5. Overall spatial Development Strategy

Showing comments and forms 1 to 30 of 78

Support

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19122

Received: 23/01/2009

Respondent: Eastbourne Borough Council

Representation Summary:

Eastbourne Borough Council have no adverse comments about this document, and would like to offer its support to the whole of the Core Strategy Consultation on Strategy Directions.

Full text:

Eastbourne Borough Council have no adverse comments about this document, and would like to offer its support to the whole of the Core Strategy Consultation on Strategy Directions.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19126

Received: 26/01/2009

Respondent: Councillor David Vereker

Representation Summary:

5.12 The 40% affordable housing requirement will turn out to be a deterrent to devleopers.

5.36 You should leave options open here: so much can change, such as an unanticipated shift from private to public education, that "Service" villages could be overwhelmed.; the smaller communities also need investment.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19127

Received: 26/01/2009

Respondent: Councillor David Vereker

Representation Summary:

5.91 Is this strong enough? In my view it should be made quite clear that without the Link Road we will be unable to fulfil our allocation of new builds without destroying (some of) the AONB.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19173

Received: 28/01/2009

Respondent: HOWARD HUTTON & ASSOCIATES

Representation Summary:

The draft South East Plan requires the Council to provide for 4,000 of the 5,600 dwellings to be built in Rother between 2006 and 2026 in the coastal sub-region of the district to promote its regeneration.

It would therefore be appropriate for the Distribution Options Table at Paragraph 5.36 to separate the villages in the coastal sub-region from those inland.

This would provide a more accurate picture of whether the distribution between the two areas complies with the emerging South East Plan.

Full text:

The draft South East Plan requires the Council to provide for 4,000 of the 5,600 dwellings to be built in Rother between 2006 and 2026 in the coastal sub-region of the district to promote its regeneration.

It would therefore be appropriate for the Distribution Options Table at Paragraph 5.36 to separate the villages in the coastal sub-region from those inland.

This would provide a more accurate picture of whether the distribution between the two areas complies with the emerging South East Plan.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19174

Received: 28/01/2009

Respondent: HOWARD HUTTON & ASSOCIATES

Representation Summary:

In summary
The strategy proposed is considered to be unsound as it does not include any contingency plans which would address the issue of delayed (or cancelled)infrastructure.

The Council should include specific contingency plans that the Inspector can examine for soundness when considering the CS.

It is suggested that the Council consider additional allocations of c. 500 dwellings either as phased provision or as reserve sites.

Full text:

Paragraph 5.36
We do not agree that Option 2 - 'Service Centres' is the most appropriate distribution of development for the area.

The figure of 3400 dwellings for Bexhill proposed under Option 2 is based on the assumption that the Bexhill to Hastings Link Road will go ahead as set out in the 2008 Regional Transport Programme, with work commencing in 2009/10 and finishing in 2012/13.

Paragraph 5.79 recognises that this significant growth for Bexhill is reliant upon the construction of this road. However, there is currently considerable uncertainty regarding its timing and implementation.

The cost of the scheme has more than doubled since 2004 and the Regional Transport Board is in the process of considering whether it can continue to support the scheme given the increased cost. Even if it does, it is doubtful that the road will be provided on the proposed timetable.

Paragraph 5.84 sets out the implications of any delay in the opening of the Link Road on the number of houses built.

It states that a three year delay would result in 500 fewer houses.

Paragraph 5.86 sets out a number of options or contingencies in the event of delay or cancellation of the Link Road.

We support the proposal that additional sites in other towns and villages would be allocated to maintain development levels and the recognition (Paragraph 5.87) that there may be a margin for more development than currently planned at Battle.

However the inference is that the Core Strategy would be amended after its adoption to address any shortfall. This would presumably need to be done through a review of the Core Strategy and the Site Allocations DPD which would require a new round of consultation and examination.

An alternative would be to adopt the approach which has been used by other authorities and which directly addresses the issue of infrastructure uncertainty and that is the concept of 'reserve sites' (see East Hampshire District Council et al).

We believe infrastructure delay needs to be considered now and additional sites identified that could be reserved in the event of a delay because it is highly likely that the situation on the Link Road will become clear between now and the public examination of the Core Strategy.

If a delay (or cancellation) was clear at that stage the Core Strategy may well fail to meet the Council's obligation to provide the necessary land supply upon the adoption and thus run the real risk that it is found to be unsound. The Inspector would not be able to accept an early review of the CS/Site Allocatons as an acceptable contingency plan.

The higher level of housing required to cover the possibility of infrastructure delay would not be contrary to Government aims or objectives.

Government has made it clear that it wishes to see a step change in housing delivery and that the housing figures in the draft South East Plan are considered to be minima rather than maxima not to be exceeded.

