Affordable Housing

Written Comments on New Homes for East Sussex 2006-2026 Consultation Development Pattern Summary A significant number of respondents felt that greenfield opportunities should not be utilised. This was, however, qualified by many that brownfield options should be exhausted before looking to green field sites. A handful of respondents felt that windfall estimates were optimistic and that greenfield sites would play a greater role than our proposals suggested. It was also felt that Hastings (primarily) had an untapped resource of vacant housing which was not recognised by our proposals. A considerable concern was the environmental impact of development at strategic locations in the East Sussex part of the sub-region which can be broken down into a number of key themes:  pleas for lower development levels to reduce or avoid adverse environmental and social impacts;  a redistribution of development to other parts of the sub region;  focus development on existing urban centres well served by a range of facilities;  the provision of a new town; and  avoid the coalescence of settlements along the coast. A small number of views were expressed over the distribution of development within the Rest of County Area and ranged between support and objections to development in particular locations. Response The County Council’s preferred option for the sub-region is a balanced dispersal of development along the East Sussex Coast but focussed on the existing towns. The range of spatial development options is extremely limited by the extensive environmental constraints within the sub-region. The strategy therefore seeks to make the most of brownfield development opportunities within the towns, but also allows for some development to take place on greenfield sites as sustainable extensions to them in order to deliver the sub-region’s housing requirement. The proposed distribution is considered to be the most sustainable way of accommodating the requirement. It respects the environmental imperatives, spreads the benefits of development (including affordable housing and business confidence) across the area, makes the most of available services in existing centres and promotes a better balance between people, homes and jobs, thereby helping to reduce the need to travel longer distances to work. Development levels could not be reduced in one part of the area without having to increase them in another to compensate, which would lead to a less sustainable strategy. The estimated contribution from windfall sites is based upon a continuation of the past rates of development actually achieved over the past few years. To have assumed more would risk compromising the delivery of the housing requirement if such sites did not come forward fast enough. To have assumed less would imply having to identify more greenfield development than may be required, which would tend to suppress brownfield sites coming forward if easier greenfield ones were allocated. The windfall sites estimates are considered challenging but achievable. There is neither the need nor scope for accommodating a new town or settlement within the sub region. Our sustainability appraisal assessed alternative spatial strategies which sought to concentrate the development requirement at one of the three strategic locations and found that a balanced dispersal of development would provide the greatest social, economic and environmental benefit. The need to protect strategic gaps between settlements is included in part 1 of the SE Plan. Part 1 of the South East Plan states that the residential vacancy rate is about 2.7% in the region as a whole, although there are some pockets where it is higher. However, the housing requirement set by the Regional Assembly is for a net increase in the dwelling stock. While reducing locally high vacancy rates is desirable, there is clearly no scope to offset that against the requirement to provide additional housing. 1 For the Rest of East Sussex area, the distribution of the annual requirement is based on the relative constraints and opportunities in the 3 district areas concerned. For both the sub-region and the rest of East Sussex the precise location and form of development will be determined by the relevant local planning authority through the Local Development Framework process. When preparing their LDFs local planning authorities will need to conform to national and regional policies on the provision of infrastructure, maximising the use of brownfield land and environmental protection. Summary of Comments Ref. 415 Organisation Archery Tools and Fixings Ltd Location Comment Greenfield development should not be an option especially considering all the empty property and undeveloped brownfield sites. It is essential that Burgess Hill develops a sustainable community with regard to infrastructure, housing and employment. The strategic gaps need to remain but they must serve the urban areas they surround, not just provide visual amenity. Such a plan needs to be flexible and capable of adjustment to reflect changing circumstances through the Plan period. The lack of local employment particularly agriculture has lessened the need for labour and people are moving outside the area for work. The approach (advocated by Wealden District Council) of providing for larger blocks of development in the low weald is flawed because there is a need for small amounts of affordable housing in many small villages in the High Weald AONB. Also the prospect of sprawling estates on the edge of towns and widened trunk roads is not an attractive