Local Plan Supporting Evidence Base Documents

Comment

Representation ID: 27453

Received: 22/07/2024

Respondent: Home Builders Federation

5. For co-operation to be effective, and for solutions to be found, Councils need to actively try and address the issue at hand. At present there appears to be an acceptance that housing needs will not be met and that the act of writing to other authorities is sufficient for the duty to be met. In effect consideration of unmet housing needs has become a tick box exercise. The HBF would question whether this co-operation meets the test set out in 33A(2)(a) of the PCPA which requires the LPA to engage constructively. For engagement to be constructive it needs to move beyond writing to each other and actively engage in identifying solutions. If no solution is forthcoming from any constructive engagement, with no authority willing to take action to help another with regard to housing needs, the Council need to consider the shortfall in housing across this area and feed this back into the Council’s decision-making process and the SA.

Comment

Representation ID: 27458

Received: 22/07/2024

Respondent: Home Builders Federation

Sustainability Appraisal of the potential spatial development options:

37. The Development Strategy Background Paper sets out 13 spatial development options for the Borough with the Council noting that these have all been individually assessed through the Sustainability Appraisal. What is notable is that not all of these options have indicated estimates as to how much development each would deliver. This makes it difficult to consider how appropriate these are, and of course to effectively appraise each option. With regard housing for example Figure 11 of the SA/SEA shows that against the housing objective each option scores a double or single positive. Given that even a combination of each of these options sees housing supply fall well short of meeting housing needs this assessment within the SA/SEA would appear to be fundamentally flawed and cannot be a robust assessment as to the impacts not only with regard to housing but many of the other options. In order to assess the impact of a development option the council must have some idea as to the scale of development that would be expected.

38. From these 13 options the Council have then arrived at the proposed spatial development strategy. However, what is notable is that only one spatial development strategy has been considered from the 13 options. The justification for not considering other reasonable alternatives is that all potential sites have been considered within the SA, including those rejected through the HELAA that these assessments form the consideration of reasonable alternatives.

39. However, HBF would consider such an approach to be inappropriate as it fails to even consider the potential for the Council meeting its housing needs in full through an alternative strategy. Whilst this would require the Council to assesses strategies potentially including some sites that have been rejected within the HELAA, it would have enabled the council to assess the overall harm arising from different spatial strategies and compared to the potential benefits of such strategies against the harm. In essence the Council have rejected potential strategies that may have had more of an impact in landscape terms but had significantly higher social and economic benefits which may have outweighed that harm. In essence the collective benefits of further development may outweigh the harm of these alternative strategies with regard to landscape or other issues, especially where the harm can be mitigated but the potential of such strategies has been ignored. The Council have also failed to assess the potential; impact of not meeting need sin full on neighbouring areas and adding to the cumulative shortfall in East Sussex. The impact of not meeting needs will have wider consequences and these need to be clearly set out within the SA.

40. In only considering sites this wider assessment of different strategies has not been undertaken by the council and as such the SA has failed to properly assess reasonable alternatives with regard the spatial strategy and cannot be relied on by the council to support its plan making process. The Council must consider reasonable alternative strategies that meeting housing needs alongside the strategy set out in the draft local plan to consider whether they may offer a more sustainable approach to development in Rother.

Comment

Representation ID: 27459

Received: 22/07/2024

Respondent: Home Builders Federation

Sustainability Appraisal of the Proposed Strategy:
41. What is notable about the SA of the proposed strategy with regard to housing is the way the question is posed within the assessment framework. The SA objective (8) for housing in the assessment of the strategy policies in the Draft Local Plan asks whether the strategy provides more opportunities for everyone to be in a suitable home to meet their needs. Such the objective has been deliberately written to allow the council to show this as being a positive assessment within the SA with regard to this objective. This is disingenuous and means that the SA has no credibility. In assessing the sustainability of a strategy a policy, the Council should be asking whether it meets the identified need for market and affordable housing in Rother. It is notable that the Council’s SA makes no reference, or at least we could find no reference, to housing needs and the shortfall in meeting those needs as a result of the proposed strategy. Alongside this no reference is made to fact that neighbouring authorities are also unable to meet their own housing needs leaving a substantial shortfall against identified needs over the next 15 years of around 27,500 homes. What is evident is that when considered against a more appropriate phrased objective the local plan will have significant negative consequences that need to be properly considered.

42. The scale of the shortfall in market and affordable housing would also impact on other objectives, such as those relating to health and wellbeing, with a higher chance of negative health outcomes due to a lack of affordable and good quality accommodation. The outcome in relation to climate change would also be different with more people living in less energy efficient homes that emit significantly more carbon. The Council may decide that the negative impacts arising from such a significant shortfall in housing are acceptable, but in arriving at that conclusion it must ensure that such issues are front and centre in its decision making and the documents that support it.

Comment

Representation ID: 27461

Received: 22/07/2024

Respondent: Home Builders Federation

Site assessments:
45. The Council will need to ensure that its assessment as to the constraints on sites excluded from the plan are consistent with national policy. In particular the council must not consider the strategic gap between Bexhill and Hastings to be a constraint on development on a par with the AONB or any other footnote 7 constraints. As the Council will be aware the NPPF does not mention strategic gaps and provides no guidance on their use. Whilst such local designations have been included in many local plans it is important to ensure that when preparing a new plan and considering new sites, strategic gaps are not used as a justification for not allocating a site or for the restriction of development as a whole within Rother.

46. It will also be vital that the council seeks to maximise development on each site it does allocate give the significant shortfall between housing needs and supply. The Council should look to ensure that all land within submitted sites that are considered suitable for development are allocated for development.