The purpose of Strategic Gaps is to maintain the separate identity and distinctiveness between settlements, maintain the strategic settlement pattern and prevent coalescence.

The existing Strategic Gap (shown in Appendix 1 attached to the submission email) already provides a suitable and defensible countryside gap between the settlements of Hastings and Fairlight. The Gap comprises primarily open agricultural fields and isolated dwellings that are already protected by general policies of countryside restraint, both at the national and local levels.

The proposed Strategic Gap extension (proposed under draft Policy DEN3 in Appendix 2 attached to the submission email), proposes to include existing built development along the western side of Coastguard Lane, the southern side of Hill Road, the southern side of Battery Hill and the northern most section of Warren Road.

No evidence has been produced by the Council to demonstrate that;

i) The area within the existing Strategic Gap has been under pressure for development since it was designated;
ii) That the proposed extension is reasonably necessary due to existing development pressures or serves any sound planning purpose, given the protection afforded by the existing Gap Policy combined with restrictive countryside policies;
iii) It is logical or sound to extend the existing Gap to the north up to Fairlight Road (when Hastings is located to the west), given that it is proposed to exclude the residential cul-de-sac development at 'The Close' to the west

Although paragraph 6.21 of the draft Submission Plan mentioned that The Close is considered to be vulnerable to incremental change and in-fill development, it is shown excluded on Figure 7 on page 79. The dwellings surrounding 'The Close' are of a similar density to those along the western side of Coastguard Lane, the southern side of Hill Road and the southern side of Battery Hill at its junction with Warren Road.

In addition, while householder permitted development rights would not be affected by the Strategic Gap Policy, the draft Policy should make Council's position clear about its position in relation to householder development (such as extensions and garden buildings) that needs planning permission and schemes to replace existing dwellings. This might be covered by a policy commitment to provide a Supplementary Planning Document to explain the type and scale of development that would and would not be permitted in this respect. To permit such development only in "exceptional circumstances" where this does not "detract from the openness of the area" is akin to introducing a new Green Belt type policy which is unreasonable and unjustified at this location.

This proposed Policy change cannot therefore, be considered to be positively prepared, justified or effective and should be deleted.

Fairlight and Hastings

10.24. The Gap between the Hastings Borough boundary and the edge of Fairlight Cove provides an important function in protecting the general openness of the area between the Hastings Country Park and the edge of the settlements of Fairlight and Fairlight Cove. While the 2006 Local Plan excluded developed land in this area, it is vulnerable to incremental change and infill development. It is recommended that these areas are included in the gap to conserve the open character of the gap between Fairlight and Fairlight Cove.

Rye and Rye Harbour

10.25. The Gap between Rye citadel and Harbour Road industrial area and Rye Harbour village does provides an important function in retaining the separate and distinct identity of the two settlements. The area is fragile and vulnerable to encroaching development and incremental changes in landscape management. The retention and protection of this Gap area is important to the conservation and enhancement of local landscape character and views especially with regard to the setting of the Citadel. A small extension to the Gap to also incorporate the sensitive riverside margin is recommended, as this is contiguous with and inseparable from the Gap landscape.

Conclusions

10.26. It is proposed that the Strategic Gaps be refined as recommended by the recent Strategic Gaps Landscape Assessment for the reasons set out above. This
is supported by the Sustainability Appraisal, which found that, generally, the
recommended boundaries somewhat better meet environmental objectives. In respect of the Hastings-Battle Strategic Gap, the revision is seen as more appropriate in terms of the specific function of the Gaps, as set out in the Core Strategy.