prospect. Whilst acknowledging the constraints which face the Lewes part of the sub region, there remain areas of development opportunity, such as Ringmer. It is inappropriate to ignore such opportunities. Agrees that brownfield land targets are ambitious. Appropriate to use a flexible approach which focuses housing on brownfield land but does not disregard other uses on these sites particularly employment. Do not build on AONB. New housing is better placed close to existing conurbations rather than dotting it around the countryside, this will reduce travelling to work, shopping and leisure activities and there is better access to public transport. The increase in single-person households must be noted in any overall development. The use of brownfield land is essential Generally support the approach to development in the Lewes section of the sub-region, however care is required to avoid placing additional pressure on the A259 and adversely affecting the setting of the South Downs. Should brownfield opportunities come forward in the manner expected then housing targets should be lowered rather than meeting the shortfall in the AONB/National Park. 605 Burgess Hill Town Council 547 Burwash Parish Council 595 Buxted Parish Council 456 456 552 Charles Planning for Croudace Homes Ltd Charles Planning for Croudace Homes Ltd Chiddingly Parish Council Chiddingly Parish Council Chiddingly Parish Council Civic Trust South East Council for National Parks Council for National Parks Lewes 552 552 611 310 Lewes 310 2 Ref. 455 455 596 Organisation CPRE Sussex CPRE Sussex Crowhurst Parish Council David Lock Associates Defence Estates Location 451 606 606 Defence Estates Defence Estates Defence Estates 606 606 376 East Hoathly with Halland Parish Council Sussex Coast 619 East Sussex Economic Partnership 306 Eastbourne Green Party Eastbourne Green Party English Nature Environment Hailsham Evison & Co (Clarence Preston Will Trust) Ewhurst Parish Council Ewhurst Parish Council Forest Row Parish Council 306 444 543 Comment Supports an approach that maximises development on brownfield land, limits development in the countryside and prevent excessive urban sprawl. Should reserve land for agriculture, plan should anticipate possible need for good farm land in the future. Population should be more concentrated on larger towns which should be better able to absorb numbers and enable the countryside to be protected. The report to the South East England Regional Assembly should reiterate that the primary location for development is brownfield land . The MoD is in ownership of a number of small sites in East Sussex which will be reviewed as part of a rationalisation of the Ministry's assets. Welcomes the positive policy (South East Plan) which recognises the potential contribution that surplus public sector land can make towards delivering spatial strategy objectives. These sites may have regional significance for defence uses or housing. Support proposals for maximising development on brownfield land. The 'sharper focus' option, it is recognised, seeks to focus growth into areas with strong economic potential. However, this is too polarised, restricting development in 'rural' areas. The balance of distribution is wrong. Additional housing should be located in places with the best opportunities for employment and commuting by public transport e.g. Polegate and Berwick. No village wherever located should be protected from further housing, all communities need to grow though at a level which maintains their character. While the 60% target for development on brownfield land is a worthy aim, this will put pressure on worn out or underused employment sites to go for residential, especially due to higher prices for residential land. Policies should not increase pressure to put housing in employment sites - or in cases where it does occur ensure replacement employment land is provided. The basis of the proposals should be that no development takes place on greenfield sites. All development should be based on brownfield land and bringing back into use the thousands of empty and derelict homes across the region. This would largely deal with housing need. Ensure sufficient green space is retained within the existing built-up areas. Suggest an alternative option of creating a small new town close to major new or existing roads and railway network. Would accommodate nearly all the new homes and stop existing towns being overloaded. Supports a strategy of concentration, believes there are settlements including Uckfield where opportunities for balanced sustainable development exist. Redundant agricultural holdings should be used to provide land for affordable and market housing. Any shortfall in development in the sub region should not be met in the Rest of East Sussex. More use should be made of existing older properties and offices. 