The Policy as drafted misses a key planning opportunity to provide for an integrated new allocation for housing, employment, community facilities and infrastructure at the NW Hastings fringe on land south of Battle Road (Breadsell Lane) as part of a joint strategic allocation with Hastings Borough Council. The proposed provision in HF1 (vi) is not location specific.

The Policy when considered in the context of OSS1 will result in an under-supply of allocated housing land in the District over the Core Strategy period and has too much reliance on the delivery of the Bexhill-Hastings bypass which was exactly the same position facing the District Council during their Local Plan process. Historically through its Local Plan process, the District Council has relied on the Bexhill location to deliver the core part of its housing and employment land. The policy has not delivered in this area and yet remains a cornerstone of the Core Strategy.

Because of the historic weakness of this strategic approach, it is considered that strength can be added to the Core Strategy by introducing a second strategic growth location at the NW Hastings fringe ie land south of Battle Road (Breadsell Lane). This approach will meet the Council's objectives on Policy OSS4 and will provide development in a location where new initiatives are particularly needed between the District Council and Hastings Borough Council.

The spatial distribution policy does not appear to meet the need for providing a 5 year land supply + 20% as defined in the emerging NPPF and as it stands, the policy does not meet regional guidance and is unsound on that basis.

The spatial policy places too much emphasis on the 'traditional' centres for development where there are long-standing development constraints.

Whilst not entirely ruled out, the Core Strategy has not taken the clear opportunity to support a strategic allocation on the north-western side of Hastings. Although Hastings Borough Council favoured this strategic approach in its earlier Core Strategy, they have not pursued this in their submission CS. The constraints raised against this can be mitigated and therefore it is considered that the District Council have been too readily dismissive of this clear opportunity.

The Core Strategy spatial strategy policy should include a strategic housing allocation on land at Breadsell Lane certainly encompassing the northern part of that area of land. The approach should be carried out in conjunction with Hastings Borough Council because of the mutual authority interests by way of an area action plan. Such an approach would be likely to ensure the provision of sustainable and properly planned short, medium and long development including homes, jobs, community provision and infrastructure in a location that has a strong need for improvement in these areas. A positive allocation on this basis will add further weight to support the need for the Bexhill-Hastings bypass to be delivered.

The effectiveness of the Core Strategy's strategic allocations policies would be increased if supported by the added weight of a strategic land allocation for housing, employment and community facilities on land south of Battle Road (Breadsell Lane) at the NW Hastings fringe in association with Hastings Borough Council allowing greater certainty for the early provision of the bypass project and a potentially important source of funding for that project.