Rother Local Plan 2025-2042 Regulation 19 (pre-submission) version September 2026

Parish: Bexhill

10.14The central area of Bexhill benefits from an excellent range of services and facilities, cultural assets, access to the mainline railway station and good bus services. However, there are things that need improving, including more pedestrian and cycle-friendly routes to enable people to travel around sustainably. There are also constraints including flood risks, and important assets that require protection, including public open spaces and the two Conservation Areas.

10.15In the main, opportunities for development in the central area will arise on brownfield sites. In accordance with national planning policy, it is important that developments make the best use of land, and avoid homes being built at low densities.

10.16Bexhill is benefiting from £20 million government funding through the Pride in Place Programme. To plan how the funding will be spent to improve the town, the Bexhill-on-Sea Place Plan, and an associated 4-Year Investment Plan, has been developed by the Bexhill Neighbourhood Board, a partnership of local stakeholders. The Place Plan encompasses the entire town of Bexhill, with strategic emphasis on the town centre. The Place Plan and the Local Plan are intended to align closely in their shared vision for improving Bexhill. This includes celebrating Bexhill’s heritage and enhancing the public realm, supporting opportunities for residents through improved access to skills, jobs and housing, and strengthening connections between the town centre, the coast, natural assets and neighbouring communities. Together, these plans provide a coordinated framework for investment, spatial planning and delivery over the coming decade and beyond.

Policy BX1: Bexhill Central Urban Area Comment

10.17In planning for the future of Bexhill, a distinction is made between the central urban area and suburban areas. The Bexhill Central Urban Area has been identified as an area within reasonable walking distance of Bexhill mainline railway station and the services and facilities within Bexhill Town Centre. It includes the designated Town Centre and Primary Shopping Area, as well as the Beeching Road business area (see Policy BX4) and some key brownfield sites for redevelopment, identified by separate site allocation policies in this chapter.

10.18 The area also contains key heritage assets, including the Bexhill Town Centre Conservation Area and it adjoins the Old Town Conservation Area. It is also home to key facilities and attractions for residents and visitors, including Egerton Park, Bexhill Leisure Centre, Bexhill Museum and the Grade I listed De La Warr Pavilion. It overlaps with the Bexhill Cultural Area (Policy BX2).

10.19This area accommodates a mix of uses and building typologies, and its proximity to public transport and services makes it a strategic location for residential intensification. In accordance with national planning policy, the use of minimum density standards in this area is considered appropriate.

10.20To support higher densities, external residential amenity space provision may need to be reconfigured and reallocated. This could include through the provision of smaller private gardens, first-floor courtyards, roof terraces and shared communal spaces. These arrangements will be acceptable where the overall design quality is high, the proposal accords with the policies of the Live Well Locally and Housing chapters, and national guidance^[3], and residential amenity is protected.

10.21While opportunities for new greenspaces and biodiversity enhancements may be more limited in the central urban area due to its built-up nature and lack of space, meaningful interventions can still be successful, as detailed in the “Urban Nature” Priorities and Core Measures in the East Sussex and Brighton and Hove Local Nature Recovery Strategy.

Policy BX2: Bexhill Cultural Area Comment

10.22The Policy designates a “cultural area” to focus the enhancement of the activity and facilities offer, to improve patronage and the evening economy around the seafront as a significant amenity asset to the town.

10.23The arts, cultural and heritage offer in Bexhill is centred around the Grade I listed De La Warr Pavilion, which is internationally renowned for art installations and as a venue for live music; the adjacent, Grade II listed Colonnade and, further west, Bexhill Museum and Egerton Park. On the seafront itself are further facilities and heritage assets including the Bexhill Rowing and Sailing Clubs; the Grade II listed terrace of residential properties Marina Court Avenue; Marina Arcade, which comprises a mix of commercial and residential uses; and the war memorial.

10.24The De La Warr Pavilion, the seafront and its surrounding area is seen as a significant asset and hub for cultural and social activity within the town, being the focal point for festivals and events. The area is critical in not only providing an important local amenity and areas of public open space including blue and green infrastructure but also attracting visitors from further afield.

10.25The Rother and Hastings Tourism and Visitor Accommodation Study identifies central Bexhill as a strategic “tourism focus area”, where high-quality visitor accommodation will be supported. There is a particular need for additional hotel accommodation in the town centre. Proposals will be considered in accordance with Policy ECO7.

Policy BX3: London Road – Sackville Road Enhancement Area Comment

10.26The London Road – Sackville Road corridor is an important gateway to Bexhill town centre, seafront and Cultural Area (see Policy BX2). However, there are shortcomings in its operation and appearance in terms of the public realm. Impeded traffic flows, queuing traffic, lack of off-street parking, poor presentation of shopfronts and prominent advertising all serve to degrade the local environment. The significance of these streets to the appeal of, and approach to, the town centre warrants policy support for their enhancement. Priorities include improvements to pedestrian safety, active travel and public transport connections, public realm enhancements and support for the commercial environment.

10.27The Area adjoins the Cultural Area (Policy BX2) and the Beeching Road Enhancement Area (Policy BX4) and lies within the Bexhill Urban Area (Policy BX1), as well as adjoining some key brownfield sites allocated for redevelopment. It is intended that all these policies work together to complement each other and secure improvements and appropriate new development in this central area of Bexhill. Sackville Road also lies within the Bexhill Conservation Area and therefore any enhancements will need to be appropriate and take account of relevant heritage considerations.

Policy BX4: Beeching Road Enhancement Area Comment

10.28The Beeching Road enhancement area comprises the Beeching Road industrial estate, which is the largest industrial area in Bexhill. It includes a mixture of uses, not limited to employment but also accommodating the Police and Fire Stations, the Bexhill Diagnostic Centre and community uses including a Day Centre, Scout Hall and public car parking areas.

10.29This policy supports delivery of the Bexhill-on-Sea Place Plan, including exemplar projects for creative workspace activation, public realm improvements, and employment intensification.

10.30The Grade II listed former Bexhill West Station building at the southern edge of the Beeching Road estate plays an important role in providing a gateway to the area which should be enhanced. There is also some high-quality new development within the area, such as the Beeching Road Studios. However, much of the existing building stock and public realm remain uninspiring and of varying quality. This policy seeks to secure improvements to the appearance and design of the area and to support the diversification and intensification of the employment mix, as well as complementing improvements within the neighbouring London Road- Sackville Road Enhancement Area (Policy BX3). The Bexhill-on-Sea Place Plan particularly supports the creative industries and circular economy uses, in line with its proposals for a reuse hub and workspace activation.

10.31Active travel improvements are required in this area to provide safe and convenient routes and related infrastructure, not only within the Enhancement Area itself but also to link to the town centre, bus stops and the railway station.

10.32Parts of the area are at risk of surface water flooding, and development proposals will need to comply with Policies ENV1 to ENV3

10.33The area lies within the Bexhill Urban Area and the requirements of Policy BX1 also apply to development proposals within it.

10.34The Beeching Road Enhancement Area includes a largely vacant plot in the south-eastern section of the industrial estate, which is also separately allocated for a residential-led mixed use development through Policy BX5. Development proposals for the BX5 area will also need to comply with Policy BX4 through the provision of an improved public realm, and improved active travel connections to Beeching Road, Terminus Road and Victoria Road/ Reginald Road and onwards towards the Town Centre.

Policy BX5: Land south-east of Beeching Road Comment

10.35This is a brownfield site in the south-eastern part of the Beeching Road industrial estate. It is within the Urban Area Type, has a site size of 2.81 hectares and an indicative developable area of 2 hectares. It is allocated for some 200 dwellings as part of a mixed-use scheme at an indicative residential density of 120 dwellings per hectare.

10.36The site is likely to come forward for redevelopment in phases, with the central section (recently cleared) available in the short term. The northern section (also cleared) could accommodate a new GP surgery. The existing commercial and industrial units in the eastern and southern parts of the site are currently occupied but could become available for redevelopment later on in the Plan period, subject to the relocation of the current occupiers. The area currently used for public car parking in the eastern part of the site could potentially be relocated for redevelopment, but this would require careful consideration to prevent any adverse effects on the wider Beeching Road enhancement area or nearby Bexhill town centre.