555 223 309 330 3 Ref. Organisation Friends of Lewes Location 425 Lewes 18 G D UK Ltd Hastings 550 Hailsham Town Council Hailsham Town Council Hastings & Rother Local Agenda 21 Hellingly/Hailsham/P olegate 550 Wealden 578 Bexhill/Hastings 618 Hellingly Parish Council 536 Hillreed Developments Ltd Sussex Coast 588 Home Builders Federation 602 137 Individual Lewes Green Party Lewes Rural Voices, Rural Choices Multiple Sclerosis Society Hastings & Rother Branch National Council of Women 590 Comment Do not oppose development on brownfield development which would contribute to a vibrant economy in Lewes. This is conditional that any development is sympathetic to the rest of the town. If this principle cannot be kept then no development should take place. Significant amount of under used/derelict accommodation in Hastings - place priority in bringing these into effective use before using greenfield sites. Comments apply equally to the whole of the county. It is considered essential that the strategic gaps between Hellingly and Hailsham and Hailsham and Polegate are protected. Suggests one or two large scale developments in Wealden, with access to the A27 and good rail links. Also such large scale proposals would be capable of delivering the necessary infrastructure. Windfall estimates for Hastings is far to high. Believe link road between Bexhill and Hastings will increase congestion suggest Bexhill can develop much more sustainably as a separate town rather than a satellite of Hastings. Notes that the option of a new settlement was not considered in the consultation material - whilst such an option would involve developing greenfield land it would ensure a planned and phased approach to development and the delivery of infrastructure. Supports concentrating growth in the coastal sub-region and in the areas in need of regeneration. Opportunities in Rother at North Bexhill and Wealden are rightly identified and focused on in the strategy. The HBF is doubtful that the capacity for development on brownfield land is as high as the proposals suggest. The high emphasis on brownfield land will not fulfil the objective of delivering sustainable communities. There is a need to provide a more diverse product (housing) range. There are lots of empty homes that can be brought back into use instead of new building. Need to use vacant properties to address the unmet demand for affordable housing. Concern that the reliance on windfall sites means that it is difficult to plan for improved infrastructure and services. If developments are predominantly small and piecemeal this makes service planning very difficult. 180 Emphasis should be placed on utilising existing housing stock 545 Brownfield land should be used up before any green areas are used. Although the methodology used in distributing development in the Rest of East Sussex is supported, the focus of development should be on major centres such as Crowborough. Some limited development should take place in the villages. Place a priority on brownfield opportunities for development. Believe that the allocation of greenfield sites on the edge of settlements may undermine regeneration efforts in urban centres. 408 National Trust Rest of East Sussex 408 National Trust Sussex Coast 4 Ref. 408 Organisation National Trust Newhaven Strategic Network Pestalozzi International Village Trust Rydon Homes Ltd Location Sussex Coast Comment A priority should be placed on higher (but unspecified) densities on brownfield land to maximise accessibility to services and public transport. Newhaven must not be a simple target for housing development just because of an availability of sites. Proposals must take into account regeneration and renovation of existing housing stock. Suggest redistributing allocations from Hastings and Rother to Lewes. Believe there are sustainable opportunities outside the four main settlements in Lewes District that are not constrained by environmental designations. Believe it is important that there is a flexible approach to achieving housing targets as it is considered that the significant contribution of windfalls in the Hastings/Bexhill area may be optimistic. Suggest that more greenfield sites should be held in reserve in case development does not take place at the rates anticipated. Support the statement that land north and west of Bexhill and the Wilting area has potential, and consider that it should be a strategic allocation. Supports dispersal around the Sussex Coast sub-region rather than focused on one or two areas. Welcomes focus on brownfield land . If estimated brownfield land is not forthcoming overall housing figures should be reduced. Supports the use of brownfield sites over greenfield sites, which should apply to all forms of development not just housing. Residential densities should be at the higher end of the spectrum to reduce the need for development on greenfield land and increase accessibility to services. Uckfield should be identified as the principal town within the Rest of East Sussex to accommodate strategic scale growth. Disagree with maximising house building on brownfield land . Need a balanced approach which reflects the need to identify both brownfield land and greenfield development opportunities. Development should be directed to the most sustainable locations. Support dispersal option. Lewes is not suited for major expansion because of its proximity to the Downs and the Ouse flood plain. New development should be concentrated in other, less constrained, coastal towns. The easy development decisions have already been made. Brownfield opportunities are constrained leaving development options which are environmentally damaging. Support the re-use of brownfield land but question whether the urban areas will deliver all the housing numbers projected. As land values are extremely low in some areas wonder whether sites in towns such as Hastings will ever be feasible. Land at Cradle Hill North East Seaford should be designated as a strategic housing site with a notional yield of 300 dwellings. The proposals should place much less emphasis on windfall sites, given their inability to deliver sufficient affordable housing to meet the needs of the sub region. 