An increase of c 500 dwellings at the other towns or villages, either allocated/phased or as 'reserve sites' would cover any likely potential delay to the Link Road and associated development at Bexhill.

The proposal that such an allocation or allocations should include prioritising the higher order service centres such as Battle is supported.

In summary
The strategy proposed is considered to be unsound as it does not include any contingency plans which would address the issue of delayed (or cancelled)infrastructure.

The Council should include specific contingency plans that the Inspector can examine for soundness when considering the CS.

It is suggested that the Council consider additional allocations of c. 500 dwellings either as phased provision or as reserve sites.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19240

Received: 29/01/2009

Respondent: Park Holidays UK

Agent: Rural Solutions

Representation Summary:

Tourism is recognised in the South East Plan as a significant element of the local economy, particularly in the coastal resorts and along the south coast as a whole, as well as in rural areas. It is acknowledged as a significant part of Rother's economy.

The SE Plan calls for a comprehensive, long term vision for the role of tourism and related activities in order to shape investment and decisions (SE Plan D10 1.5)

As such tourism as a distinct element of the economy of the area should feature within the overall spatial strategy.

Full text:

Tourism is recognised in the South East Plan as a significant element of the local economy, particularly in the coastal resorts and along the south coast as a whole, as well as in rural areas. It is acknowledged as a significant part of Rother's economy.

The SE Plan calls for a comprehensive, long term vision for the role of tourism and related activities in order to shape investment and decisions (SE Plan D10 1.5)

As such tourism as a distinct element of the economy of the area should feature within the overall spatial strategy.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19251

Received: 30/01/2009

Respondent: Aroncorp Ltd

Agent: Broadlands

Representation Summary:

With reference to paragraph 5.61 the Strategy should acknowledge that there is an opportunity at, and adjoining, the current Local Plan residential allocation at Udimore Road, Rye to achieve more dwellings than the 135 benefitting from the grant of planning permission. The approved access could accommodate such development and there are no overriding environmental issues that outweigh the benefits of making best use of this residential commitment including the delivery of affordable housing that should be considered an important objective in furthering the aim to improve the economic and social well-being of Rye

Full text:

With reference to paragraph 5.61 the Strategy should acknowledge that there is an opportunity at, and adjoining, the current Local Plan residential allocation at Udimore Road, Rye to achieve more dwellings than the 135 benefitting from the grant of planning permission. The approved access could accommodate such development and there are no overriding environmental issues that outweigh the benefits of making best use of this residential commitment including the delivery of affordable housing that should be considered an important objective in furthering the aim to improve the economic and social well-being of Rye

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19252

Received: 30/01/2009

Respondent: Aroncorp Ltd

Agent: Broadlands

Representation Summary:

The proposal that the approximate development level for Rye in the twenty year period 2006-26 should be confined to 450 dwellings is inadequate.
The Strategy does not contain the evidence referred to in paragraph 8.25 on which the case for the lower figure of 450 dwellings is advanced.
There is no evidence to support the proposal not to provide for a range of housing numbers at Rye

Full text:

With reference to paragraph 5.66 the proposal that the approximate development level for Rye in the twenty year period 2006-26 should be confined to 450 dwellings is inadequate (see comments under Box 3). It is less than the commitment led Option 4 figure of 475 (paragraph 5.36) and less than the District-wide distribution options in Section 5 that suggest approximately 500 dwellings (paragraph 8.26).
The Strategy does not contain the evidence referred to in paragraph 8.25 on which the case for the lower figure of 450 dwellings is advanced. There is no evidence to support the proposal not to provide for a range of housing numbers at Rye "subject to detailed investigation of potential sites" as the Strategy provides for with dwelling numbers at Bexhill, the Hastings Fringes and Rye, or as the Strategy proposes with employment provision at Rye.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19253

Received: 30/01/2009

Respondent: Aroncorp Ltd

Agent: Broadlands

Representation Summary:

With reference to paragraph 5.87 there is scope at Rye to accommodate more than the 450 dwellings in the 20 year period 2006-2026 as proposed at paragraph 5.66. This paragraph fails to acknowledge that land to the west of Rye is not covered by national designations (see paragraphs 8.31 - 8.33).

Full text:

With reference to paragraph 5.87 there is scope at Rye to accommodate more than the 450 dwellings in the 20 year period 2006-2026 as proposed at paragraph 5.66. This paragraph fails to acknowledge that land to the west of Rye is not covered by national designations (see paragraphs 8.31 - 8.33).