10.37There are significant level differences across the site, falling from Beeching Road in the west towards the eastern boundary. The northern section of the site has been cleared, while the southern section includes some older style industrial buildings (some vacant) as well as a veterinary surgery and scout hut, and areas used for coach and public car parking. There is a Police Station adjacent to the site and predominantly two-storey residential properties along the eastern boundary (Reginald Road).

10.38There are two culverts which run through the site which would have a bearing on the siting of new buildings, requiring an 8 metres easement from each side of the culverts. The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment), and a large portion of the site is at risk of surface water flooding. Therefore, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment and appropriate Sustainable Drainage (SuDS) in accordance with Policies ENV1-3. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Development will need to be sympathetic to the surface water ponding in the southern part of the site. A sequential approach should be undertaken, by locating the most vulnerable aspects of development in areas of lowest flood risk.
• Consideration of land raising and flood storage compensation would be required if development is to be located within the areas at risk of flooding. Flood storage compensation would need to be provided on a level-for-level, volume-for-volume basis and would need to be accompanied by site-specific hydraulic modelling (including the culverted Egerton Stream) evidencing that ground modifications did not impact on flood risk elsewhere.
• Blockage modelling should be conducted as part of an FRA to assess the residual risk associated with potential blockage of the culverts on the Egerton Stream beneath Beeching Road and Terminus Road.
• A buffer distance from the Main River (at least 8m) will need to be maintained to allow access and maintenance.
• Where possible the existing culvert should be removed and the channel re-naturalised.
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water ponding.
• A Flood Response Plan will be required as the primary access route within the site (Wainright Road) is predicted to be affected during the surface water 1% AEP plus climate change event.

10.39The site’s sustainable location, in walking distance of Bexhill town centre and railway station, and adjacent to a large residential area to the east and within the Bexhill Urban Area (Policy BX1) makes it suitable for high density residential development. However, this will need to be sensitively designed and sited to ensure the protection of the amenity of future occupiers, having regard to the adjoining industrial estate.

10.40Convenience goods retail could also be acceptable at the site, subject to the proposal passing the sequential test and a retail impact assessment in accordance with Policy ECO6 (given the site’s edge of centre location), although the site was allocated for this use in the previous Local Plan (adopted 2019) and such a use has not come forward in that time. Additional commercial and business development could be accommodated as part of the site’s redevelopment, which should include the re-provision of any existing employment floorspace lost adjacent to the site’s southern boundary. Community uses would also be suitable within the site, and the retention of some public car parking.

10.41The site is close to the A259 which is part of the Strategic Road Network and therefore an appropriate Transport Assessment will be required in accordance with Policy INF2, and there will be a need to comply with any requirements of National Highways and the Local Highway Authority.

Policy BX6: Land adjacent to Bexhill Town Hall Comment

10.42This is a brownfield site within Bexhill Town Centre. It is within the Urban Area Type, has a site size of 0.6 hectares and an indicative developable area (for a new building) of 0.1 hectares. It is allocated for some 36 dwellings as part of a mixed-use scheme at an indicative residential density of 200 dwellings per hectare.

10.43The eastern part of the site contains Bexhill Town Hall, a Grade II listed building, and a 20th century, four storey office building to the rear. Both of these buildings are in use as offices and would be retained. The western part of the site contains a pair of Victorian villas with 20th century extensions, also currently in office use on short-term commercial leases, and an open yard to the rear which formerly accommodated a mechanic’s business.

10.44The western part of the site provides an opportunity for redevelopment for residential use, through the construction of a new residential building within the open yard in the north-western section (which is likely to come forward in the short term), and the conversion of the Villas (which could come forward later in the Plan period). Given the sustainable location and the constrained nature of the site, a high density, high-quality residential development is appropriate. While some car parking for the new residential development may be achieved on site, the development should take advantage of its sustainable location and include measures to encourage and improve pedestrian and cycle use and access to public transport.

10.45The loss of offices (a main Town Centre use, as defined in national planning policy) is generally resisted through planning policy, however, legislation grants significant “permitted development” rights for the conversion of small offices to residential uses, although these may not apply in this case due to the site adjoining a listed building. Notwithstanding this, the Villas are not ideally suited to office use, being originally converted from residential use. The small loss of converted office space would be offset by the benefits arising from the provision of 8 new residential units in a highly sustainable location within walking distance of services, facilities and public transport.

10.46Southern Water has advised that the site may have limited local network (sewerage) capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings.

10.47The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels hydrological catchment), and part of the site is at risk of surface water flooding. Therefore, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment and appropriate Sustainable Drainage (SuDS) in accordance with Policies ENV1-3.

Policy BX7: Sainsbury’s site, 1 Buckhurst Place Comment

10.48The site comprises a two storey, 1970s building which accommodates a supermarket and a separate small residential unit on its ground floor, an adjoining large car parking area accessed from Station Road, and a service yard. It is within Bexhill town centre but outside the Conservation Area, and just north of the railway line.

10.49The site is within the Urban Area Type, has a site size of 0.67 hectares and an indicative developable area of 0.4 hectares (excluding car parking). It is allocated for some 75 dwellings as part of a mixed-use scheme at an indicative residential density of 180 dwellings per hectare.

10.50The site offers an opportunity for redevelopment to improve its appearance, public realm, access, and its relationship with the town centre. Its sustainable location and large size mean that it could accommodate a high number of residential units at a high density above retail use, which should be retained on the ground floor.

10.51The site has some heritage sensitivities including its proximity to listed buildings and the conservation area and also three concrete murals within the site, which are recognised for their importance by the 20th Century Society. The policy requirements reflect these.

10.52The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment), and part of the site is at risk of surface water flooding. Therefore, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment and appropriate Sustainable Drainage (SuDS) in accordance with Policies ENV1-3. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Demonstrate through a site-specific FRA that the proposed development will be safe for its lifetime, taking account of the vulnerability of its users and potentially locating the more vulnerable aspects of the development in lower risk areas (e.g. in the eastern part of the site).
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water ponding.
• A Flood Response Plan will be required if properties or primary access routes are shown to be impacted during the design flood event.

Policy BX8: Former Bexhill High School site, Down Road Comment

10.53This vacant, brownfield site, formerly occupied by Bexhill High School, is located north of the Town Centre close to the junction of Combe Valley Way and the A259 and forms a prominent gateway to the town. Bexhill Leisure Centre and a former Skills Centre lie to the east, with King Offa Primary School to the west, and a large area of public open space, Bexhill Down, further west. There is a Ministry of Defence (MoD) Drill Hall to the south.

10.54The site is within the Urban Area Type, has a site size of 1.65 hectares and an indicative developable area of 1 hectare. It is allocated for some 80 dwellings at an indicative residential density of 80 dwellings per hectare. It is acknowledged this is below the density required through Policy BX1, however this site is subject to a planning permission for a lower number of dwellings and the allocation reflects a compromise, taking into account the site constraints.

10.55Two public footpaths cross the site, providing connections from Bancroft Road to Bexhill Down and linking to the Combe Valley Way underpass. An Archaeological Notification Area covers part of the site broadly in the southern section and development would need to comply with Policy HER1. The northern section of the site is bordered by a wider Area that Could become of Importance for Biodiversity (ACIB), as defined by the East Sussex Local Nature Recover Strategy (LNRS). Any proposed scheme will be required to contribute to the measures and objectives of the LNRS.

10.56The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment), and the southern part of the site is within Flood Zone 2 and at risk of surface water flooding. Therefore, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment and appropriate Sustainable Drainage (SuDS) in accordance with Policies ENV1-3.

10.57The allocation seeks to deliver a high-quality, accessible residential development within walking distance of the Town Centre and public transport connections.

10.58The site is very close to the A259 which is part of the Strategic Road Network. Therefore, an appropriate Transport Assessment will be required in accordance with Policy INF2 and there will be a need to comply with any requirements from National Highways and the Local Highway Authority.

