Object
Proposed Submission Development and Site Allocations (DaSA) Local Plan
Representation ID: 24300
Received: 07/12/2018
Respondent: Miss Elizabeth Parker
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
No map of the Battle to Hastings strategic gap is shown but it appears from the text that the gap between Battle and Telham has been deleted and the gap between Telham and Hastings retained.
There is no justification for the deletion.
The supporting text to the Rother DC strategic gap policy paragraph 6.14ff accords with NPPF green belt policy para 133-134.
The strategic gap between the two settlements has been identified to be at risk, justifying a strategic gap designation. The NPPF policy states that once established no alterations to green belt designations should occur except where exceptional circumstances exist due to their intended permanence in the long term.
In this location, the deleted part of the strategic gap is important to the setting of a historic location, Battle, Battle Abbey and the Battlefield.
The land is designated an AONB however this designation is not a new circumstance and green belt designations overlap with landscape designations in many areas nationally. The designation as an AONB does not justify deletion as a strategic gap: it is not a new or exceptional circumstance.
No alteration of the boundary is justified. No exceptional circumstances have been identified, fully evidenced or justified.
Objection to deletion of one half of Battle/Hastings strategic gap
No map of the Battle to Hastings strategic gap is shown but it appears from the text that the gap between Battle and Telham has been deleted and the gap between Telham and Hastings retained.
There is no justification for the deletion of one half of the established strategic gap between Battle and Forewood Lane/ Telham.
The relevant national policy for strategic gaps is NPPF chapter 13 "Protecting Green Belt land". The supporting text to the Rother DC strategic gap policy paragraph 6.14ff accords with NPPF green belt policy para 133-134.
The strategic gap between the two settlements has been identified to be at risk, justifying a strategic gap designation. The NPPF policy clearly states that once established no alterations to green belt designations should occur except where exceptional circumstances exist due to their intended permanence in the long term.
In this location, the deleted part of the strategic gap is important to the setting of a historic location, Battle, Battle Abbey and the Battlefield.
The land is designated an Area of Outstanding Natural Beauty however this designation is not a new circumstance and green belt designations overlap with landscape designations in many areas nationally. The designation as an AONB does not justify deletion as a strategic gap: it is not a new or exceptional circumstance.
No alteration of the boundary is justified. No exceptional circumstances have been identified, fully evidenced or justified. The proposed deletion conflicts with paragraphs 136 and 137 of the NPPF which state:
"Once established Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of updating of plans." [para 136]
"Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period" [para 136].
"Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate it has examined fully all other reasonable options" [para 137].
In summary, the deletion of one half of the Battle/Hastings strategic gap is unsound and contrary to national policy.