Affordable Housing

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					Written Comments on New Homes for East Sussex 2006-2026 Consultation

Development Levels

Summary
Respondents who considered that the overall housing provision was too high were, by a small margin,
in the majority. Responses in this category presented arguments ranging from the environmental
consequences of further development in a region which is already full, to questions of need for
development given relatively static population figures.

Of those who did not wish to see a decrease in the figures, more advocated an increase in the regional
or sub regional development provisions overall than were satisfied with development levels set in Part 1
of the SE Plan. The arguments presented in support of an increase focussed on the issue of
affordability and the relationship between higher rates of development and economic growth, both in
the sub region and the rural areas.

Other respondents raised issues of specific sites, figures for the rest of county area and whether the
Lewes part of the Gatwick sub-region could absorb some of the provision for the Lewes part of the rest
of county total.

Response
The County Council was asked by the Regional Assembly to provide advice on the district or part
district housing provision figures for the period 2006 – 2026. The Regional Assembly had already
consulted on and agreed the regional, sub regional and rest of county housing figures in January 2005.
The focus of the Principal Authorities’ work was, therefore, on formulating a distribution of development,
not consulting on the level of housing figures once more.

The level of development proposed for East Sussex by the Regional Assembly is 17% less than that
required by current Regional Planning Guidance (RPG9). This broadly accords with the County
Council’s earlier advice to the Assembly which strongly argued for the sub region placing a much
greater emphasis on economic regeneration while allowing some respite from externally generated
housing demands. To attempt to address the issue of affordability simply by increasing supply would
involve a level of development which would compromise environmental designations and be unlikely to
be matched by job growth and infrastructure, even if the market could absorb it. A separate policy
seeks to maximise the proportion of affordable housing that the viability of residential development will
allow.

The consultation proposals proposed a balanced dispersal of development maximising brownfield
opportunities, providing the widest spread of affordable housing provision, and reducing out commuting
whilst respecting environmental designations. No significant redistribution of development between
strategic locations within the sub region would be more sustainable, given the circumstances of the sub
region. As the sub-regional and rest of county area figures were decided in Part 1 of the SE Plan, a
redistribution between these areas is not appropriate.

Given the strategic nature of the advice provided to the Regional Assembly, the County Council’s
proposals do not allocate specific sites for development. It will be for the district planning authorities to
determine the precise location and form of development within the strategic framework set by the
policies of the South East Plan and the Sussex Coast sub regional strategy.

Whilst our sub regional proposals have identified general development levels around strategic
locations, our rest of county proposals have sought to provide a percentage split of the 300 dwellings
per annum required by the Regional Assembly in the three districts. The ratio we have proposed has
been based upon an assessment of the constraints and opportunities present in each of the districts,
the results of which were seen by all three district authorities as a fair and equitable method to
apportion development.



                                                                                                           1
However, the anomaly of part of Lewes being in the Gatwick sub region is an issue the County Council
has taken up with the Regional Assembly, recommending the redrafting of the boundary to exclude
Lewes District from the Gatwick sub region.



Summary of Comments

 Ref.   Organisation            Location                                      Comment
 205    Ashley Homes             Lewes           Not enough jobs to support the population
                                                 The Rest of East Sussex part of Lewes allocation of 50
         Barcombe                                houses a year is too high. Need further information regarding
 580                             Lewes
        Parish Council                           the calculations, what type of sites are expected and what
                                                 percentage will be affordable housing.
                                                 In Barcombe, development should take account of local
         Barcombe                                housing, commercial and employment requirements.
 580                           Barcombe
        Parish Council                           Considers that housing growth of no more than 1% p.a. is
                                                 acceptable.
                                                 The proposals involve too much development. This will
                                                 increase costs to the population in supplying essential
 115    Bohemia Trust
                                                 infrastructure - in turn the quality of life in the south east will be
                                                 "destroyed".
         Chalvington
                                                 Unhappy with the "allocations" of greenfield sites, particularly
 133      With Ripe            Low Weald
                                                 in the Low Weald.
        Parish Council
           Charles                               Proposals considered inadequate to serve rural settlements
         Planning for                            and fails to recognise potential. Suggest Robertsbridge for
 456                       Rest of East Sussex
          Croudace                               small scale growth Proposals may prevent natural growth
         Homes Ltd                               which, in turn, would harm internal sustainability.
           Charles
                                                 Support the principle of additional development in the Sussex
         Planning for
 456                             Rother          Coast part of Rother District, though the overall level for the
          Croudace
                                                 district is too low.
         Homes Ltd
           Charles                               Overall East Sussex has both the potential and need for a
         Planning for                            higher rate of development. Lower levels of development will
 456
          Croudace                               not deliver the required infrastructure, will make the market
         Homes Ltd                               less attractive and will not regenerate the area.
          Chiddingly                             Is it an option to say to the government that East Sussex is full
 552
        Parish Council                           up? Can it accommodate any acceptable sustainable growth?
                                                 Lower levels of housing provision will perpetuate affordability
          David Lock                             problems. Without additional housing the existing housing
 451
          Associates                             stock will continue to be unaffordable. Levels should be
                                                 above current RPG9.
           Defence                               Supports overall strategy except for the absence of guidance
 606
           Estates                               for the area outside the sub-region.
                                                 The level of housing is too low and will serve to compound the
           Defence                               housing back-log and overall shortage of housing in the
 606
           Estates                               region. The rate of growth should be to the higher end of the
                                                 growth options available.
         Development
          Land and                               Provides calculations for an alternative housing distribution
 447                         Sussex Coast
           Planning                              and revised numbers.
         Consultants
        East Chiltington                         Brighton & Hove should accommodate more than 550 new
 604                       Brighton and Hove
        Parish Council                           homes per year as it is the most sustainable location.
                                                 Cabinet is comfortable that the proposed housing figure is
          Eastbourne
                                                 deliverable without any undue detrimental effect on the quality
 424       Borough             Eastbourne
                                                 of life of the community. This is on the proviso that the
           Council
                                                 required infrastructure is put in place.