Policy BX9: Land south of Terminus Road Comment

10.59This is a brownfield site currently occupied by car sales and car wash businesses and a small office, and an adjoining small plot of land.

10.60The site is within the Urban Area Type, has a site size of 0.19 hectares and an indicative developable area of 0.13 hectare. It is allocated for some 14 dwellings at an indicative residential density of 108 dwellings per hectare.

10.61The site is bound by the railway line to the south and residential development to the west, with the Beeching Road industrial estate on the opposite side of the road to the north. Network Rail has highlighted the need for suitable boundary fencing and noise mitigation measures to protect future occupiers.

10.62There are an underground surface water culvert and a separate main river culvert in the western part of the site, which will influence the layout of the development. It is expected that built development on the site will be restricted to the eastern part of the site.

10.63The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment), and the western part of the site is at risk of surface water flooding. Therefore, early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment and appropriate Sustainable Drainage (SuDS) in accordance with Policies ENV1-3. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Development will need to be sympathetic to the surface water ponding in the western part of the site. A sequential approach should be undertaken, by locating the most vulnerable aspects of development in areas of lowest flood risk.
• Blockage modelling should be conducted as part of an FRA to assess the residual risk associated with potential blockage of the culverts on the Egerton Stream beneath the railway line and Terminus Road.
• A buffer distance from the Main River (at least 8m) will need to be maintained to allow access and maintenance.
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water ponding.

10.64Previous planning appeal decisions have considered the car sales business within the site not to be an employment use and accepted that a solely residential scheme could be provided on the site without having an unacceptable impact on the Council’s employment land supply. The appeal decisions indicated that the site may only be suitable for a three-storey block of flats, given the characteristics of the locality. The inclusion of the plot to the east will result in the loss of a small office, however, this will not significantly affect the employment land supply and will allow for more dwellings on this constrained site.

Policy BX10: Land at 30 Dorset Road Comment

10.65The brownfield site is located behind a pair of semi-detached dwellings at Nos. 32 and 34 Dorset Road in and is currently in use as a builders’ yard.

10.66The site is within the Urban Area Type, has a site size of 0.08 hectares and an indicative developable area of 0.06 hectare. It is allocated for some 8 dwellings at an indicative residential density of 120 dwellings per hectare.

10.67The south side of the site adjoins the railway embankment. Network Rail has highlighted the need for suitable boundary fencing and noise mitigation measures to protect future occupiers.

10.68Outline planning permission was granted in 2024 for redevelopment of the existing builders’ yard to provide 8 flats with associated landscaping and parking with all matters reserved except for access which has not yet been implemented.

10.69The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment) although it is not shown to be at risk of flooding. Nevertheless, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS) in accordance with Policy ENV3.

Policy BX11: Rear of 11 Endwell Road Comment

10.70The site is located on Endwell Road within Bexhill Town Centre and the Town Centre Conservation Area. It comprises a privately-owned car park with 13 parking spaces and a single storey triple-bay garage. It is flanked by mixed-use commercial and residential development on either side.

10.71The site is within the Urban Area Type, has a site size of 0.04 hectares and an indicative developable area of 0.03 hectare. It is allocated for some 8 dwellings at an indicative residential density of 200 dwellings per hectare.

10.72Planning permission was granted in 2024 for the demolition of the garage block and provision of a 3-storey building containing 6 flats, which has not yet been implemented.

10.73The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment) although it is not shown to be at risk of flooding. Nevertheless, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS) in accordance with Policy ENV3.

Policy BX12: Eversley Road Car Park, Eversley Road Comment

10.74The site is a public car park, providing some 35 spaces accessible from Bexhill Town Centre, in a largely residential street. It is within the Town Centre Conservation Area but just outside the primary shopping area and town centre.

10.75The site is within the Urban Area Type, has a site size of 0.05 hectares and an indicative developable area of 0.05 hectares. It is allocated for some 10 dwellings as part of a mixed-use scheme at an indicative residential density of 200 dwellings per hectare. A careful design will be required to protect the amenity of adjacent properties and the character of the Conservation Area.

10.76The site lies within the Cuckmere and Pevensey Management Catchment (but not the Pevensey Levels Hydrological Catchment) although it is not shown to be at any significant risk of flooding. Nevertheless, early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS) in accordance with Policy ENV3.

10.77While the redevelopment of the site would reduce the number of public car parking spaces, this is a sustainable location within a short walk of the railway station and bus services. There is ample on-street parking nearby and a large public car park at the De La Warr Pavilion, within a short walk of the site. The benefits of providing additional dwellings in this location are considered to over-ride the small loss of car parking.

Parish: Bexhill

10.78The suburban area of Bexhill covers a large area outside the central urban area. The map above illustrates only a portion of it, focusing on locations where allocation sites are included. Generally, suburban areas are less centrally located in relation to key services, facilities and public transport connections, although some parts of the Bexhill suburban area do benefit from good access, including to the district centres at Sidley and Little Common.

10.79In this area there are opportunities for both brownfield and greenfield development. While the higher densities typical of the central urban area may not suit all suburban contexts, medium-density development can support walkability and local service viability. In accordance with national planning policy, it remains important that developments avoid homes being built at low densities and make optimal use of the potential of each site. Development should also respond positively to local character and contribute to a sense of place.

Policy BX13: Land at Broad Oak Park Comment

10.80The site comprises former agricultural buildings, last in use for small-scale commercial/ community uses, associated car parking and an adjoining small area of woodland. It is accessed via a narrow lane which also leads to the adjoining large area of public open space at Broad Oak Park. It is outside the Development Boundary of Bexhill and has a rural setting, close to grazing fields, woodland and open space. Nevertheless, as a brownfield site it is relatively close to the amenities of Bexhill and suitable in principle for small-scale residential redevelopment, providing it is sensitively designed to take account of the historic use of the site, the non-designated heritage asset of the remaining historic farmstead buildings and its rural setting.

10.81The site is within the Suburban Area Type, has a site size of 0.44 hectares and an indicative developable area of 0.2 hectares. It is allocated for some 8 dwellings at an indicative residential density of 40 dwellings per hectare.

10.82Woodland adjacent to the south-eastern boundary of the site forms part of a wider Area that Could become of Importance for Biodiversity (ACIB), as defined by the East Sussex Local Nature Recover Strategy (LNRS). Any proposed scheme will be required to contribute to the measures and objectives of the LNRS.

10.83The site lies within the Pevensey Levels Hydrological Catchment and is partly at risk of surface water flooding. Therefore, the proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Development will need to be sympathetic to the surface water ponding in the centre of the site. A sequential approach should be undertaken, by locating the most vulnerable aspects of development in areas of lowest flood risk.
• Demonstrate through a site-specific FRA that the proposed development will be safe for its lifetime, taking account of the vulnerability of its users.
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water ponding.

Policy BX14: Land north of Broadoak Lane Comment

10.84The site comprises an area of open space consisting of a sloping grassed field with treed boundaries on the edge of a residential area, just south of an area of land currently being developed with 210 dwellings.

10.85The site is within the Suburban Area Type, has a site size of 1.26 hectares and an indicative developable area of 1 hectare. It is allocated for some 35 dwellings at an indicative residential density of 35 dwellings per hectare.

10.86National planning policy seeks to prevent existing open space from being built on unless certain criteria are met, including that the loss resulting from the development would be replaced by equivalent or better provision in a suitable location. This is also a condition of a deed of dedication with Fields in Trust, which the site is currently subject to (together with the adjoining, larger Broad Oak Park). While the deed of dedication is not a planning matter, it does mean that an alternative, equivalent area of public open space would need to be identified and dedicated before this field could be released for an alternative use. This would also satisfy the national planning policy requirement. The council, as landowner, is currently seeking to develop proposals to satisfy the Fields in Trust requirement, which would retain the same level of open space for public access within the same catchment area.

10.87On completion of the adjoining development, the site will be surrounded by residential development on three sides. Given the significant need for housing and the adjoining, larger area of public open space to the west, the release of this limited parcel of land can be accepted, on the basis that an equivalent replacement area of open space will be identified and secured by the Council as landowner prior to the commencement of development.

