This representation is in relation to Policy DS1, paragraphs 4.21 to 4.23 and all other relevant references in the Planning Strategy with respect to the housing target.

Having reviewed the Assessment of Housing Need Background Paper and the content of the proposed submission version of the Hasting Planning Strategy, we raise concerns over the soundness of the Council's total housing requirement as set out within Paragraph 4.21 and Policy DS1.

As the Local Planning Authority, Hasting Borough now has the responsibility to establish what the full, objectively assessed needs are for market and affordable housing which the Strategy is required to address in terms of the requirements of the National Planning Policy Framework (NPPF).

This is crucial to the soundness of the Strategy in terms of its consistency with national policy. Paragraph 159 of the Framework indicates that, amongst other things, the Strategic Housing Market Assessment should identify the scale of housing that meets household and population projections and caters for housing demand. Once this is established, and if the provision in the plan is less than (or greater than) the full, objectively assessed needs, then consideration can be given to the factors which have led to a different figure and their consistency with the other policies in the Framework.

As per paragraph 76 of the Assessment of Housing Need Background Paper (May 2012), the Council acknowledges that the 'starting point for the Hastings target (3,400) is one based on the amount of development that is already committed,.....together with some new development opportunities and an allowance for windfall development' (paragraph 76). Setting a housing target based on an assumed dwelling capacity is a different concept to setting one based on the objectively assessed housing needs of a District.

Within the Background Paper, the Council covers a range of scenarios from Zero Net Migration, trend based household projections, former housing market trends and trend-based labour demand. The outcome of this assessment is a range of between 0 and 441 dwellings per annum for Hastings Borough.

With regard to the Zero Net Migration option, the NPPF specifically excludes such an approach with Paragraph 159 advising that the scale and mix of housing should be to meet 'household and population projections, taking account of migration and demographic change'. (Paragraph 159 NPPF). The housing market trend approach would also conflict with paragraph 159 of the NPPF as this simply quantifies the previous level of housing building over a prescribed period of time and ignores future demographic changes and current housing need of the Borough.

This would leave the two extremes of the assessment; the household projection trend based approach and the housing needs to support economic growth. With regard to the latter, it is concerning that the Council has concluded a zero housing requirement on the basis that there is a similar level of those on Job Seekers Allowance within the two administrative areas compared to the forecast growth in jobs. While the Council recognises this is a rather simplistic approach as those currently unemployed may not have the skills to address the future job creation, it is simplified even more by the assumption that each person claiming JSA is currently in suitable accommodation. Again, this approach does not address the housing needs of the Borough or fully assesses the household growth which would be needed to deliver the economic regeneration proposed.

As an exercise therefore, it is considered that the only National Policy compliant (paragraph 159 NPPF) assessment of housing need is that contained within the household projection analysis (441 dpa), and this should be recognised within the Planning Strategy document.

To restrict or seek to lower the housing requirement on the basis of the availability of site capacity and environmental factors are not sound socio-economic matters that are relevant to the calculation of full, objectively assessed housing needs. They might be factors to be taken into account when assessing whether the identified needs can be met in terms of other policies set out within the Planning Strategy. That however, would only come into play once the level of need had been established and would need to comply with the criteria of paragraph 14 of the NPPF, which states;

'Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

* any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
* specific policies in this Framework indicate development should be restricted'

Clearly there is a significant variation between the proposed annual requirement of 200 dpa and that which has been identified by the most recent household projections and the County Council's estimates (441 dpa). What is not clear within the Planning Strategy however is how the Council has concluded that the requirement should be 200 dpa, how this relates to paragraph 14 of the NPPF, and more so, what effect this will have on meeting the current and future housing need and demand within the Borough to 2028.

If this level of requirement has been concluded purely on the basis of what is deemed to be suitable by the Council, (i.e. site capacity, as alluded to in paragraph 76 of the Housing Needs Background Paper), this would in our opinion fail the justified and consistent with National Policy test of soundness.

Meeting the Affordable Housing Need

We would draw a comparison between the Council's proposed total proposed housing provision of 3,400 dwellings and the quantum of people currently on the Housing Register (2,392 at March 2012). Such a level of affordable need would equate to 70% of the total housing proposed to be delivered over the 17 years of the plan period, and excludes those concealed households or those in need of an Intermediate Tenure product such as Shared Equity.

It is noted that the Council acknowledge that this level of registered need remains persistently high. The reason for this is quite simply that not enough opportunities are afforded by the Council to deliver the level of housing stock needed. Again, as per the requirements of paragraph 159 in conjunction with paragraph 14 of the NPPF, the Council will need to set out specifically why this level of affordable need cannot be met.

Addressing the Existing Shortfall

In preparing its Planning Strategy, the Council has sought to wipe the slate clean in respect of the level of completions achieved since 2006 when compared against the South East Plan requirement.

With an annual requirement of 210 dpa in the 5 year period from 2006 to 2011, the Council should have delivered a net gain of 1,050 dwellings. As per the latest Annual Monitoring Report net completions during this time came to 959 dwellings, with a shortfall of 91 units. This under supply should therefore be made up for within the emerging Planning Strategy.



Summary

It is evident that in preparing its Planning Strategy the Council has made a policy judgement on the level of requirement to be delivered and that this judgement has been influenced by an assumed level of capacity. The process the Council has followed does not accord with the advice contained within the NPPF, which requires the full, objectively assessed needs of the area to be assessed and set out within the Planning Strategy. This socio-economic assessment should not be influenced by other factors such as environmental constraints in establishing both the open market and affordable housing need. Any deviation from the objectively assessed needs the Council wishes thereafter should be assessed in compliance with paragraph 14 of the NPPF.

As part of the additional consultation regarding the six residential allocations, the Council has taken the step of assessing land within the wider AONB and deeming land acceptable in principle for release. This assessment will have examined the merits of each site against the need to deliver a prescribed housing requirement during the Plan Period.

It is not the case that the Council is reliant on delivering housing from sites purely within the urban area and artificially raising the density to aid with increasing purely the quantum of housing. Indeed, within the Planning Strategy (paragraph 4.7), the Council acknowledge an existing bias towards smaller dwellings within the Borough, which will be compounded by the proposal to increase density within the urban area (paragraph 4.14). This is a conflict and one which ignores the need to deliver a range of house types during the course of the Plan Period, particularly where it is acknowledged that there is a current bias towards smaller dwellings.

On the contrary, there are appropriate sites available to come forward on the fringe of the existing urban areas within the Borough, which could aid both numerically in meeting the objectively assessed needs, but also in delivering a range of dwelling types over the course of the Plan Period.

To this end, we do not consider that the Plan has been prepared positively in exploring all possible opportunities for future housing growth to meet at least in part the objectively assessed housing needs. When taken with the conflict with the NPPF, we would contend that the Planning Strategy as currently drafted is unsound.