Eastbourne Local Plan reaches final consultation with 7,330-home shortfall

The Eastbourne Local Plan has reached its final pre-submission consultation with a proposed requirement for 4,400 homes against assessed need for 11,730, leaving a 7,330-home shortfall. Representations close at 5pm on 13th November 2026.

Eastbourne Borough Council opened the Regulation 19 stage at 9am on 2nd October 2026. Its Proposed Submission plan covers 2025 to 2042 and is the version it intends to submit for independent examination.

The council says this is “not a general consultation on the content of the Local Plan”. Responses, invited under Regulation 20, should address legal compliance or soundness. For residents, landowners and developers, that means explaining what is wrong with a policy or allocation, why the evidence matters and what needs changing.

Eastbourne Local Plan would meet about 37.5% of assessed need

Policy SS5 proposes 4,400 net additional homes outside the South Downs National Park, equivalent to approximately 259 a year. Paragraph 4.1.2 identifies need of 690 homes a year, or 11,730 across the same 17-year period.

Our calculation puts the proposed requirement at approximately 37.5% of assessed need. The remaining 62.5%, some 7,330 homes, is the gap between those two figures, not a count of refused applications or an existing delivery backlog.

This is a capacity-based requirement: the council is starting from what it considers deliverable within its constrained planning area. That distinction does not make the shortfall disappear. Whether the strategy does enough to meet need will be a central examination question.

The Proposed Submission Local Plan separates the policy requirement from its supply calculation. Table 1 records:

The table also identifies 454 homes of potential capacity on other identified sites and 200 through estate regeneration, producing a potential total of 5,140. These additional opportunities are separate from the core 4,486 supply figure and should not be presented as committed development.

The 454 comprises 294 homes on small infill and redevelopment sites and 160 on larger sites whose landowners’ intentions are unclear. The windfall allowance concerns anticipated small changes of use and conversions, informed by past delivery.

Why the spring figure has changed

The Regulation 18 draft proposed 6,010 homes over 2022 to 2042, averaging about 301 a year. The proposed submission version moves the starting point to 2025 and uses updated completions, commitments, allocations and windfall assumptions.

Simply saying Eastbourne has cut its target by 1,610 homes would therefore miss part of the story: the periods differ. The annualised requirement has nevertheless fallen from approximately 301 to 259 homes.

The spring supply table included 513 completions from 2022 to 2025, compared with 260 from 2025/26 in the new table. Commitments change from 1,197 to 959, strategic allocations from 2,380 to 2,060, non-strategic allocations from 492 to 284, and windfalls from 1,428 to 923. These are revised snapshots, not five independent counts of cancelled homes.

The Site Selection Background Paper explains that further engagement tested availability and capacity. Sites were removed where promoters did not respond, while new evidence changed what other sites could accommodate.

Three strategic allocations disappear: Ashford Road, previously 34 homes, is no longer considered available; East Langney Levels, previously 150, loses most available parcels, with remaining parcels failing further assessment; and the former Law Courts on Old Orchard Road, 30 homes, moves into commitments after permission was granted. The last is a change of accounting category, not lost housing.

Town centre, seafront and former university sites

The proposed Eastbourne Local Plan contains 24 strategic housing allocations. Major examples include 200 homes beside the railway station and Enterprise Centre, 250 north of Pevensey Bay Road, 230 beside Royal Parade and Prince William Parade, and 231 at Harbour Quay.

The station allocation also proposes 8,000 square metres of Class E floorspace, including at least 3,000 square metres of offices, subject to market needs and viability. Harbour Quay combines homes with offices and one hectare of public open space. These are mixed-use proposals, not housing numbers detached from their surroundings.

Several allocations have materially changed since spring:

• Former Debenhams on Terminus Road: 120 homes reduced to 60, reflecting promoters’ viability and deliverability concerns
• East Sussex College: 225 reduced to 130, following a smaller site area
• Moy Avenue: 72 reduced to 36, with the council seeking a more viable and deliverable scheme
• Aldro, Darley Road: 150 reduced to 100 because of topography and biodiversity mitigation
• Queenwood, Darley Road: 50 reduced to 30, reflecting conversion of the retained building
• Summerdown Field: 35 reduced to 25 to retain sports provision

New strategic entries include the former railway sidings at Tutts Barn Lane, with at least 120 homes, and St Andrew’s Prep School on Meads Street, with 100. St Elisabeth’s Church on Victoria Drive moves from a 10-home non-strategic proposal to a 25-home strategic allocation after its site area was extended.