                                                                                                                    2
Ref.   Organisation          Location                                   Comment
                                            The continued development of the South East is not
        Eastbourne                          compulsory - if the continued overdevelopment is set to
306
        Green Party                         increase there will be a serious imbalance of social, economic
                                            and environmental needs.
          English                           As a land owner with a remit to deliver affordable and key-
587
        Partnerships                        worker housing, English Partnerships support the proposals.
                                            House building is too high in all parts of the South East.
        Environment
543                                         However, small amounts of affordable housing in and around
         Hailsham
                                            many villages would be beneficial to preserve the social mix.
                                            Overall allocation too low, particularly in Wealden. Supports
        Evison & Co
                                            allocations in Uckfield as it is not environmentally constrained.
         (Clarence
555                          Uckfield       Low levels of development will constrain sustainable
        Preston Will
                                            employment and provision of community benefits including
           Trust)
                                            affordable housing.
        Evison & Co
                                            The overall housing figure is too low and as a consequence
         (Clarence
555                                         will hinder, rather than promote, the aim of promoting
        Preston Will
                                            sustainable economic regeneration and growth.
           Trust)
        Forest Row                          Given that population figures are stable, cannot see why such
335
       Parish Council                       "massive" rebuilding is necessary.
        Forest Row                          The proposed numbers for the smaller towns and villages are
335
       Parish Council                       too high.
                                            Overall housing figure is too low. Believes that the population
          Gleeson                           growth in the South East and London will mean the housing
565
          Homes                             figures for the South East will have to be increased by at least
                                            50%.
                                            Whilst it is acknowledged that the number of houses being
       Hellingly Parish
618                                         consulted upon is a lower number than was anticipated, it
           Council
                                            remains too high given the poor state of local infrastructure.
         Hillreed
536    Developments                         Overall housing figure is too low.
            Ltd
                                            The housing numbers are inadequate and fall significantly
       Home Builders                        below that required to sustain economic growth targets,
588
        Federation                          achieve economic, social and physical regeneration and
                                            ensure sustainable communities.
                                            Central government has suggested a target of 36,000
                                            dwellings per year is likely to be required to achieve
       Home Builders
588                                         regeneration objectives (compared to 28,000 as basis of
        Federation
                                            consultation). House Builders Federation believe the figure
                                            should be higher still.
       Home Builders
588                                         What is clearly required is more housing across the board.
        Federation
                                            The proposed housing figures will not achieve the step change
       Howard Hutton
445                                         that would lead to a reduction in house prices and increase
       and Associates
                                            affordability.
                                            Overall total for East Sussex is far to low. Any distribution
       Jennifer Owen
                                            strategy will need to be reviewed once an increase is properly
        & Associates
490                                         considered. Most sustainable location for new greenfield
        Ltd. (Pelham
                                            development is the Low Weald Towns particularly Polegate,
        Homes Ltd)
                                            agree that the other coastal towns have major constraints.
                                            Considers that the sub regional strategy is overly optimistic in
                                            terms of the ability of Brighton & Hove to continue achieving
       KMA Chartered
452                       Brighton & Hove   its past high rates of completions. Suggests that some of the
       Town Planners
                                            Brighton & Hove allocation could be transferred to the Crawley
                                            Gatwick part of Lewes District.