10.88There is a public footpath on the southern edge of the site but no suitable vehicular access point from Broadoak Lane, although pedestrian links could be provided. Therefore, vehicular access would need to be via the adjoining land to the north. It is likely that financial contributions towards bus services would be required as part of the development, as the area is relatively poorly served.

10.89The site lies within the Pevensey Levels Hydrological Catchment. Therefore, the proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed.

Parish: Bexhill

10.90The largest sites suitable for development in West Bexhill are on greenfield land, although there are also some brownfield opportunities. Some substantial sites already have planning permission or are delegated to approve, or were allocated in the previous Local Plan. This Local Plan takes forward these sites, together with some additional large sites.

10.91Impacts of development in this area on the A259 Barnhorn Road and the Habitats sites at the Pevensey Levels in particular will need to be carefully considered through planning applications. A new western road bypass of Bexhill is not anticipated for delivery during the Plan period, and consequently the allocations work within the limitations of the existing road network.

10.92The site allocations and the specific site requirements have been carefully considered, taking into account existing constraints in the West Bexhill area, including:

• Its proximity to the environmentally sensitive area of the Pevensey Levels, meaning any new development must incorporate careful sustainable drainage (SuDS) solutions comprising at least three treatment stages in accordance with Policy ENV3;
• Impacts on the A259 trunk road, including the Little Common Roundabout;
• The road network away from the A259, which (particularly in the west) comprises narrow, winding country lanes unsuited to additional traffic;
• Its sensitive landscape setting, with long views into the countryside to the south-west and north;
• Areas at risk of flooding, which effectively encircle the Growth Area to the south and north;
• The distance of many large sites from services, facilities and public transport connections in Bexhill and Little Common, meaning that without careful planning and provision of infrastructure, new residential development could be unsustainable and largely car dependent.

Policy BX15: West Bexhill Growth Area - Infrastructure Comment

10.93There is a need for a master-planning approach to the West Bexhill Growth Area to ensure the creation of a Live Well Locally sustainable community. A strategic masterplan diagram is shown at Figure 10.3 below.

10.94The West Bexhill Strategic Masterplan provides an overarching spatial framework for coordinating development across the Growth Area. It identifies the broad relationship between development areas, local shops and services, education, health and community infrastructure, sports and recreation, strategic green and open space, retained woodland, tree belts and hedgerows, key heritage assets and the principal movement network. It also illustrates public transport connections and how individual development sites should contribute to a connected strategic active travel network, including links to existing routes, planned improvements and identified network gaps or connections that need to be secured.

10.95The masterplan is strategic and indicative rather than a detailed design or layout for individual sites. Development proposals should respond positively to the spatial principles shown, while the precise disposition of development, streets, spaces and infrastructure will be determined through the relevant site allocation policies, other policies of the Local Plan and, where required, more detailed site masterplanning. Particular importance should be given to maintaining connections between development sites and with surrounding neighbourhoods, integrating and connecting green and blue infrastructure, and ensuring that local shops and services, health and community facilities, the proposed primary school, sports and recreation provision and other infrastructure are accessible by walking, wheeling, cycling and public transport.

10.96New residential and employment development must be supported by new and improved infrastructure. This is identified in the Infrastructure Delivery Plan (IDP) and Policy BX15. The IDP will be subject to regular review, ensuring it takes account of the latest available information including on development phasing and viability. Impacts on infrastructure in adjoining Authorities is also a consideration, given the close proximity of parts of the Growth Area to the district boundary.

10.97 It is appreciated that some of the individual sites listed in Policy BX15 already benefit from planning permission (or are delegated to approve subject to a Section 106 agreement). In these cases, the infrastructure requirements of the individual site would have been secured through the permission, and this policy does not change that. However, the sites are included to allow for a situation where an existing planning permission may not be implemented.

West Bexhill Growth Area – Strategic Masterplan Comment

Strategic Masterplan Key:

Policy BX16: Gorses Car Park and Open Space, The Gorses Comment

10.98The site comprises a small public car park and an adjoining larger area of public open space consisting of grassed and wooded areas. It is located in a relatively sustainable location within walking distance of Cooden Beach railway station and is bounded by residential development to the east and west.

10.99The site is within the Suburban Area Type, has a site size of 0.39 hectares and an indicative developable area of 0.06 hectares. It is allocated for some 10 dwellings at an indicative residential density of 166 dwellings per hectare.

10.100There is ample on-street parking in the local area available for users of the nearby railway station, and consequently, the loss of the public car park is considered acceptable, on the basis that its redevelopment would allow for the provision of small dwellings, boosting the housing supply of this accommodation type in this area of Bexhill.

10.101However, the loss of the public open space within the site would be contrary to national planning policy and consequently, any impact would need to be minimised as far as possible, and any loss replaced by equivalent provision in terms of quantity and quality in a suitable location.

10.102Given the site’s close proximity to the Pevensey Levels SSSI, Ramsar site and SAC, and the fact that the scrubland to the south of the car park is defined as an Area that Could become of Importance for Biodiversity (ACIB) in the East Sussex Local Nature Recover Strategy (LNRS), the development would need to include measures to protect and enhance biodiversity, and contribute to the measures and objectives of the LNRS.

10.103The site lies within the Pevensey Levels Hydrological Catchment. Therefore, the proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Demonstrate through a site-specific FRA that the proposed development will be safe for its lifetime, taking account of the vulnerability of its users. A sequential approach should be undertaken, by locating the most vulnerable aspects of development in areas of lowest flood risk.
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water ponding.
• A Flood Response Plan will also be required.

10.104The site is close to the railway line and Network Rail has highlighted the need for boundary fencing and appropriate noise mitigation measures to protect the amenity of the new dwellings. The siting and design of this would be for determination at planning application stage.

Policy BX17: Land off Spindlewood Drive Comment

10.105This greenfield site lies to the south of Barnhorn Road and west of Spindlewood Drive, Little Common. It is within the Suburban Area Type, has a site size of 7.3 hectares and an indicative developable area of 3.4 hectares. It is allocated for some 146 dwellings at an indicative residential density of 43 dwellings per hectare.

10.106The site can be accessed from both Spindlewood Drive and Barnhorn Road and is close to bus services, shops and community facilities within Little Common District Centre. Highway impacts must be carefully assessed, with any proposals required to deliver appropriate off-site mitigation. This includes consideration of cumulative impacts from other developments. One of the accesses is to come from the A259 which is part of the Strategic Road Network. Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB). Improvements to pedestrian and sustainable transport links are essential. This includes a direct pedestrian route from the site to Barnhorn Road, footway improvements at the Spindlewood Drive access, upgraded bus stop infrastructure, and financial contributions towards improved local bus services. A site-specific travel plan will be required to ensure the use of sustainable transport is maximised.

10.107The site lies within the Pevensey Levels Hydrological Catchment. Habitats Regulations Assessment screening will be needed, to demonstrate beyond reasonable scientific doubt that the development can be delivered on the site without harming the integrity of the Pevensey Levels Special Area of Conservation/RAMSAR site. The proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed.

10.108There are also areas of the site that are within Flood Zones 2 and 3 which overlaps with areas at risk of surface water flooding. This is predominantly in the south-western part of the site and along the southern boundary. A site-specific flood risk assessment will be needed.

10.109The south-western field provides open views towards the Levels and must be kept free of built development to protect the landscape setting. This area is considered most suitable for SuDS infrastructure, enabling the retention of its open character.

10.110A connection to the nearest point in the foul sewerage network with adequate capacity will be required, agreed with the service provider. Development layout should also account for the existing wastewater pumping station at Spindlewood Drive to avoid land use conflicts.

10.111There are two bands of trees that run through the site linking a wooded area to the north with Ancient Woodland to the south. This is an important landscape feature within the site and acts as a wildlife corridor between the two areas of woodland that should be retained for ecological and recreational open space. Part of the area may be suitable for children’s play space. It is recognised that the existing track bisecting the corridor (or an alternative to it) will need to be made up as part of the internal vehicular movement network. Appropriate mitigation measures to enable the safe movement of wildlife through the corridor will need to be incorporated in the detailed design. There is also a pond in this area which should be retained and enhanced for ecological purposes only and not as part of the SuDS. The pond lies adjacent to the Ancient Woodland and provides existing habitat for protected species. It would therefore be appropriate to include this area within an enhanced buffer zone to the woodland and to restrict public access to it.

