Appendix 4 of the Sustainability Appraisal sets out the assessment of the site allocation options, the sections below review the SA of the North Bexhill site.

In the sustainability appraisal, land to the north of Bexhill was considered as one site with a variety of development options. The consideration of the site as one entity is in keeping with how the site has been viewed in the SHLAA, however it does not allow for a clear independent assessment of the land to the north and south of the NBAR, as the sites are considered in conjunction with others.

Page 70 sets out how the broader north Bexhill site has been examined, with the various connotations and combinations that have been explored. The areas relevant to this representation are to the east of the wider site, and fall within parcels 'A' and 'D'. Page 78 sets out how the various site options were considered and shows the scores that they achieved.

The land to the south of the NBAR is identified as part of a conglomeration of 3 sites in the policy options plan, all termed as Area 'A'. Area 'A' appears in every option provided, and each option is identified as having at least 7 positive scores and two 'no effect' scores of the 16 elements assessed.

The most relevant Option considered is Option 4, which considers solely the Area 'A' sites. Whilst this does not examine the site that has been identified in the DaSA as BEX3c on its own, it does provide an examination that is not affected by the other defined Areas. Option 4 identifies seven positive scores, three 'no effect' scores and six negative scores. Of the six negative scores, all are deemed to only have 'minor adverse effects'.

Given the inclusion of land to the south of the NBAR within the DaSA as a site allocation, it is therefore interpreted that receiving similar scores would also justify sites with a similar score being included as draft allocations.

The site to the north of the NBAR is identified as being Area 'D' in the policy options plan. It is only included in three options - Option 2, Option 3 and Option 5. In Options 2 and 3, business development on Area 'D' is proposed, whilst in Option 5, residential development is proposed.

Given that the proposed masterplan for the site includes residential development to the north of the NBAR, it is prudent to examine the outcomes of Option 5 of the sustainability Appraisal. Option 5 includes both Area 'A' and Area 'D', and assesses the sustainability of these two areas together. As with the assessment of Option 4, Option 5 shows a positive score against seven of the sustainability criteria with three criteria being deemed to be of 'no effect'. Of the six negative scores, five are deemed to have only 'minor adverse effects'. Sustainability Objective 15 (to protect and enhance the high quality natural built environment) is deemed to register a score of 'potentially significant adverse effects' when Area 'D' is included in Option 5.

This inclusion of this 'potentially significant adverse effect' appears erroneous. When considering SA Objective 15 specifically, (Protect and enhance the high quality natural and built environment) the SA finds that with Option 2 (which includes Areas 'A', 'B', 'C', and 'D)', there may be minor adverse effects, however when Areas 'B' and 'C' are removed, and only Areas 'A' and 'D' considered under Option 5, this rises to potential significant effects. For less development to fail to protect and enhance the high quality of the natural and built environment appears to therefore be an erroneous score. Option 5 should therefore register the same score when considered against the sustainability appraisal and result in a score that matches that achieved by Option 4.

It is acknowledged that development on greenfield land will result in a negative impact on the natural environment, however, had the inclusion of Area 'D' under Option 5 been scored correctly, It can be seen that the inclusion of Area 'D' for development has not had a materially harming impact when considered alongside the development of Area 'A'.

In light of this, the inclusion of Area 'D' for development would not register any more of a material impact on the natural environment than the inclusion of land that has already been given a draft allocation in the DaSA under BEX3a, BEX3b, or BEX3c. Accordingly the land assessed under Area 'D' should be taken forward as an allocation in accordance with the comments made in section 7 of this representation.

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