We do not agree with the preferred sites for housing within the Hastings Fringes, we consider that Land at Breadsell Lane (Ref: HF5) should be included as a preferred option within the Rother District Council Development and Site Allocations Local Plan for the potential delivery for up to 150 dwellings. It is noted that the site was considered and rejected by the Hastings Local Plan Inspector, however we consider that the reasons for doing so can be overcome in relation to this site, which lies adjacent to Hastings. The inclusion of this site would make a significant contribution to meeting housing requirements within Rother during the current plan period. The issues raised for not including Land at Breadsell Lane as a preferred site are discussed in turn below.

Marline Valley Wood SSSI
This matter is discussed in detail within the Environmental Report appended to this submission. The conclusions to this report are set out by Pages 5-6, Paragraph 6.01 - 6.10.
In summary, the report indicates (see Paragraph 1.05 and 1.06) that the site makes up only a small part (2.4%) of the catchment area which drains to the Marline Valley Woods SSSI. As the site makes up such a small part of the catchment area its development would not have a significant impact on the level of
water draining to the SSSI. In conclusion, it states that the use of sustainable drainage methods will ensure that the level of run off will remain as the existing green field position and could in fact seek to increase the level of run off. The level of run off to the Marline Valley Woods SSSI would therefore be maintained at least at current levels and could be improved (see Paragraph 6.10).

In view of this report it can be held that land at Breadsell Lane could be delivered in a way which would protect the SSSI. The drainage techniques suggested are well understood and could be implemented as part of a scheme for housing. As such we do not view this as an issue that would impact on the deliverability of the site. It is also worth noting that although Natural England object to the site within Hastings they have not made any submissions to this effect in relation to the Rother Core Strategy, or in relation to this smaller part of the site.

Transport
This matter is discussed in detail within the Highway Note provided by Motion and appended to this submission. The summary and conclusions are provided on Page 5 Paragraphs 5.1 & 5.2.

The Transport Note finds (at Paragraph 2.1) that there are a number of options and opportunities to provide a suitable highway access to the site that would be achievable and deliverable. The Note concludes (at Paragraph 3.8) that site access would not be restricted by highway capacity constraints that result in prolonged periods of congestion. It can be concluded that a suitable access could be provided to the site and there would be no access issues which would restrict development of the site within the Plan period. As such there would be no highway reasons for not including Land at Breadsell Lane as a preferred site.

Land at Breadsell Lane lies just to the west of the built up area of Hastings and can be accessed directly from Hastings Road. The Transport Note identifies (at Paragraph 4.6) that a good bus service operates within walking distance from the site offering services to Battle and Crowhurst railway stations, as well as to the town centres of Battle and Hastings. The site is also within cycling distance to areas of employment.

The development of additional housing in this area could support existing and additional shops and services. The site is therefore considered to be accessible by a choice of transport modes, consequently sustainability issues are no considered sufficient to warrant not including land at Breadsell Lane as a preferred housing site.
The Note concludes that the development of the site for housing would be acceptable from a highway and transport perspective.

Landscape
This matter is discussed in detail within the Visual Impact Assessment prepared by Nick Harper and appended to this submission. A summary of the potential impacts is provided on pages 32 - 46 and a table of the findings is included on Page 47. The summary and conclusions are provided at Page 51 Paragraph 7.2.
Section 3 of the LVIA discussed the site character. At Paragraph 3.31 it confirms that the site is relatively well contained with limited views offered to the site from the surrounding area. It does however note that there are some longer distance views from Breadsell Lane approximately 200m to the south of the site.
The development of the site for housing has been considered to have a major adverse impact to 1 of the 11 viewpoints (Breadsell Lane) identified by the LVIA and a moderate adverse impact to 3 of the view points. A plan of the viewpoints is included on Page 25 of the LVIA. The most significant impact is to views from directly adjacent to the site and from a public footpath to the south (Viewpoints 1, 2, 3 and 5). In order to mitigate the impact on these views additional landscape screening would be required. Upon implementation of appropriate mitigation measures the LVIA site concludes that the site would be suitable for residential development (Paragraph 7.2).

It should be noted that Land at Breadsell Lane lies within a small area of the District that is not constrained by the AONB or by other locally or nationally recognised designations. The proposal for developing this site would be considerably less harmful than many other locations within Rother. Given the constrained nature of the District identifying sites that would be suitable to make provision for housing with no significant impacts on the scenic quality of the District are limited. The submitted LVIA indicates that any impacts in this case are limited to the near views to the site and can be successfully mitigated. In our view landscape impacts would not act as a constraint in relation to development of the site within the plan period.

Conclusion
Having considered the issues raised, we disagree with the decision not to include Land at Breadsell Lane as a preferred housing site, and consider that it should be included to provide housing within the plan period. It would provide medium term flexibility within the Plan to provide for the housing needs of the District. The site is controlled under one landowner and consequently there are no landownership issues
in terms of delivery. It is our view that the issues raised would not preclude development of the site for housing and that a suitable scheme for housing could be developed over the plan period helping to achieve a significant contribution towards Rother District Council's housing needs.

Additional supporting information was submitted with this representation and can be viewed at the following links:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28106
http://www.rother.gov.uk/CHttpHandler.ashx?id=28105
http://www.rother.gov.uk/CHttpHandler.ashx?id=28104