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19466

Received: 24/02/2009

Respondent: Fairlight Parish Council

Representation Summary:

Para 5.79 (and elsewhere) Hastings/Bexhill Link Road
The Link Road is clearly essential to the Strategy. If it is not built then one of the options to achieve the South east Plan target is to "Allocate additional sites in other towns or in villages to be brought forward if necessary to maintain development levels" - para 5.86(2). We agree that option should be ruled out - para 5.88. Possibly villages should be referred to in the reasoning at para 5.87, the villages being unable to make up the deficit.

Support

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19497

Received: 30/01/2009

Respondent: Guestling Parish Council

Representation Summary:

Overall: The aim, objectives and preferred strategy are broadly agreeable.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19568

Received: 23/01/2009

Respondent: Mr. D. Redhead

Agent: Kember Loudon Williams Ltd

Representation Summary:

Paragraph 5.70 Page 30.
Inland rural village sites can contribute significantly towards meeting the District's housing targets. Controlled growth of villages can help to maintain and improve their viability and to prevent them effectively becoming devoid of community services. It is therefore considered that the role played by Rother's villages in providing housing allocations should neither be underplayed nor underestimated. the amount of housing planned in these locations should be increased towards meeting Regional guidance in the SE Plan.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19601

Received: 30/01/2009

Respondent: Rother and Hastings CPRE

Representation Summary:

Is the Baldslow Link critical to Rother per se? CPRE does not believe that the Bexhill Hastings Link Road (BHLR) is critical either, since it would introduce very significant environmental damage and is being promoted solely in our view to create a new development boundary. It is however critical because of the loss and environmental harm it would cause.
The trap into which this para has fallen is to believe that the housing is dependent on the BHLR. The BHLR is being in fact used as a pretext for designating an area for development.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19602

Received: 30/01/2009

Respondent: Rother and Hastings CPRE

Representation Summary:

We believe the figures in this box should be seriously retested as the ratios, particularly between the various options for Battle and Rye do not appear logically consistent.
Para 5.40 This is not equitable: it is just based on existing population statistics. Therefore it only takes account of previous developments which have swollen certain centres to a point of unsustainability.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19603

Received: 30/01/2009

Respondent: Rother and Hastings CPRE

Representation Summary:

Page 27 Para 5.44 This again reflects what has happened in the past and takes no account of current factors in those areas.

Para 5.47 This is flawed, because in the midst of the current recession, you cannot say what housing will be achieved by the end of 2011.
Option 2 appears to be the fairest basis for assessment.
Rother does have a strong record of providing windfall sites for housing. This must be taken into account so that all housing targets are continuously reassessed

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19605

Received: 30/01/2009

Respondent: Rother and Hastings CPRE

Representation Summary:

Para 5.79 We contest absolutely this statement. It is simply not true: significant growth, if needed, can be accommodated without the BHLR. There were substantial submissions about this to the planning application, but the application was decided on political grounds, not planning ones. Therefore this and subsequent paragraphs fall because they are based on a totally false premise.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19651

Received: 02/03/2009

Respondent: Messrs. Chishick, Commotto and Terry

Representation Summary:

The choice of Distribution Options is far from sophisticated. One wonders whether some serious multi-factor modelling would have been justified, given that this matter will be at the heart of the LDF. Options l, 3 and 4 are just extrapolations. Option 5 (housing need) is not convincing, given that it seems to be based on wishes of where one would like to live and ignores key constraints such as job availability. Option 2 (service centres) appears to be the most sensible. However, the horizon of 2026 is so long that a single option is unlikely to be sustainable. Why not Option 4 until 2011 and then Option 2?

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19730

Received: 30/01/2009

Respondent: Tesco Stores Ltd.

Agent: Development Planning Partnership

Representation Summary:

We note that the strategy set out at Paragraph 5.19 identifies the importance to retain retail expenditure within Rye through a qualitative improvement in local retailing. However, we believe that this paragraph needs to be more explicit as to the nature of the need (i.e. convenience goods shopping supplemented by some ancillary comparison goods floorspace1) and provide a broad indication of the scale of and nature retail development (namely a new foodstore) required to be able to stem the very substantial level of convenience expenditure outflow, thus helping to retain retail expenditure within Rye.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19731

Received: 30/01/2009

Respondent: Tesco Stores Ltd.

Agent: Development Planning Partnership

Representation Summary:

The 'Rother District Wide Shopping Assessment' identifies qualitative need for additional convenience floorspace within Rye. We welcome the acknowledgement of this need within the Core Strategy. However, the scale of floorspace need identified in the Shopping Assessment is indicative and should be seen as a starting point only. This figure should be taken as a guide only. As it is currently worded, there is not enough attention drawn to the key matter of convenience expenditure leaking from Rye to surrounding areas. It is requested that the second sentence of Paragraph 5.19 be amended as follows:

"However, there is a substantial trade "leakage" from both towns/ particularlv for convenience goods."

