Site BEX3c is allocated for development in the proposed submission version of the DaSA. As detailed in section 3, the Site constitutes an area of 8.8ha to the north of the settlement of Bexhill, south of the recently constructed NBAR, and has been identified as a draft allocation in the Regulation 19 Proposed Submission Consultation of the DaSA. The allocation of the Site under Policy BEX3c: Land east of Watermill Lane sets out that the site is allocated for housing ("some 150 dwellings") and open space.

The allocation of this site is supported. The site is located in a sustainable and accessible location, with a direct relationship with the existing residential development of Bexhill and the wider north east Bexhill strategic growth area. The existing topography presents a site that is enclosed by natural landscape features and one that would not negatively impact upon the wider countryside.

There are, however, two technical amendments that we wish to see:

1) Removal of gypsy/traveller section on draft allocation site BEX3c

The allocation of Site BEX3c includes the provision of up to five gypsy and traveller site pitches for permanent residential use by gypsies. This aspect of the allocation is sought to be removed for three primary reasons:
i. the proposed gypsy and traveller pitches are not distributed evenly across all proposed allocations;
ii. there is insufficient evidence indicating that any Gypsy and Traveller pitches are necessary;
iii. The site of the allocation is the same as the location of an area of mitigation/compensation approved as part of the NBAR planning application.

The inclusion of all Gypsy and traveller sites on one prospective allocation site is an unbalanced approach that will not allow for integration, creating a clustering effect that would be detrimental to both the travelling community and local residents. If they are proven to be needed, the provision of a number of smaller sites across various site allocations set out in the DaSA would allow for a better approach to integration with the local community and allow an even distribution of traveller pitches, ensuring that not only were all sites close to amenities, but no amenity provider was overburdened.

The allocation of Gypsy and Traveller pitches on site BEX3c would be fundamentally unsound as the proposed allocation of part of the site for such pitches has not been based upon any recent evidence that details specific Gypsy and Traveller need. The evidence that has been submitted in association with the DaSA dates from 2011 and refers to Planning Policy Statements and Planning Circulars - both of which pre-date the current National Planning Policy Framework and are therefore out-of-date. As a clearly outdated piece of evidence, it cannot be relied upon to be indicative of any current or future need.

The construction of the NBAR was approved under application RR/2015/2260/P. As part of the application an Ecological Design Strategy showing a landscape and ecological mitigation plan was required as part of the pre-commencement conditions. This was submitted and approved. As part of this, Drawing (08)011 Rev.B Landscape Masterplan - E3 Specification for mitigation/compensation (Figure B.2.1) clearly shows the location of Native Broadleaved Wet Woodland Planting on the area that has been identified for the Gypsy and Traveller pitches. Therefore allocation of this site for development of Gypsy and Traveller pitches would be in direct conflict with the approved Ecological Design Strategy & Biodiversity Monitoring Strategy (March 2017) submitted and approved under application 2015/2260/P for the NBAR.

2) Allocation of land to the north of the North Bexhill Access Road (NBAR)

In the representation made to the regulation 18 DaSA, land to the north of the NBAR was highlighted as being suitable for inclusion as a site allocation, however it has been overlooked in the Proposed Submission version of the DaSA. Given the additional need for housing allocations in the DaSA, as identified and set out in the first part of this section, and the sites availability within the first five years of the plan period, it would be erroneous to not include land to the north of the NBAR as a further site allocation in the DaSA.

As set out in section 3, the site consists of approximately 4.6ha, is bounded to the north and east by ancient woodland, to the south by the NBAR, and is in flood zone 1. The proposed masterplan for the site includes development of housing and the development of community sports facilities. This would entail the development of approximately 25 units on the eastern portion of the site, with a cricket pitch and associated pavilion on the western part of the site.

The need for a ground for the cricket club has been identified in the DaSA, in particular in paragraph 9.13, where the specific needs of Sidley Cricket Club are identified. The supporting Sidley Sports Ground Feasibility Study, that has been prepared as part of the evidence base for the DaSA, identifies that the Sidley sports ground has been closed and a number of sports teams have been forced to relocate outside of the District on order to continue operating. Redevelopment options for the sports ground have concluded that an artificial turf football facility would be the most beneficial development on the site. However, this results in the playing surface being unsuitable for cricket, and there remaining a need for a cricket ground. The allocation of the land to the north of the NBAR would enable this community facility to be accommodated and the retention of Sidley Cricket club in the local area. If the site were to be allocated and the residential development of 25 units on the northern part of the site to go ahead, it would enable the cricket ground to be gifted to the community and enhance the recreation facilities available to the local population.

The erection of the cricket ground on the west of the site and the modest element of housing on the east would enable the open nature of the west part of the site to be maintained, whilst making best use of the available land resource to the east which is more naturally screened from wider views and therefore readily able to contribute towards the much needed housing supply.

Whilst the newly constructed North Bexhill Access Road has been identified in the DaSA paragraph 9.17 as "a clear edge between the urban area and the countryside to the north", it is a man-made boundary. The stronger, more defensible natural boundary that exists to the north of the road - the area of ancient woodland - which would provide a more robust and natural feature and would provide a natural limit for the settlement boundary. In the Core Strategy (2006), it is set out in paragraph 10.19 that "development to the north and north east of Bexhill should plan for the creation of a robust, long-term urban edge, with development contained from the wider countryside setting by well-defined topographical and landscape features."

Accordingly it would be in keeping with existing approaches and a far more logical step to include the site as part of the allocations of the DaSA through extending the settlement boundary to the edge of the woodland area, utilising a natural landscape feature of ancient woodland to set a firm, defensible boundary.

Additionally, the road need not be seen solely as a boundary and a limiting factor in development to the north, as it could readily operate as a spine road providing access to both its northern and southern sides without impacting upon the traffic flows through the area. A Highways Access report has been prepared by GTA Civils (August 2018) that has examined the capacity of the road and its ability to effectively service development to the north of the road. The road has been designed and built to be 'future proof', and is capable of a far higher vehicular capacity than is currently being proposed/operated. This has been reinforced in the Highways Access report, which has found that trip generations from the proposed development would have no material impact on the operation of the highway network.

The Highways Capacity Assessment Report that has been produced as part of the evidence base of the DaSA has identified that scope to increase road capacity within Bexhill is limited, and therefore further development within the existing urban area, through densification or other means, will lead to additional pressure on the road networks. Development on a well screened area that is in a sustainable location with good access to public transport networks would therefore make best use of existing land and help to accommodate an identified and much needed community facility.

It has already been highlighted as being available and developable within the first five years of the Plan period, and would utilise the newly constructed the NBAR as its means of access.

A precedent for development to the north of the NBAR has already been set, as Outline Application RR/2017/2181/P for uses B1 and B2 includes development to the north of the NBAR close to the junction of Combe Valley Way in a well screened location. The allocation of land to the north of the NBAR as detailed in these representations would also be in a well screened location with a strong natural boundary.

The Bexhill development boundary does not go far enough. It does not include the land to the north of the NBAR which was submitted to the Local Plan and representations made in support of at the regulation 18 round of consultation.

Accordingly the proposed Bexhill settlement boundary should be revised to include the land to the north of the NBAR. This amendment would enable the provision of an additional 25 dwellings that will further ensure that the plan is robust against any increase in housebuilding and enable the provision of a new cricket pitch for Sidley Cricket Club.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172