10.112Elsewhere, a minimum 15m buffer between development and the Ancient Woodland should be maintained and other appropriate wildlife mitigation measures informed by a full evaluation of the site’s ecological value and potential will be required. The southern part of the site forms part of an Area that Could become of Importance for Biodiversity (ACIB), as defined in the East Sussex Local Nature Recover Strategy (LNRS), and the ancient woodland is defined in the same document as an Area of Particular Importance for Biodiversity (APIB). The development would need to include measures to protect and enhance biodiversity and contribute to the measures and objectives of the LNRS.

10.113The north-west part of the site adjacent to the historic medieval farm complex is identified as an Archaeological Notification Area and a geophysical survey of the site has identified the potential for archaeological remains to be present throughout this whole field. It will be necessary to clarify the significance of these features through trial trench testing prior to the detailed layout of development on the site being designed so that any important remains can be retained in situ.

Policy BX18: Land north of Barnhorn Manor Caravan Park Comment

10.114This site lies just west of the land subject to Policy BX17. It is within the Live Well Locally Area Type, has a site size of 1 hectare and an indicative developable area of 0.5 hectares. It is allocated for some 20 dwellings at an indicative residential density of 40 dwellings per hectare.

10.115The site previously contained a number of agricultural buildings including livestock barns although most of these have now been demolished, as agricultural activity in the area has been reduced. The site is sandwiched in between existing residential development on the southern side of Barnhorn Road and Oak Tree Place, planned residential development to the east, and Barnhorn Manor Caravan Park to the south (which is itself contained within the land subject to Policy BX19).

10.116The site provides an opportunity for a small extension to the residential development at the adjoining site (BX17), utilising the same access point from A259/Barnhorn Road, part of the Strategic Road Network (SRN). Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB).

10.117The site lies within the Pevensey Levels Hydrological Catchment and there are small areas at risk of surface water flooding including waterbodies in the eastern part of the site. Therefore, the proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed.

10.118The site is within an Archaeological Notification Area, and there is a grade II listed building, Barnhorne Manor, Lower Barnhorne, just to the west. The need to protect the setting of the listed building reduces the overall suitable developable area of the site. The development will need to be of an appropriate scale and layout and include suitable landscaping and extent of built development, to ensure no unacceptable harm to the significance of the listed building. Development should respond positively to the principal drive approaching Barnhorn Manor by ensuring that the approach remains legible as part of a more rural, estate-influenced setting, rather than being enclosed or dominated by standard suburban frontage. This could be achieved through a generous landscape buffer, tree-lined avenue or comparable green edge along the drive, together with a carefully considered layout that preserves visual separation and avoids presenting the new housing as the primary spatial focus on the approach to the manor.

10.119The south-western corner of the site is located in close proximity to the listed building and is prominent in approaches to it. A landscape-led strategy will be particularly important in this part of the site, potentially integrated with Biodiversity Net Gain provision, to help secure an appropriate degree of separation and soften the transition between new development and the listed building’s setting. In design terms, built form should adopt a subservient, traditionally informed character, with scale, materials, roofscape (including chimneys), boundary treatment and detailing selected to complement rather than compete with the character and setting of Barnhorn Manor, Lower Barnhorne.

Policy BX19: Land south of Barnhorn Road Comment

10.120This is a large area of mostly greenfield land to the south of Barnhorn Road, comprising agricultural fields at the rear of ribbon development. It also includes, in its eastern section, the Barnhorn Manor Caravan Park and a historic farmstead and Grade II listed building at Barnhorne Manor, Lower Barnhorne.

10.121The site is within the Live Well Locally Area Type, has a site size of 24 hectares and an indicative developable area of 12 hectares. It is allocated for some 400 dwellings as part of a mixed-use scheme at an indicative residential density of 40 dwellings per hectare.

10.122Development of this site will result in a relatively large extension of the built form of Bexhill into the countryside. However, a carefully designed development, suitably landscaped and including a mix of uses and improved pedestrian and cycle links, will enable the creation of a sustainable community with a new urban edge while protecting the adjoining sensitive landscape and heritage assets.

Landscape Impacts

10.123The proximity of the Levels, with its wide, open views south-westwards constrains the extent of developable land south of Barnhorn Road in landscape terms. Adjoining land to the west (in the same ownership) is considered unsuitable for development due to its exposure from the south-west, meaning development here would be very harmful to the landscape setting of Bexhill. The site itself, however, is relatively enclosed from wider views, containing individual fields benefiting from mature and substantial treed and hedged field boundaries, although development within the northern parts of the site in particular is likely to be visible in long views from lower lying land to the south, against the backdrop of existing ribbon development south of Barnhorn Road. Development proposals will need to be informed by a detailed Landscape and Visual Impact Assessment in accordance with Policy LAN1, to ensure development is landscape-led and creates a new, high-quality settlement edge.

10.124As well as including an appropriate buffer, the Ancient Woodland parcels to the east of the site should be provided with a linking woodland belt with scrub which would extend along the southern edge of the site, with a thinner tree belt along the northern edge. This will also provide some physical and visual separation with the Grade II Listed Barnhorne Manor Lower Barnhorne. All existing field boundaries and individual mature trees (including veteran trees and ancient woodland) within and adjoining the site will need to be retained and protected as part of the development, together with existing ponds, ditches and streams.

10.125The narrow central fields west of the Ancient Woodland (the westernmost of which contains a Public Footpath) should be left at least partly undeveloped, to form part of a GBI network, to conserve the rural character and perception of this from the Right of Way, with suitable buffers where required, including consideration of the present glimpsed visibility towards the southern elevation of the Grade II Listed Barnhorne Manor Lower Barnhorne. The historic agricultural structures north-west of these fields should be considered for retention in part, perhaps re-purposed or incorporated in some way to retain the time depth to non-designated heritage assets within the Site.

10.126The more cohesive group of fields to the west, which fall to the south towards the Pevensey Levels are defined within a strong structure of tree belts and lines of varying widths, which would physically and visually contain settlement, whilst reflecting a westerly extension of the Bexhill settlement boundary towards a strong western boundary tree belt, underscoring the existing ribbon development to north. Where vegetated boundaries are thinner there may be an opportunity to further reinforce these, which may contribute to enhanced ecological connectivity and reduced sediment runoff / potential improvement to water quality.

Heritage Impacts

10.127 The site is largely within an Archaeological Notification Area and contains a historic farmstead and Grade II listed building, Barnhorne Manor, Lower Barnhorne in its eastern section. Development of the site will need to take a whole-site masterplan approach, informed by a proportionate heritage assessment^[4] which identifies the significance of Barnhorne Manor, defines the areas of land that contribute most strongly to its setting, and establishes clear parameters for layout, density, building height, landscape buffers, open space, access, movement and design character. The listed building’s architectural, historic, spatial and farmstead relationships are to be conserved as part of the development.

10.128Development in the eastern part of the site has the greatest potential to affect the setting and appreciation of the listed building. The principal approach drive, associated open land, former farmstead context, tree and hedgerow structure, and the spatial relationship between the manor and its surrounding rural landscape should be retained as legible components of the asset’s setting. a sensitive landscape-led strategy both in the immediate vicinity of Barnhorne Manor and across the wider allocation where this contributes to the experience of the listed building. Around the listed building, substantial open space, structural planting and retained field boundaries should be used to secure separation, preserve the primacy of the heritage asset and soften the transition between new development and the historic farmstead. At the same time, the treatment of the southern and south-western edges of the allocation will be important in longer views where those views contribute to the appreciation of Barnhorne Manor and its wider rural setting.

