the Council would wish to see. However, as we have previously explained in our evidence, and comments at the Examination hearings, this assumption is flawed.

The provision of housing actually helps to stimulate the economy, and housing is clearly identified as an economic driver throughout the NPPF. A greater level of housing provides accommodation for a resident work force, reducing prices, providing affordable housing, and generally making it possible for people to live close to where they work. Without new housing, local employers are more likely to relocate away from an area, as they find it more difficult to recruit staff, particularly those who are paid less.

Housing itself also helps to stimulate the creation of new jobs through the construction industry, and the secondary generation of employment through related industries.

There is no evidence which suggests that it is necessary to limit the amount of housing in order to allow the number of jobs in the area to "catch up" in some way. Neither is there any evidence which suggests that constraining the amount of housing will in some way help to stimulate the provision of new jobs, and the available evidence actually suggests quite the opposite. To restrict the level of housing based on these spurious grounds would be contrary to paragraph 47 of the NPPF. This proposed modification should therefore be deleted.