1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194