597 Newhaven 254 601 Lewes 622 Seaspace Bexhill/Hastings 622 592 592 Seaspace South Downs Campaign South Downs Campaign South Downs Joint Committee South Downs Joint Committee South East Consortium South East Consortium South East Consortium Streat Parish Meeting Sussex Wildlife Trust Taylor Woodrow Town Planning Consultancy Town Planning Consultancy Bexhill/Wilting Sussex Coast 440 440 614 Uckfield 614 614 438 Lewes 247 625 334 Lewes 334 5 Ref. 53 123 123 Organisation Wartling Parish Council Wealden District Council Wealden District Council Location Sussex Coast Comment Concentrate bulk of housing on the larger towns where infrastructure is already in place. Brownfield opportunities are not utilised effectively Densities on brownfield sites need to be increased. Supports additional homes as additions to existing settlements rather than new larger scale developments, because all settlements need to offer a number of additional homes, particularly affordable to ensure a spread of age ranges and sustain the viability and sustainability of local services. Cannot accept that Wivelsfield, parts of Chailey, Ditchling, Plumpton, Streat and Westmeston Parishes have any significant transport and important economic links with East Sussex. Central and southern parts of Wealden District are the most suitable areas for development in Rest of East Sussex. Background data in preparing the Rest of Sussex approach identified that only Crowborough and Uckfield performed well. AONB constrains Crowborough, so support a focus of development at Uckfield. Identifies potential strategic development in Uckfield, Hailsham and Polegate as being compatible with the strategy promoted by the adopted Structure Plan. Don't turn Eastbourne into a 'Megalopolis'. There is no room in the towns in East Sussex for the required housing. Development must therefore be put on the fringes, this will diminish greenfield land which is a shame. Eventually Eastbourne/Polegate/Hailsham will be a sprawling mess. Eastbourne / Polegate / Hailsham should not be allowed to become one big sprawl. There should be a designated greenbelt around the Polegate area to restrict outward expansion and urban sprawl. There should be plans to reuse existing empty homes and buildings in Hastings. Don't develop the Sussex Coast to create a linear city. Unemployment in Hastings is very high, more houses will add to this problem. The level of development proposed is unnecessary. There are plenty of unused houses in Hastings. Hastings has 5000 houses that need refurbishing and could account for some of the proposed figures. Proposes a new town between Lewes and Uckfield, on the old railway line. This would solve most of the plans for East Sussex. There are some villages in the High Weald AONB that can accommodate some development. Why is east Bexhill the only area being proposed as a greenfield site in Rother? Why should Bexhill loose its greenbelt? Why has only E Bexhill and Pebsham been identified for housing development? Create a new settlement in the Three Oaks / Westfield area, north of Hastings. The character of the area could accommodate a settlement of 5,000-10,000 dwellings. Don’t turn coast into 'mega-city'. Development should be concentrated in the Sussex Coast Sub-Region where infrastructure can cope. 423 Wealden LSP 491 Wivelsfield Parish Council Lewes 537 Woolf Bond Planning (Martin Grant Homes) Woolf Bond Planning (Martin Grant Homes) Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Uckfield 537 13 172 216 322 556 75 149 432 484 576 374 188 202 352 523 279 509 Wealden Eastbourne Eastbourne Eastbourne/Polegate/ Hailsham Eastbourne/Polegate/ Hailsham Eastbourne/Polegate/ Hailsham Hastings Hastings Hastings Hastings Lewes Rest of East Sussex Rother Rother Rother Rother Sussex Coast Sussex Coast 6 Ref. 585 586 634 634 562 Organisation Individual Individual Individual Individual Individual Location Sussex Coast Sussex Coast Sussex Coast Sussex Coast Uckfield 25 191 327 5 34 42 66 66 74 85 86 93 93 111 112 123 123 125 150 157 166 168 169 185 191 200 201 216 221 234 242 Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Wealden Wealden Wealden Comment Unacceptable to keep building at this rate in Sussex Coast Sub-Region. Once countryside is developed it is lost forever. Concerned about the impact on the South Downs (proposed) National Park. Brownfield sites must be used Reuse empty homes Development at Cysleys Farm Ridgewood is ribbon development of the worst kind - denuding green space and extending the already stretched town perimeter. Spread the 2,000 houses around the villages in Wealden within the High Weald AONB, at a density that can be tolerated. Then no greenfield allocations need be made, or development in overburdened Low Weald towns. Wealden is taking the brunt of the development. There is development opportunity around Crowborough that isn't in the AONB. It can be integrated into the town and utilise the railway station. Don't spoil the countryside. Don't understand why greenfield sites should be developed. Brownfield land should be developed as opposed to greenfield. Developing on greenfield sites is unsustainable. High proportion of under occupied housing in East Sussex. Greenfield sites should be a last resort. Stop destroying our countryside. Stop destroying our countryside. Developing greenfield sites sets a poor benchmark for the future. Developing in the Sussex coast will eventually lead to urban sprawl. Greenfield sites should not be considered for development. Opposed to greenfield development. Brownfield opportunities are not utilised effectively Densities on brownfield sites need to be increased. Stop building on greenfield sites. The Phoenix