Former university land remains important in Meads. Alongside Aldro and Queenwood, the plan retains 56 homes at Welkin, 40 at New Field and 42 east of Carlisle Road. An allocation would guide future applications; it is not itself planning permission.

Constraints must withstand examination

The plan describes a town bounded by the South Downs to the west, the English Channel to the south and Wealden to the north and east. Much of Eastbourne Park is functional floodplain serving the town’s flood alleviation scheme. Other coastal, surface-water and river flood risks also affect development choices.

The strategy therefore prioritises brownfield land and higher densities in accessible locations, while considering limited development at the edge of the built-up area. Policy SS5 expects 75% of homes on previously developed land, compared with 82% in the spring draft.

Neighbouring authorities have not supplied an agreed solution to the shortfall. The site-selection paper records advice that Eastbourne’s residual need could not be accommodated by neighbouring or other authorities in its housing market areas. The plan itself says discussions, including with Wealden, remain ongoing.

Infrastructure is another delivery test. The infrastructure topic paper links growth to transport, water, wastewater, community facilities and flood mitigation. Identifying a need for infrastructure is only the start; delivery, funding and timing need to work alongside the allocations.

For me, the examination issue is whether the council has demonstrated an appropriate, deliverable strategy after testing reasonable alternatives and opportunities for additional capacity. Physical constraints are evidence to examine, not automatic approval for a 7,330-home shortfall.

Affordable housing percentages have fallen

Final Policy HO1 differs substantially from the spring proposal. It now seeks a minimum 30% affordable housing on greenfield sites and 10% on wholly previously developed sites, down from 40% and 30% respectively. The higher requirement applies where a site is only partly previously developed.

The policy covers developments with a net gain of 10 or more dwellings, or sites of at least 0.5 hectares. The Homes for All Topic Paper attributes the reduction to updated viability evidence, including falling new-build values and rising construction costs.

Open-book viability assessments and independent scrutiny remain where developers seek lower contributions. Review mechanisms also remain, with the trigger changed to substantial completion, defined as 75%, within 18 months. Outline permissions, reserved matters and phased schemes have further provisions, so the precise wording matters.

Those reviews can capture improved viability through additional affordable homes or an equivalent contribution. Our affordable housing guide explains the wider planning context. These are proposed Eastbourne policies, not newly adopted requirements.

The housing trajectory needs clarification

The plan anticipates slower early delivery before larger allocations contribute. However, paragraph 4.1.48 says the annual requirement rises from 190 to 300 homes in 2032/33, while Appendix 2 shows the 300 figure starting in 2031/32.

Appendix 2 also includes a separate potential-capacity row. Its annual totals should therefore not be confused with either the 4,400 policy requirement or Table 1’s core supply. The conflicting start year needs clarification before readers rely on a precise stepped requirement.

How to respond by 13th November

Regulation 19 concerns publication of the proposed submission documents; Regulation 20 provides for representations. Unlike Regulation 18’s earlier plan-shaping exercise, this stage focuses on legal compliance and whether the plan is positively prepared, justified, effective and consistent with national policy.

A useful response should identify the policy, allocation or paragraph; state the compliance or soundness concern; explain the supporting evidence; and specify the modification sought where appropriate. Supportive representations can also be made.

For example, a challenge to an allocation’s capacity is stronger if it identifies an access, flood-risk or delivery assumption and explains the change needed. A general objection without that connection gives the examination less to work with.

Respondents seeking a change can request to be heard at examination. Under the applicable section 20(6) provisions, that is a right to an opportunity to appear and be heard; the Inspector manages the hearing programme and participation arrangements. Our Local Plan examination guide explains the process.

Use the council’s Eastbourne Local Plan consultation portal to read the documents and submit representations before 5pm on 13th November 2026. If you need help assessing a site or preparing a focused planning representation, we can help with the planning strategy and coordinate specialist evidence where needed.