10.129 In design terms, the prevailing context indicates that a traditional character and form would be the most appropriate response within the vicinity of the manor house. New built form should be clearly subservient to Barnhorne Manor in scale, height, massing, roofscape, materials, boundary treatment and detailing, and should avoid a standard suburban character that would compete with, or visually absorb, the listed building. A varied density approach may therefore be required, with lower density, greater landscape separation and a more restrained architectural language around the manor and its approach, while any higher density elements are directed to less heritage-sensitive parts of the site.

Ecological and Water Impacts

10.130The site lies within the Pevensey Levels Hydrological Catchment and parts of the site directly adjoin the Pevensey Levels SSSI, SAC and Ramsar site. Habitats Regulations Assessment screening will be needed, to demonstrate beyond reasonable scientific doubt that the development can be delivered on the site without harming the integrity of the Pevensey Levels Special Area of Conservation/RAMSAR site. The protected habitats sites, together with the ancient woodland adjacent to the site’s south-eastern boundary, are identified as Areas of Particular Importance for Biodiversity (APIBs) in the Local Nature Recovery Strategy (LNRS), and adjoining areas (some within the site) are identified as Areas that Could Become of Importance to Biodiversity (ACIBs). Development will need to include significant areas for Biodiversity Net Gain, taking into account the Priorities and Measures of the LNRS.

10.131The whole site masterplan will need to include substantial areas of green infrastructure throughout the site, including areas of public open space. This will need to be carefully designed to encourage public use and not create additional recreational pressures on the Pevensey Levels or other areas of APIB or ACIB in close proximity to the site.

10.132Due to its location within the Pevensey Levels Hydrological Catchment, the proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment. The extent of necessary SuDS features will inform the layout of the development and the overall site capacity. In addition, Southern Water has advised that the site may have limited local network (sewerage) capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings.

Access and Sustainable Transport

10.133Vehicular access to the site will need to come from the A259 Barnhorn Road to the north, which is part of the Strategic Road Network, however, a suitable access point has yet to be determined.

10.134Land adjacent to the site to the north-west has been made available, where a new roundabout could potentially be constructed on the A259. However, this would result in development in a highly prominent location when viewed from the Pevensey Levels to the south-west, harming the rural character of the edge of Bexhill and potentially also harming the setting of the Grade II Listed building Barnhorn Manor (Barnhorn Road). Consequently, an access further east would be preferable in landscape terms.

10.135Detailed transport assessment will need to be carried out to support the planning application, to determine the vehicular access point(s) and the extent of necessary improvements and interventions. This includes policy compliance regarding new accesses onto the Strategic Road Network as contained with DfT Circular 01/2022, in particular paragraphs 18 to 25. In addition, compliance will be required in line with the Design Manual for Roads and Bridges (DMRB) and a Stage 1 Road Safety Audit (RSA) and a Walking, Cycling and Horse-riding Assessment and Review (WCHAR) will need to be evidenced, all to be assessed by National Highways and East Sussex County Council.

10.136Improvements to the existing public rights of way network, as well as new pedestrian and cycle paths through the site and linking it to the district centre at Little Common and further south-east towards Cooden Beach station, will also be required, along with improvements to bus services.

Mix of Uses

10.137 The redevelopment of the caravan park within the site will result in the loss of tourist accommodation, contrary to Local Plan policy, and consequently, the site should accommodate either new employment floorspace or alternative, appropriate commercial uses (which could include tourist accommodation). The provision of a mix of uses, to also include community uses, significant areas of green infrastructure and outdoor sports infrastructure (as appropriate) will also ensure the creation of a sustainable community in this south-western part of Bexhill. Minimum floorspace requirements have not been set through the policy, to allow flexibility for the mix of uses and also provide for the detailed scheme to take account of the site’s landscape and heritage sensitivities and vehicular access implications.

Policy BX20: Land north of Rosewood Park Comment

10.138This is a large greenfield site on the western edge of Bexhill, adjoining a sizeable, recently completed residential development at Rosewood Park. It is subject to an outline planning application, delegated to approve subject to the completion of a Section 106 legal agreement, and the policy reflects the parameters of that accepted proposal.

10.139 The site is within the Live Well Locally Area Type, has a site size of 25 hectares and an indicative developable area of 18.9 hectares (9.7 hectares of which is for housing). It is allocated for some 340 dwellings as part of a mixed-use scheme at an indicative residential density of 35 dwellings per hectare.

10.140The site predominantly consists of agricultural fields, with boundaries defined by hedgerows, woodland shaws and mature trees. It lies within the Pevensey Levels Hydrological Catchment Area and is located 0.9 km from the Pevensey Levels Ramsar, SAC and SSSI. Parts of the site fall within Flood Zones 2 and 3 and are at risk of surface water flooding, necessitating careful management of flood risk and drainage. The proposal would need to include appropriate Sustainable Drainage (SuDS) with at least three treatment stages, in accordance with Policy ENV3. Early pre-application engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed, together with a site-specific flood risk assessment. In addition, Southern Water has advised that the site may have limited local network (sewerage) capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings.

10.141The development will also need to incorporate substantial new areas of public open space, including formal and informal provision, a central focal area, green corridors, and dedicated children’s play areas (NEAP, LAP and Trim Trails). The creation of a Green Infrastructure (GI) network is central to the required layout, retaining habitats of woodland, scrub, shaws, hedgerows, trees and floodplain grazing marsh, complemented by new landscaping and Sustainable Drainage Systems (SuDS). Development must be supported by a landscape-led masterplan, ensuring an integrated approach that enhances biodiversity and supports habitat connectivity.

10.142The majority of the site area is identified, in the Local Nature Recovery Strategy (LNRS) as an Area that Could Become of Importance to Biodiversity (ACIB), and the designated ancient woodland adjacent to the eastern boundary is an Area of Particular Importance to Biodiversity (APIB). Development will need to include significant areas for Biodiversity Net Gain, taking into account the Priorities and Measures of the LNRS. Priority species, including White Admiral butterfly, are recorded adjacent to the site and ecological surveys will be required.

10.143The site is within the Pevensey Levels Hydrological Catchment, and Habitats Regulations Assessment screening will be required to demonstrate beyond reasonable scientific doubt that the development can proceed without adverse effects on the integrity of the Pevensey Levels SAC/Ramsar site. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS).

10.144The site also lies in an area of known archaeological interest and heritage investigations will be required in accordance with Policy HER1.

10.145Access will be taken from Stowe Drive via Brooklands Road and onto the A259/Barnhorn Road (part of the Strategic Road Network), supported by dedicated cycle lanes, improved public rights of way and new recreational links to the wider countryside. Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB). The development will also provide a centrally located retail/community facility (Use Classes E/F) including a convenience retail element to reduce the need for longer journeys.

10.146To mitigate transport impacts, a comprehensive package of highway and sustainable transport measures will be secured. This includes off-site works, financial contribution towards Footpath FP51b upgrade, investment in bus services and digital demand responsive transport (DDRT), and a centrally located transport hub with shelter, lighting and seating, a Travel Plan, and provision of electric vehicle hire car club spaces.

10.147Phasing of development is critical to ensure highway capacity and safety are maintained. Access arrangements, parking and cycle parking provision must be completed for each phase before its occupation.

Policy BX21: Land east of Sandhurst Lane Comment

10.148The site comprises sections of two agricultural fields and associated agricultural structures, just north of the larger area of land subject to site allocation policy BX20 of this Plan. It is within the Live Well Locally Area Type, has a site size of 3.3 hectares and an indicative developable area of 1.7 hectares. It is allocated for some 68 dwellings at an indicative residential density of 35 dwellings per hectare.

10.149The site is currently of a semi-rural character, however the character of the area will change significantly with the development of site BX20, and this site provides an opportunity to extend the residential development agreed on the larger site, using the same vehicular access, but will only be acceptable if constructed at the same time as, or following, the development of site BX20. A Landscape and Visual Impact Assessment will be required to inform the layout and detailed design of the development and an area of green infrastructure will be required in the northern section of the site to provide appropriate separation to, and protect the setting of the historic farmstead to the north.

10.150Policy criteria are included to address the environmental and heritage constraints affecting the site including Ancient Woodland, an historic farmstead and a Public Right of Way. There are also areas of the site at risk of surface water flooding, and these are primarily located in the areas of existing development and the track through the centre of the site.