development (Lewes) is a good example of a quality brownfield proposal. Greenfield development over brownfield is counter-productive. Stop building on greenfield sites. The Phoenix development (Lewes) is a good example of a quality brownfield proposal. No more high density development. Greenfield land must be kept green, especially AONB and proposed National Park. Development must take place on brownfield land. Concerned about greenfield development in the southern part of the county. Money should be spent on refurbishing existing buildings which is cheaper than building new ones. Development should not occur on greenfield sites. There is a need to refurbish run-down existing housing and the use brownfield sites. Loss of open space in this region causes people to move away. Greenfield sites should not be developed. Plans for affordable houses need to ensure that they remain so. There are many homes that are unused which should be brought back in to use. Development should be on the edge of existing towns in East Sussex. 7 Ref. 245 251 265 277 279 283 285 294 298 302 324 326 347 354 363 364 366 368 370 385 386 404 404 407 420 422 428 441 453 458 462 463 468 471 472 479 488 492 501 508 509 512 Organisation Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Location Comment Housing should not be developed on greenfield sites. Avoid building on the countryside. There should be no building on greenfield sites. Should renovate existing homes instead of building new ones. Greenfield sites in South East should not be developed. Replace caravans and holiday homes with permanent homes. Building in countryside locations is part of its natural development. No housing on greenfield sites. The plan ignores potential for reusing old buildings. Development on greenfield sites should be minimal brownfield sites should be used where possible. No greenfield development should be allowed. Development puts pressure on natural resources and the AONB and proposed National Park. All development should be on brownfield land. The unique qualities of the High Weald AONB should be protected. Affordable housing is required if our communities are to be socially mixed. Greenfield sites should not be developed. Greenfield land must be protected for future generations. Increased housing development means lower quality of life. The AONB will be severely damaged if any greenfield development takes place. It is important to preserve our green spaces. Do not agree with greenfield development. There is no mention of bringing new properties up to scratch. The presence of the AONB is not a valid planning reason to refuse planning permission for development. The identification of land with no viable agricultural use should be a priority. The AONB should not be developed. To avoid any further damage to villages, development should be targeted on higher densities in urban/brownfield sites. AONB - Should not be a location for development. Development should be located at transport hubs. County is already too overdeveloped. In exceptional circumstances brownfield sites should be developed. Why not build a new town? All countryside should be protected from development not only AONB. We do not need new homes there are plenty of houses in East Sussex. No justification for building on greenfield sites. Too many people own more than one home. Support brownfield and oppose greenfield development. Affordable housing is more necessary than executive homes. Do not develop greenfield sites. Need to protect green spaces. Against greenfield development. There is a huge amount of empty homes that could be brought back into use instead of building more. Bringing empty homes into use would reduce the need for more housing development. Better use should be made of empty flats above shops. Don't agree with using greenfield sites for development. Opposed to building in the High Weald AONB villages. Disagrees with greenfield development. 8 Ref. 512 516 527 527 530 534 557 558 Organisation Individual Individual Individual Individual Individual Individual Individual Individual Location 562 569 569 571 574 577 581 583 Individual Individual Individual Individual Individual Individual Individual Individual Comment There are many homes that are unused which should be brought back into use. Developing brownfield sites must be a priority. It is more sustainable to disperse development rather than concentrate it, for example, in a new town. Brownfield targets are still too ambitious. More use needs to be made of brownfield sites. While we have a responsibility to provide housing for future generations, the countryside should also be protected. There is already too much building on greenfield sites in the Westham area and no more should be developed. Preference to reusing existing unused buildings instead of building new ones. Development should be carefully integrated and not left up to developers choosing greenfield sites. The Council should create a properly thought out strategic plan that takes account of all factors. Fear the loss of environment as countryside is built upon. As the elderly population dies, their bungalows can be used for redevelopment to avoid encroaching on greenfield sites. Any building on greenfield sites should be restricted. There is too much building in the countryside. New estates are unacceptable. Infilling and brownfield development is better. All development should avoid the South Downs. Any housing development in this area would devastate the countryside. There is no evidence of need. Any development should be kept away from the South Downs. 9