Hastings Local Plan reaches Regulation 19 with housing gap

The Hastings Local Plan has reached its final public consultation stage, with Hastings Borough Council opening Regulation 19 representations on 1st October 2026 before the plan is expected to move towards independent examination.

This is not another opportunity simply to say whether people like or dislike an allocation. Regulation 19 is the formal stage at which representations should address whether the plan is legally compliant and whether it is sound: positively prepared, justified, effective and consistent with national policy.

The deadline is 11:59pm on 12th November 2026 for electronic representations. Postal representations must also arrive by 12th November. Anyone hand-delivering a response needs to be more careful: the council says Muriel Matters House closes at 5pm that Thursday, so the 11:59pm cut-off only works online.

Hastings Local Plan Regulation 19 changes the question

The council consulted on Preferred Options between 19th February and 7th April 2026 under Regulation 18. That was the plan-shaping stage. It generated 2,292 representations from 541 individuals and organisations, and the council has since revised policies, updated evidence and added or changed sites.

Regulation 19 is different. The council is now publishing what it considers should become the development plan. Its own Regulation 19 consultation page tells representors to focus on legal compliance and the four soundness tests:

• Positively prepared
• Justified
• Effective
• Consistent with national policy

If someone wants a change, the useful representation is therefore not simply “I object”. It should explain what is wrong in legal or soundness terms, identify the evidence, and say what modification would put it right. Planning Geek’s guide to Local Plan examination explains what happens when those arguments reach an Inspector.

The housing gap will face examination scrutiny

Housing is likely to be one of the most closely examined parts of the Hastings Local Plan. Under the standard method used in the plan evidence, Hastings’ local housing need is about 697 homes a year, equivalent to 12,546 homes over 2023 to 2041.

The Regulation 18 Preferred Options identified provision of 3,174 to 3,446 homes, around 176 to 191 homes a year, including 1,187 to 1,454 dwellings on allocations. That was a fraction of the standard-method figure, and housing minister Matthew Pennycook warned the council in February that an Inspector would scrutinise whether it had genuinely left “no stone unturned” in looking for suitable land.

The September pre-submission plan has not made that fundamental gap disappear. What it has done is push harder on capacity, add sites and make clearer how environmental and physical constraints limit what can realistically be accommodated inside a tightly bounded coastal borough.

The plan itself says: “Meeting government housing targets will require creative solutions, higher density development, and bringing empty homes back into use.”

That is important. Hastings is not presenting the standard method as irrelevant. Its case is that the full figure cannot be delivered within the borough without unacceptable consequences, despite brownfield-first development, higher densities, regeneration and new allocations. Whether that evidence is sufficiently robust is exactly the sort of issue Regulation 19 representations and then the examination will test.

What changed in the Hastings Local Plan after Regulation 18

One of the clearest changes is the Former Convent of the Holy Child Jesus, Magdalen Road. At Regulation 18 it sat within the R2 regeneration area without a fixed housing allocation. In the pre-submission plan it becomes HS25, with about 200 homes and a dedicated masterplan and development brief.

The move is not simply about squeezing more housing onto the site. The former convent contains nationally important Grade II* listed buildings and a chapel on the Heritage at Risk Register. The final plan tries to make housing delivery part of a heritage-led route to repair and long-term reuse.

Cllr Mark Etherington, the council’s planning portfolio holder, said in September that the development brief seeks to “balance the protection and long-term future of its important historic buildings with the need to provide much-needed homes”.

Two further housing allocations appear in the final plan. HS26 Four Courts, Stonehouse Drive provides for 64 net new homes, while HS27 My Way Lodge, The Ridge West has a minimum indicative capacity of 20 homes. My Way Lodge sits within the High Weald National Landscape, so the policy couples that capacity with landscape-led design, ecological work, dark-sky protection and substantial open space.

But the changes are not all upwards. At HS5 Former West St Leonards Primary School, the Regulation 18 draft indicated 70 to 120 homes. The Regulation 19 allocation is now 50 homes. The policy confines building to the northern part of the site because of flood risk, the Hollington Stream and ecological sensitivity. That is a useful illustration of why a simple “find more land” argument does not automatically translate into a higher deliverable number.