                                                                                                           3
Ref.   Organisation           Location                                     Comment
                                                The Lewes part of the Gatwick Sub-Region has the potential
                                                to meet the needs of that area. East Sussex County Council
       KMA Chartered                            should redistribute some of the Lewes allocation to contribute
452                             Lewes
       Town Planners                            to the Gatwick Sub-region (should be counted as part of the
                                                Rest of East Sussex). The Rest of East Sussex figure for
                                                Lewes should be increased to 80 from 50 dwellings.
                                                The level of development proposed is inadequate to address
       KMA Chartered                            identified social and economic requirements. A higher figure
452
       Town Planners                            of 38,000 dwellings across the region as a whole is justified
                                                and a higher level of growth should therefore be sought.
                                                Supports the view that the environmental constraints preclude
       Lewes District                           any new strategic housing land allocation in Lewes District.
494                             Lewes
         Council                                Supports the view that no higher rate of windfall housing land
                                                supply should be assumed for Lewes District.
                                                Proposals are more acceptable than previous plans, but
        Mountfield
539                                             remain too high. Development will cause too much congestion
       Parish Council
                                                for the inadequate road and rail infrastructure.
                                                Development proposals at Bexhill and Wilting Farm are too
408    National Trust      Bexhill/Hastings
                                                high given environmental constraints
                                                The central area strategic location and amount of
                         Eastbourne/Polegate/   development is judged to be acceptable. However, there may
408    National Trust
                              Hailsham          be opportunities to increase development here given the
                                                relative lack of environmental constraints.
        Peacehaven
                                                There is too much building to accommodate people from
379      Residents
                                                Eastern Europe and Africa.
        Association
                                                The overall level of housing development proposed for the
                                                Rother part of the Sussex Coast area is considered
                                                appropriate having regard to economic, social and
                                                environmental objectives, subject to three qualifications:
                                                 a) The Bexhill-Hastings link road needs to be committed
                                                within relevant national, regional and local transport strategies
       Rother District                          and funding programmes, and specifically the proposed
621                            Rother
          Council                               Implementation Plan, to be built within the next 5 years;
                                                b) This level of housing needs to be shown to be consistent
                                                with the sustainable regeneration and growth of
                                                Hastings/Bexhill area specifically with anticipated growth in
                                                potential employment; and
                                                c) It is essential that proper provision is made for infrastructure
                                                needed to support and integrate development.
                                                Support high level of new housing in Wealden, though
       Rydon Homes
601                           Wealden           distribution should be better balanced in order to assist growth
           Ltd
                                                in the smaller towns and villages.
                                                Rye is no longer a priority area for regeneration and has a pop
          Rye
                                                of 4500, it should not be categorised as a main town in the
373    Conservation              Rye
                                                Sussex Coast Sub-Region. The housing numbers are much
         Society
                                                too high for this small town.
                                                The Task Force's regeneration strategy for Hastings and
                                                Bexhill assumes provision of 7450 new homes over a
622      Seaspace          Bexhill/Hastings     comparable period to the life of the South East Plan. This
                                                figure will be met if the annual building rates set out in the
                                                consultation documents are achieved.
                                                Support the allocation of 500 extra dwellings on brownfield
                                                sites within Hastings. This is a realistic figure and the
622      Seaspace             Hastings
                                                Millennium Community can provide a valuable contribution
                                                towards this allocation.
                                                Concerned at the likely implications of the proposed amount of
       South Downs
                                                new houses for the environment and infrastructure. Housing
440        Joint
                                                numbers appear to be being promoted that existing
        Committee
                                                infrastructure and, possibly, the environment cannot handle.



