• We object because the Core-Strategy fails fully to take account of the obligations and requirements imposed by draft PPS4. Whilst Para 5.1 of the consultation paper recognises the need for the overall spatial strategy to carry forward the National and Regional policies, it fails to take mention or take account of PPS4 as important and relevant emerging National policy. As a result, we believe that the objectives fail to fully recognise the importance of providing a welcoming approach to opportunities for the tourism and leisure business to expand and improve within the District as a whole and in Camber in particular.

• In particular, the aspirations and needs of tourists are undergoing a significant change both within the UK and internationally. This is a trend now accentuated by the worsening economic background, where visitors expect a broader and higher quality experience. Similarly, leisure habits of the population are changing. Policies being formulated today cannot adequately anticipate how these changes will manifest themselves.

• It is essential therefore that policy to cover the next fifteen years allows flexibility to accommodate unforeseen needs without stifling the economic engine that tourism and leisure has become. This is equally relevant to established and emerging rural and coastal tourism and leisure facilities as it is for the tourism sector within the urban areas of the District.

• Again, draft PPS4 makes clear the Government's new and high priority objectives towards fostering economic growth. In her Introduction, The Minister says...

"As a result of this new policy, regional and local planning bodies will support economic development by ensuring that they understand and take into account what their economies need to remain competitive, and responsive (my underlining) to the needs of business, and factor in the benefits of economic development alongside environmental and social factors."

• In this statement, Government clearly recognises the need for flexibility of approach with policy-making at a local level. As worded, there are a number of Policy Directions and references within the background papers which would inhibit a "responsive" approach, if adopted.

• And in paragraph 24 of PPS4:

"Due to the increasing demands on the land available for development, local planning authorities should seek to make the most efficient and effective use of land and buildings, especially vacant or derelict buildings (including historic buildings).

• And in paragraph 25:

"Encourage new uses for vacant or derelict buildings, including historic buildings and buildings in rural areas, as this can contribute positively to an area's regeneration, provide wider economic benefits, help to preserve historic assets and also reduce the need for Greenfield development"


• The PPS continues:

"....local planning authorities should use a wide evidence base to understand both existing business needs and likely changes in the market, to prepare policies to support sustainable economic development in their area"....

18. To achieve this, regional planning bodies and local planning authorities (my underlining) should:
• Ensure that the strategy addresses the particular needs of rural areas in terms of new economic opportunities,
• Take account of the different locational requirements of businesses, such as the size of site required, site quality, access and proximity to markets, as well as the locally available workforce;
• Take account of relevant market information -- and economic data, including price signals;
• Ensure the plan supports existing sectors, taking into consideration whether they are expanding or contracting;
• Where possible identify and plan for new or emerging sectors likely to locate in the region/sub-region/local area or which the regional planning body or local planning authority wish to attract to the region or area, but maintain flexibility to accommodate sectors not anticipated in the plan;
• Recognise, and positively plan for, the benefits that can accrue when certain types of businesses locate within proximity of each other or with other compatible land uses ...."

• Paragraph 5.4 of the CS states that the aims and objectives "highlight the main priorities in determining the pattern of activity and development across Rother District. They reflect both the strategic need for economic regeneration and growth of the coastal towns, especially for Bexhill (and Hastings), and the environmental sensitivities in meeting economic objectives and other community needs in Battle, Rye and the smaller settlements, and in the countryside";

• However, we cannot see that this has been taken into account when preparing the overall spatial strategy aims and objectives, since none of the listed objectives refer to 'supporting existing sectors' ; 'identifying emerging sectors'; 'maintaining flexibility'; or 'positively planning for businesses (locating together)' ; etc.

• In this context we object to objective (iii) - because it fails to recognise and plan for the likely benefits of encouraging positive change through re-development and expansion.

• We object to objective (vi) - because tourism and leisure needs are much more than 'local' and visitors need to be encouraged to support economic growth and opportunity for all.