10.151The whole site area is identified, in the Local Nature Recovery Strategy (LNRS) as an Area that Could Become of Importance to Biodiversity (ACIB), and the designated ancient woodland adjacent to the eastern boundary is an Area of Particular Importance to Biodiversity (APIB). Development will need to include significant areas for Biodiversity Net Gain, taking into account the Priorities and Measures of the LNRS. Priority species, including White Admiral butterfly, are recorded adjacent to the site and ecological surveys will be required to accompany the planning application.

10.152The site is within the Pevensey Levels Hydrological Catchment, and Habitats Regulations Assessment screening will be required to demonstrate beyond reasonable scientific doubt that the development can proceed without adverse effects on the integrity of the Pevensey Levels SAC/Ramsar site, with SUDS including at least three treatment stages in line with Policy ENV3. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS).

10.15310.153 The site is not particularly well-located in relation to services and facilities in Little Common and Bexhill. Additionally, vehicular access from the adjoining road, Sandhurst Lane, would not be appropriate due to the narrow and winding nature of that lane.

10.154 As noted above, the acceptability of the development of this site is dependent on the development of the adjoining site (BX20) – to provide both a vehicular access but also some mix of facilities and services in close proximity, namely, the retail/community facility (Use Classes E/F) and sustainable transport hub within the larger site. The site will therefore ultimately gain access form the A259/Barnhorn Road which is part of the Strategic Road Network. Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB).

Policy BX22: Land at Barnhorn Green Comment

10.155This site lies within the wider Rosewood Park development area, north of the A259. It is currently grassed with mature hedgerows and trees, including a north–south tree belt of landscape importance.

10.156The Council acquired the site in 2019 to ensure delivery of employment space and a GP surgery. Planning permission has since been granted which includes modern light industrial units, meeting a clear local need for small workshops. As development has not yet commenced, the site allocation policy reflects the planning permission in parts (a) and (b). The policy also provides flexibility for an alternative mixed use to include small-scale residential units, in the event of the employment floorspace not coming forward^[5], which is appropriate given the residential character of the surrounding area and the small amount of potential employment floorspace affected.

10.157The site will also deliver a new medical centre to meet growing primary care needs. The existing Little Common Surgery is constrained and lacks capacity to expand. In partnership with the NHS and local GPs, the Council has developed a purpose-built facility to accommodate the Primary Care Network, provide additional clinical services, improve accessibility, and meet modern parking requirements. The centre will be delivered to Health Building Note standards and achieve BREEAM Excellent in line with funding requirements.

10.158The site access is from the A259, part of the Strategic Road Network. Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges. The site adjoins existing residential areas and community facilities, with Little Common local centre within walking and cycling distance, offering shops and services for future employees.

10.159Ecological assessment has identified habitats and species of value, which will need to be safeguarded and enhanced through appropriate mitigation and biodiversity measures. Development will need to ensure integration with its surroundings and a cohesive design approach across the whole site.

10.160The site is within the Pevensey Levels Hydrological Catchment, and Habitats Regulations Assessment screening will be required to demonstrate beyond reasonable scientific doubt that the development can proceed without adverse effects on the integrity of the Pevensey Levels SAC/Ramsar site, with SUDS including at least three treatment stages in line with Policy ENV3. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS).

Policy BX23: Land south of Sandhurst Lane, Bexhill Comment

10.161 This is a contained site comprising two land parcels, which is adjacent to existing and planned built development. It provides an opportunity for additional dwellings. It is within the Live Well Locally Area Type, has a site size of 1.45 hectares and an indicative developable area of 0.7 hectares. It is allocated for some 25 dwellings at an indicative residential density of 40 dwellings per hectare.

10.162 While the site bounds Sandhurst Lane to the north, this would not provide an acceptable vehicular access to the site due to its narrow and winding nature and lack of footways. Consequently, vehicular access must come from adjoining land to the south (subject to Policy BX23 of this Plan). This means access will be ultimately come via the A259 Barnhorn Road which is part of the Strategic Road Network (SRN). Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB).

10.163The northern part of the site is more environmentally constrained than the southern section, containing mature trees (including protected trees on its eastern boundary), a pond within its eastern section and a further large pond on adjoining land. This part of the site also gives rise to areas at risk of surface water flooding. This part of the site offers opportunities for Biodiversity Net Gain.

10.164The site lies within the Pevensey Levels Hydrological Catchment Area, meaning that development must incorporate careful sustainable drainage (SuDS) solutions comprising at least three treatment stages in accordance with Policy ENV3. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS).

Policy BX24: Beeches Farm and land north of Barnhorn Road Comment

10.165This is a large greenfield site on the northern side of Barnhorn Road (A259), comprising a network of agricultural fields, with mature trees and hedges defining individual field boundaries. It is within the Live Well Locally Area Type, has a site size of 29.7 hectares and an indicative developable area of 15 hectares. It is allocated for some 540 dwellings at an indicative residential density of 40 dwellings per hectare as part of a mixed-use development.

10.166The site provides an opportunity for a strategic-scale, residential-led, mixed-use development on the edge of Bexhill. Unlike many development sites in this area, the site has a direct frontage to Barnhorn Road and consequently, is also suitable to a primary school and class E uses required through Policy BX15 of this Plan (West Bexhill Growth Area – Infrastructure Policy). The site is also bound by Coneyburrow Lane and Sandhurst Lane although these are not suitable to provide vehicular access to the site due to their narrow and winding nature and lack of footways.

Landscape Impacts

10.167This is an undulating site and while much of it is relatively contained in the landscape by its topography, there are some higher sections affording long views across the countryside to the north and north-west. Consequently, development will need to be carefully and sensitively designed, informed by a Landscape and Visual Impact Assessment and Heritage Assessment, to ensure an appropriate extension to the built form of Bexhill can be achieved without harming the intrinsic character and beauty of the countryside beyond.

10.168A key requirement to achieving a successful design will be the retention of existing field boundaries, including mature trees which are key landscape and ecological features. Coneyburrow Lane and Sandhurst Lane along the borders of the site are oak tree lined, with understorey scrub of varying densities. Field boundaries of more irregular field parcels to the northern half of the site are well defined with dense hedgerow and dispersed trees or tree lined. There are some field corner patches of woodland within the site. All trees and hedgerows should be retained as part of the development, excepting for short stretches to allow for access, which should be minimised as far as possible.

10.169The site comprises of a patchwork of some thirteen fields located about a spur of high ground, bordered by Coneyburrow Lane to the west, Sandhurst Lane to the east and Barnhorn Road (A259) to the south. Landform falls away east and west of the site and to the north, where the narrow country lanes form a junction, with Sandhurst Lane continuing northwards. Outside of the site area to the southeast is a cluster of dwellings including two Grade II Listed Buildings at Sandhurst Lodge and Beeches Farm, whose northern curtilage borders the Site. Public Footpath 12b extends between the two lanes upon the high ground west of Beeches Farm. There are views across to comparably elevated landform some 1km to the north and northwest from the Footpath. The southern fields within the Site upon the ridgetop contribute to the rural approach to Bexhill along the A259.

10.170Built development should be confined to the eastern and central parts of the site, which are more enclosed and do not readily form part of a treed skyline, meaning they are of lower susceptibility to change with regards to visual prominence and contribution to rural character. However, part of the eastern section of the site has heritage constraints, being located close to the two buildings as detailed further below, meaning a careful layout will be required. Built development should be avoided in the northern- and western-most fields in order to maintain rural vistas through the western part of the site from Barnhorn Road and provide a transition to the countryside beyond. The western and northern parts of the site could be suitable to accommodate green infrastructure including public open space, areas for habitat creation and SuDS features.

Heritage Impacts

10.171As noted above, there are two, 18^th century, grade II listed buildings to the east of the site. The significance of both assets is partly architectural but also derives from their historic relationship with the surrounding agricultural and lane-side landscape, where their rural setting, mature boundary structure and separation from larger-scale built development contribute to an appreciation of their former functional and spatial context.