                                                                                                                4
Ref.   Organisation           Location                                     Comment
                                                There is no support for any further urban extensions. The
                                                allocation for housing in Brighton & Hove should be reduced
       South Downs                              so that the city has no excuse for advocating development that
450                        Brighton & Hove
         Society                                encroaches upon, or is visually damaging to the South Downs.
                                                The numbers from the city target should be reallocated to
                                                regeneration areas in the Eastern part of the County.
                                                Overall housing figures are inadequate to address identified
                                                social and economic requirements both locally and throughout
        South East                              the South East. East Sussex County Council should assess
614
        Consortium                              options for accommodating an increased housing figure of
                                                31.5% above what is proposed (based upon a rate of 38,000
                                                dwellings per annum for the whole region).
         St Helens
           Down
165                                             Housing proposals are too high
         Residents
        Association
          Sussex                                Refers to State of Housing Report - increase the level of
138
        Enterprise                              employment/business allocations,
                                                Refers to State of Housing Report - South East Plan to
          Sussex
138                                             increase the level of housing proposed regionally and sub
         Enterprise
                                                regionally, ensure that need for affordable housing is met,
                                                Consider that the overall levels of housing in East Sussex are
       Sussex Wildlife
247                                             too high and as a consequence no comment is made on the
           Trust
                                                distribution of what is seen as an unacceptable figure.
                                                Overall housing figure is too low and is not going to deliver
          Taylor
625                                             economic regeneration, improve infrastructure or deliver
         Woodrow
                                                affordable housing.
          Town and                              Overall housing figure is too low. This could seriously affect
594        Country                              the economic performance of the region as not enough
       Housing Group                            affordable housing will be provided.
       Town Planning                            East Sussex County Council needs to increase the provision
334
         Consultancy                            of new housing over the plan period.
       Willingdon and
                         Eastbourne/Polegate/   Not convinced that further large scale house building is
554       Jevington
                              Hailsham          desirable or necessary in this area.
       Parish Council
         Woolf Bond
           Planning
549                                             Overall housing figure is too low.
           (George
         WimpeyUK)
         Woolf Bond
           Planning
537                                             Overall housing figure is too low.
        (Martin Grant
           Homes)
88        Individual         Eastbourne         Eastbourne is overcrowded which spoils the quality of life.
                                                Concern that Eastbourne is expanding to the extent that
192      Individual          Eastbourne
                                                smaller communities are being/and are to be 'swallowed up'.
                                                Over-developments such as Sovereign Harbour should be
46       Individual          Eastbourne
                                                avoided.
                                                There is scope for development in East Sussex and the rest of
                         Eastbourne/Polegate/
364      Individual                             the sub-region. Especially in Polegate / Eastbourne for
                              Hailsham
                                                affordable housing for locals.
                         Eastbourne/Polegate/   Housing proposals for Polegate and Hailsham are not
584      Individual
                              Hailsham          accepted. Subsequent road building is also unnecessary.
                                                Hastings is full! More homes will destroy the area. Develop in
90       Individual           Hastings
                                                the larger districts.
                                                An increase of 25 dwellings per year across rural East Sussex
527      Individual           Hastings
                                                will absorb the 500 allocated for Hastings.
                                                Rother should not bear the brunt of the proposals. The only
492      Individual            Rother           land available for development is greenfield and this cannot be
                                                allowed.



                                                                                                             5
Ref.   Organisation   Location                               Comment
358      Individual     Rye      Housing proposals are too high.
                                 East Sussex will stagnate if the level of development is not
10      Individual
                                 increased.
                                 If more development takes place in the South East residents
21      Individual               will move away due to reduced quality of life, leaving behind
                                 underused, expensive infrastructure.
45      Individual               No more houses!
                                 There isn't any room in the villages to accommodate more
86      Individual
                                 development.
109     Individual               The South East is already overcrowded .
112     Individual               The high level of development is unacceptable.
                                 The proposals are based on an in-migration level which is
177     Individual
                                 unsustainable.
                                 There is not enough housing provided in the plan for all the
200     Individual               people who will need to move to the South East for a good
                                 job.
                                 More residential units encourage Central Government to
210     Individual
                                 increase council tax.
249     Individual               The South East is already overcrowded.
252     Individual               Level of housing is unacceptable.
268     Individual               No new housing should be built in the South East at all.
293     Individual               The South East is far too crowded already.
294     Individual               Targets are too high and too ambitious.
330     Individual               We must do our share.
                                 Housing figures are much too high. People need spaces for
360     Individual
                                 physical and spiritual health.
                                 Do not accept the Government's housing proposals they are
366     Individual
                                 much too high.
                                 There is a danger of providing too much development in the
385     Individual
                                 South East.
390     Individual               The South East is already over crowded.
394     Individual               The South East is already over developed.
407     Individual               Housing numbers are too high.
431     Individual               There is no need for new housing as the birth rate is static.
478     Individual               The county is already at bursting point.
527     Individual               There is scope to increase the housing target.
                                 The South East is already overcrowded. Do not want any
531     Individual
                                 more development of any kind here.
                                 The region is already overpopulated - the proposals are ill-
567     Individual
                                 advised.
                                 Challenge the premise that more housing is needed in the
569     Individual               South East, and that it is the solution to delivering the homes
                                 that will be needed.
571     Individual               The overall proposals are far too high.
                                 Concerned that there will be no gap between settlements
593     Individual
                                 starting with Hastings and Battle.
602     Individual               Overall housing proposed is too high.
                                 More development will lead to resource shortages and
636     Individual
                                 increasing levels of crime




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