Town-centre reuse sits alongside constrained edge sites

The final Hastings Local Plan strategy still leans heavily on brownfield regeneration and town-centre reuse. HS7, the former Post Office and University of Brighton building at Priory Square, has an indicative capacity of 41 homes as part of a mixed-use scheme. The policy expects active ground-floor retail, leisure or other town-centre uses, affordable housing, public-realm improvements and protection of the Hastings Town Centre conservation area and views to and from Hastings Castle.

More widely, the town-centre strategy protects the role of the Old Town, central Hastings and St Leonards while supporting specialist and independent businesses around Trinity Street, Claremont, Robertson Street and White Rock. It is a regeneration strategy as much as a housing strategy.

Employment allocations also remain important. The plan directs new workspace towards established strategic employment areas, including Queensway and Churchfields. Among the allocations are at least 6,500 square metres at Queensway North, 2,800 square metres at the Ivyhouse Lane northern extension and smaller plots at Sidney Little Road and Brook Way. The spring evidence had identified a need for about 51,297 square metres of additional employment floorspace over the plan period.

Affordable housing, flood risk and land stability are written into the sites

The Hastings Local Plan does not treat housing capacity as a number divorced from site constraints. The final site policies repeatedly bring affordable housing, flooding, land stability, ecology, transport and green infrastructure into the delivery test.

At Rock Lane, for example, the plan expects 40% affordable housing alongside a landscape-led response to the High Weald National Landscape. Planning Geek has a separate guide to affordable housing in planning.

At Winchelsea Lane and Beaneys Lane, steep slopes and ground conditions mean land-stability and geotechnical evidence is specifically required. Flood risk and drainage appear repeatedly too. West St Leonards Primary School, Ore Valley and Beaneys Lane all require detailed flood or drainage work, with sustainable drainage and, where relevant, safe access during flood events. Our Flood Risk Assessment guide explains the planning process behind that evidence.

This matters to the housing shortfall debate. An Inspector will not only ask whether more homes would be desirable. The examination can probe whether the council’s capacity assumptions, constraints and rejected alternatives are proportionate, up to date and justified.

The Hastings Local Plan evidence base has moved on

Hastings has done more than edit policy wording since Regulation 18. Its updated evidence base now includes a June 2026 Densification and Capacity Study, September transport modelling, an updated Habitats Regulations Assessment, a Regulation 19 Sustainability Appraisal and a September Whole Plan Viability Assessment.

The transport work is particularly relevant because earlier joint evidence from Hastings and East Sussex County Council recognised the very large gap between the standard-method need and identified land supply. The authorities had deliberately modelled what they considered a realistic maximum level of growth rather than 12,500-plus homes, while leaving room to update the work if the densification exercise identified more capacity.

The site policies now repeatedly use a more “vision-led” approach to transport. That means schemes are expected to plan around sustainable and multimodal travel, with monitoring and further intervention where needed, rather than treating future traffic growth as something simply to predict and accommodate.

What can people legitimately argue before 12th November?

There is still plenty to argue about, but the Hastings Local Plan Regulation 19 stage is a more technical exercise than Regulation 18. A representation can challenge, for example, whether the housing strategy is positively prepared, whether an allocation is justified by proportionate evidence, whether infrastructure makes a policy effective, whether the sustainability appraisal has properly assessed reasonable alternatives, or whether a policy is consistent with national planning policy.

Conversely, a representation can support the plan and explain why a policy or allocation is sound. What is less useful now is simply resubmitting a spring objection without connecting it to legal compliance or one of the soundness tests.

The council’s online consultation portal is the easiest route for electronic responses. The formal deadline is 11:59pm on Thursday 12th November 2026. Paper responses need to have arrived by that date, while hand delivery to Muriel Matters House effectively closes at 5pm.

Submission is the next stage, but not an automatic next-day step

When the consultation closes, the council must consider the representations and prepare the material needed for submission. Its September committee report says a further report will go to councillors in December summarising the main issues and seeking authority to submit the plan to the Secretary of State for independent examination.

The current Local Development Scheme has been working towards submission in December 2026, with examination following after that and adoption anticipated in June 2028, although examination timetables are not wholly within the council’s control.

So the significance of 1st October is not merely that another Hastings Local Plan consultation has opened. Hastings has moved from asking what its Local Plan should contain to defending the plan it wants an Inspector to examine. The housing shortfall, the evidence for capacity and constraints, the new allocations and the deliverability of the strategy are now moving into a much sharper legal and policy test.

For a wider explanation of how Local Plans are prepared and adopted, see Planning Geek’s guide to Local Plans in England.