10.172Development has the potential to alter the rural and agricultural character of their setting, particularly on the eastern edge of the allocation and in views from Sandhurst Lane and surrounding public routes. The layout should be informed by a proportionate heritage assessment^[6] that identifies the contribution made by the intervening fields, hedgerows, mature trees, lanes and topography to the significance of the listed buildings. Built development should be set back from the eastern boundary where necessary, with lower density, generous green infrastructure, retained and reinforced field boundaries, and carefully managed open space used to maintain a legible transition between the historic lane-side assets and the new development.

10.173The indicative density of 40 dwellings per hectare should not be applied uniformly where this would result in an abrupt suburban edge near the listed buildings or in elevated parts of the site that are more visible in views relevant to their setting. A varied density approach would be more appropriate, with more sensitive parts of the eastern and north-eastern edges designed at a lower intensity and with a stronger landscape framework. Any larger-footprint non-residential buildings, parking, servicing and lighting should be sited so that they do not introduce an overly urbanising influence within the setting of Sandhurst Lodge or Beeches Farm.

Ecological and Water Impacts

10.174Other than its significant treed boundaries detailed above, the site is relatively unconstrained, environmentally, although it lies within the Pevensey Levels Hydrological Catchment Area, meaning that development must incorporate careful sustainable drainage (SuDS) solutions comprising at least three treatment stages in accordance with Policy ENV3. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS). Parts of the site are at risk of flooding and development should be avoided in these areas.

Access and Sustainable Transport

10.175The site is some distance to services and facilities in Little Common District Centre, and not within walking distance of the nearest primary school. Consequently, the allocation includes provision for a primary school. This would be provided at the relevant time when the County Council determines there is a need for additional school places. Consequently, the policy also requires a raft of sustainable transport measures including improvements to bus services and active travel routes outside the site (linking to Little Common) and also active travel routes through the site. Contributions towards improving connectivity with the nearest railway station at Cooden Beach may also be appropriate.

10.176Evidence suggests that an acceptable vehicular access onto the A259 is achievable. Vehicular access to the site via the two adjacent lanes, Coneyburrow Lane and Sandhurst Lane, will not be permitted (other than any necessary emergency access) due to the narrow and winding nature of the lanes. However active travel linkages and improvements will be required. Detailed transport assessment at planning application stage will be required to determine the requirement for improvements and interventions on the A259, to be assessed by National Highways. This includes policy compliance regarding new accesses onto the Strategic Road Network as contained with DfT Circular 01/2022, in particular paragraphs 18 to 25. In addition, compliance will be required in line with the Design Manual for Roads and Bridges and a Stage 1 Road Safety Audit (RSA) and a Walking, Cycling and Horse-riding Assessment and Review (WCHAR) will need to be evidenced.

Mix of Uses

10.177 A mix of uses will be required within the site to provide for services and facilities in walking distance of new dwellings. This will include a primary school when required, but in the shorter term, small-scale class E units, to accommodate, for example, a local shop and/ or small-scale workshops or light industrial uses, and community uses, including open space and potentially, formal outdoor sports provision.

Policy BX25: Land at Northeye and adjoining land Comment

10.178The site comprises three separate land parcels. The largest parcel is brownfield, originally developed in the 1940s as a RAF base and later used as a prison and training centre, although it has been vacant for some years. Two adjoining parcels, comprising agricultural fields in separate ownership, are also available. Together, the three parcels provide an opportunity for a substantial residential development on the edge of Bexhill, to form part of a Live Well Locally sustainable community.

10.179The site measures some 19.2 hectares and has an indicative developable area of 9.5 hectares. It is allocated for some 364 dwellings at an indicative residential density of 40 dwellings per hectare.

10.180 The largest portion of the site was allocated for 140 dwellings and a full-sized adult football pitch and/ or a senior cricket pitch, with associated ancillary changing and parking facilities to serve the playing pitch, through the previous Local Plan. It was anticipated that the sports pitch would be provided on the level, northern section of the Northeye site. However, the current landowner (Homes England) has indicated that in order to make residential redevelopment of the site viable, additional housing will be required (above the 140 previously anticipated) and it will not be possible to accommodate a sports pitch.

10.181It is appreciated that the redevelopment of this likely contaminated, brownfield site will be costly. However, there remains a need for additional outdoor sports provision including formal playing pitches in Bexhill, as identified in the Rother and Hastings Playing Pitch and Built Facilities Strategy (2023), to meet the needs of new and existing residents. Identifying an alternative site for a sports pitch in the west Bexhill area is not straightforward, given the undulating topography of much of the area, the landscape and ecological sensitivities of the Pevensey Levels, and limitations to available land. The level topography of part of the Northeye site means that it likely remains the most suitable site. The Council will continue to work with the landowner to seek to secure both the delivery of housing at this site but also, ideally, the provision of a pitch and associated facilities. The addition of the two additional land parcels does provide an opportunity for additional dwellings, public open space and other community facilities within the wider site.

10.182The site, particularly the largest portion, is environmentally sensitive, containing Priority Habitat (Coastal and floodplain grazing marsh) in its north-western section, a habitat which links to the protected Pevensey Levels further west, and this section also lies within Flood Zone 3. This is also identified as an Area that Could be of Importance to Biodiversity (ACIB) in the Local Nature Recovery Strategy. Development will need to be informed by ecological surveys and include mitigation and enhancement measures, taking into account the Priorities and Measures of the LNRS.

10.183The site is undulating, including the two smaller land parcels, and sites on the edge of the marsh, with long views afforded north and westwards across the countryside. Development will need to be carefully designed to conserve Priority Habitats and avoid areas at risk of flooding but also to ensure an appropriate extension to the built form of Bexhill can be achieved without harming the intrinsic character and beauty of the countryside beyond. Trees and areas of scrub within the site and on the site boundaries should be retained, and development should be of high quality and landscape led.

10.184Public Footpath 59a which passes along the northern edge of the site could potentially be permanently diverted to its historic south-easterly alignment, through the site to a more southerly point along Coneyburrow Lane, as indicated on historic maps from the late 19^th century, as part of the development.

10.185The whole site lies within the Pevensey Levels Hydrological Catchment Area and the policy requirements reflect this. Early engagement with the Lead Local Flood Authority and the Pevensey and Cuckmere Water Level Management Board will be needed to ensure the provision of appropriate Sustainable Drainage (SuDS) in accordance with Policy ENV3. This site also lies adjacent to a Main River (GB107041012430 - East Stream) and flood defences. Development will need to incorporate recommendations from the Level 2 Strategic Flood Risk Assessment, as follows:

• Demonstrate through a site-specific FRA that the proposed development will be safe for its lifetime, taking account of the vulnerability of its users.
• Blockage modelling should be conducted as part of an FRA to assess the residual risk associated with potential blockage of the road bridge within the site.
• A sequential approach should be undertaken, by locating the most vulnerable aspects of development in areas of lowest flood risk.
• Utilise SuDS with multiple benefits throughout the site, particularly in areas of predicted surface water risk.
• Detailed modelling of the ordinary watercourse which flows through the centre of the site should be undertaken.
• A buffer distance from the Main River and Ordinary Watercourse (at least 8m) will need to be maintained to allow access and maintenance.

10.186The southern part of the site is within an Archaeological Notification Area and a Heritage Assessment will be required in accordance with Policy HER1.

10.187Like for other sites in this area, detailed transport assessment will be required to determine the extent of impacts on the A259 trunk road/Strategic Road Network (SRN) and the requirement for improvements and interventions. There will be a need to comply with any requirements from National Highways, in addition to any from the Local Highway Authority. Any proposed upgrade/improvement of an existing SRN access will need to be fully assessed by National Highways in line with the relevant guidance set out in DfT Circular 01/2022 and the Design Manual for Roads and Bridges (DMRB).

10.188A mix of uses will be required within the site and the wider West Bexhill area, to provide for services and facilities in walking distance of new dwellings. Improvements to the existing public rights of way network as well as new pedestrian and cycle paths through the site and linking it to the district centre at Little Common will also be required, along with any necessary improvements to public transport provision and infrastructure.