Whilst it is understood that the Council would wish to make appropriate provision for employment-generating development, it needs to ensure that the right sites, in the right location are identified. It should not simply retain former employment premises on the assumption that they are now in the right location to meet modern day requirements. Indeed, the government has published consultation documents on this matter. Moreover, the draft National Planning Policy Framework also requests councils to take a fresh look at such matters.

Objection is therefore made to the way in which this policy is both worded and applied to certain sites, particularly the land on the eastern side of Winchester Road, Rye. If land is not being used as hoped by the Council, then it should surely consider whether a change of policy is appropriate. To simply retain land for uses such as car parking and car washing, when housing and mixed uses are needed is inappropriate. Whilst it is acknowledged that the policy does contain an element of flexibility, in parts (i) and (iv), these can cause substantial delay in the re-development of land. In particular, councils often require landowners or developers to try to prove that there is little or no demand for their premises. This can result in added cost and avoidable delay, whilst marketing exercises are undertaken.

The Council should, from its own records, knowledge and contact with developers and agents, know what land is required for certain uses- and where these should be. To impose further delay is therefore unjustifiable. Furthermore, the wording of the policy is such that it indicates that the Council has limited knowledge of viability and development economics. For example, if a scheme is not viable, then suggesting that priority be given to affordable housing in preference to market housing is nonsensical. Market housing is likely to generate much more development value and it should not, therefore, be relegated to the bottom of the list of acceptable alternative uses. The effect of such a policy is already clearly demonstrated by sites such as that at Winchelsea Road remaining in an under-used state.