Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24335

Received: 07/12/2018

Respondent: SeaChange Sussex

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Elements of this policy are unsound as they seek to impose restrictions beyond those already determined at an outline planning permission stage and place unrealistic obligations on the developer.

We suggest the removal of all obligations to work with Southern Water to deliver sewerage infrastructure to the site prior to occupation.

This policy would also unfairly advantage Southern Water over providers of alternative sewerage infrastructure provision options. There is no planning justification requiring developers to rely on this provider.

We do not consider the policy wording reflective of the planning permission (ref:RR/2017/2181/P).

The main issues are:
1. The increase in landscape buffers and exclusion of parts of the consented outline permission from
the allocation, including the exclusion of the parts of the permission to the north of NEAR, resulting in a
reduction in the area allocated for employment.

2. The policy states that development will be predominately falling within Class B1, this contrasts with the permission which includes B2 uses.

3. The policy states that existing landscape boundaries should be retained and reinforced, including along NBAR, we object to this as it is not consistent with the outline permission and would lead to further reductions in the business space available.

Full text:

Elements of this policy are considered to be unsound as they seek to impose restrictions beyond those already determined at an outline planning permission stage and place unrealistic obligations on the objector as the developer of the site.
We would suggest the removal of all obligations to work specifically with Southern Water to deliver sewerage infrastructure to the site prior to occupation, as requiring the delivery of infrastructure through an organisation that have proven to be slow and reluctant to positively engage in the delivery of infrastructure would unduly slow
the delivery of development. This policy would also unfairly advantage Southern Water over providers of alternative sewerage infrastructure provision options such as on-site treatment plants, or the use of inset providers to deliver development on a more viable timescale. We consider there to be no planning justification for
requiring developers to rely on this provider who has failed to deliver infrastructure prior to occupation of developments.
We do not consider the policies current wording to be reflective of our current planning permission (ref:RR/2017/2181/P) for the land contained within the allocation. We consider it to be unjustified and inconsistent with national planning policy for the local planning authority to adopt planning policy inconsistent with existing planning consents. We consider the main issues with the present wording to be;
1. The increase in landscape buffers and exclusion of parts of the consented outline planning permission from
the BEX1 allocation, in particular the exclusion of the parts of the permission to the north of NEAR, resulting in a
reduction in the area allocated for employment uses within the plan. We consider this approach fundamentally
unsound as noted in paragraph 9.8 of the proposed DaSA submission. Significant progress in bringing forward
business land has been made since the construction of the link road and we cannot see any justification for
reducing the size of employment land allocations which benefit from the £130m link road investment.
2. The policy states that development will be predominately light manufacturing and offices, falling within Class B1, this contrasts with the planning permission with was granted to include B2 manufacturing uses, which has also been considered an appropriate use for the site subject to suitable screening in local planning policy dating back to 2006, including the North East Bexhill Supplementary Planning Document 2009. We suggest that the allocation is amended to incorporate B2 manufacturing uses to reflect the existing consent as the changes do not appear to be justified. It should be noted that this is one of the few B" manufacturing Locations within the entire Rother District.
3. We also note that the policy states that existing landscape boundaries should be retained and reinforced, including along the boundary with NBAR, as indicated on the Detail Map, we object to this policy amendment as it is not consistent with the outline planning permission and would lead to further reductions in the already finite
levels of business space available, despite a proposed increase in overall settlement size through additional housing allocations.
As such we would suggest that the allocation policy is amended to fully reflect the existing planning permissions and that additional employment land is allocated to meet the employment needs of residents living in the proposed additional housing therefore delivering, a more balanced mixture of development within the urban
extension.