Following maps attached
Fairlight Map 1 (www.rother.gov.uk/CHttpHandler.ashx?id=31259)
Figure 6: Strategic Gasp at Bexhill (www.rother.gov.uk/CHttpHandler.ashx?id=31260)
Figure 7: Strategic Gap at Fairlight (www.rother.gov.uk/CHttpHandler.ashx?id=31261)
Figure 8: Strategic Gap at Rye (www.rother.gov.uk/CHttpHandler.ashx?id=31262)



Strategic Gaps

6.14 Strategic Gaps are regarded to be of strategic importance in terms of guiding the location of development. The particular objectives of the Gaps are:
* To maintain the separate identity and distinctiveness between settlements.
* To maintain the strategic settlement pattern.
* To prevent the coalescence of settlements.

6.15 Their protection through local plans is an established policy tool. Development within these Gaps has been strictly limited to maintain their openness, although does allow for agricultural buildings, conversions and the replacement of an existing building.

6.16 The principle of these Strategic Gaps has been carried forward in the Council's
adopted Local Plan Core Strategy (2014) where policies HF1 and RY1 highlight the
need to maintain the Gaps between:

* Bexhill and Hastings/St Leonards
* Crowhurst and Hastings/St Leonards
* Battle and Hastings/St Leonards
* Fairlight and Hastings/St Leonards
* Rye and Rye Harbour

6.17 The Council has undertaken a full assessment of the extent of the five identified
Gaps, as set out in the Strategic Gaps Landscape Assessment, March 2016, which
is published as a Background Paper. The Gaps between Bexhill and Hastings/St
Leonards, Crowhurst and Hastings/St Leonards and Battle and Hastings/St Leonards,
although defined separately in Policy DEN3, effectively form one contiguous Gap on
the Policies Map. The extent of each Gap is summarised below.

Bexhill and Hastings/St Leonards

6.18 The Gap between the two towns is relatively small, being particularly narrow along the A259 corridor, and hence highly vulnerable to development pressure. The perception of the Gap between Bexhill and Hastings has been subject to considerable change recently with the construction of Combe Valley Way, which opens up the countryside between Bexhill and Hastings/St Leonards. The Gap encompasses the Combe Haven valley and its tributary valleys in order to protect this open landscape between the two settlements.

Crowhurst and Hastings/St Leonards

6.19 The construction of Combe Valley Way has increased the vulnerable area of the Gap between Hastings/St Leonards and the village of Crowhurst, while the area between the built up edge of Crowhurst and the Hastings to London railway line is also included as it contributes to the open area between the settlements.

Battle and Hastings/St Leonards

6.20 The Gap between Battle and Hastings/St Leonards provide an important function in maintaining the separate identities of Battle and the built up area of Hastings/St Leonards. The break in the ribbon development between the edge of Telham and the Hastings Borough boundary at Breadsell Farm is highly sensitive to change particularly in more open areas and the higher ground and ridges.

Fairlight and Hastings

6.21 The Gap between the Hastings Borough boundary and the edge of Fairlight Cove provides an important function in protecting the general openness of the area between the Hastings Country Park and the edge of the settlements of Fairlight and Fairlight Cove. The area south of Battery Hill and Hill Road and to the east of Coastguard Lane, including The Close, is vulnerable to incremental change and infill development; hence, it is also included to conserve the area's open character.

Rye and Rye Harbour

6.22 The open Gap between Rye citadel and Harbour Road industrial area/Rye Harbour village provides an important function in retaining their distinct identities. The area is fragile and vulnerable to encroaching development, as well as incremental changes in landscape management. The retention and protection of this Gap is important to the conservation and enhancement of local landscape character and views, notably with regard to the setting of the Citadel. The Gap also incorporates the sensitive riverside margin adjacent tot he River Brede and River Rother.

Policy DEN3: Strategic Gaps

The Strategic Gaps are identified on the Policies Map between the following areas:

(i) Bexhill and Hastings/St Leonards
(ii) Crowhurst and Hastings/St Leonards
(iii) Battle and Hastings/St Leonards
(iv) Fairlight and Hastings/St Leonards
(v) Rye and Rye Harbour

Within these Gaps, development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive and not detract from the openness of the area.

Enhancement of the Gaps through effective landscape management which
strengthens and reinforces their significance as protected landscape areas will be supported.