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19732

Received: 30/01/2009

Respondent: Tesco Stores Ltd.

Agent: Development Planning Partnership

Representation Summary:

Paragragh 5.65: Box 3 -Preferred Strategv for Overall Spatial Development
We note that item (g) of the preferred strategy gives particular attention to meeting 'local' needs. We believe that this paragraph should make particular reference to convenience shopping as a 'local need'.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19733

Received: 30/01/2009

Respondent: Tesco Stores Ltd.

Agent: Development Planning Partnership

Representation Summary:

Paragraoh 5.66 -Table. We believe that this table should make reference to the fact that this figure is a guide only and should not be prescriptive. The scale of new retail development required should aim to stem the outflow of convenience expenditure from the town. This can only be provided in a modern foodstore, with adjoining car parking.
The Shopping Assessment supports this assessment by stating that extending existing stores will not create sufficient customer attraction and it acknowledges the demand of 'large grocery store retailers' to have a mix of both food and non-food goods (paragraphs 7.45 -7.47).

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19740

Received: 30/01/2009

Respondent: RSPB

Representation Summary:

5.7 -Recreational and environmental pressures associated with housing and infrastructure could lead to an adverse effect on the Natura 2000 sites (Pevensey Levels Ramsar site and Dungeness to Pett Level SPA site).
The provision of alternative green space and access management measures on the European sites will provide a mitigation strategy in order to offset recreational impacts. The capacity of natural receptors (Natura 2000 Sites) to absorb additional pollutants produced from new development will have to be carefully assessed and mitigated. The Appropriate Assessment will need to demonstrate that mitigation methods will prevent adverse effects on Natura 2000 sites, before housing numbers adopted.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19742

Received: 30/01/2009

Respondent: RSPB

Representation Summary:

Bexhill Hastings Link Road
The Core Strategy should avoid all direct land take from Combe Haven or Marline Valley Wood SSSI and any assessed impacts mitigated against.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19778

Received: 30/01/2009

Respondent: East Sussex County Council

Representation Summary:

5.97 b) Contribution to 'building communities', including the potential to retain and improve key services;
It would be helpful if these key services are defined.
Officers of ESCC Children's Services welcome the opportunity to continue working with Rother District Council as it refines and finalises its site allocations and numbers of dwellings

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19791

Received: 30/01/2009

Respondent: East Sussex County Council

Representation Summary:

OVERALL SPATIAL STRATEGY

Para 5.22:
While the definition of infrastructure appears to be inclusive, it would be better;

a) if that point was explicit; and,

b) measures to make better use of existing infrastructure capacity were mentioned (as per para 5.54), i.e. amend to read "....This may be interpreted widely to include "hard infrastructure" - roads, water supply, drainage - community infrastructure - schools, leisure facilities, green spaces and services - measures to make better use of infrastructure - travel plans, travel information, car club - and other local services."

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19792

Received: 30/01/2009

Respondent: East Sussex County Council

Representation Summary:

Para 5.79

Complementary measures to make better use of the existing transport network are necessary as well as the BHLR. On that basis, the text should be amended to read: "... highway authority that significant growth, as envisaged by the South East Plan, for both Bexhill and Hastings, is reliant upon both its construction and local measures to provide the necessary transport network capacity."

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19823

Received: 04/02/2009

Respondent: Crowhurst Society

Representation Summary:

Surely it is fallacious to say that housing needs in RDC cannot be met without major road schemes.
5.10 Where is the evidence that this proposition works?
5.11 Is the provision of business premises the only driver for the economy -what other help can be given to local businesses? e.g. rate reductions!
5.18/19 Again what about local businesses that are already here? What help will they receive?
5.22 Really? Is this really the case?
The constraint of the SSSI has not stopped Rother supporting the Link Road and development on Greenfield sites next to Acton's Farm!
5.25 The greatest risk to lack of progress is the paralysis brought about by pinning too many plans on the back of the Link Road. Is there not a fall-back position?
5.31 Agreed.
5.32. Too strong.
Benefits of living in the countryside need to be set against the low level of service enjoyed in these areas.
5.65- needs to be underlined throughout.

Comment

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19825

Received: 04/02/2009

Respondent: Crowhurst Society

Representation Summary:

5.66 - 1300 village dwelling 10,000 sq.m of business - how does this impact upon 'villages'? - a shopping mall in Sedlescombe?
5.84 - What is the evidence base (apart from the house not being in any other plan) for this statistic? Is there any reliability in this statement?
5.87 Are we to take from this that the statements about land for housing is not based on anything other than a desk top exercise?
5.93 This would follow on from housing services.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19905

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Representation Summary:

The Core Strategy should ensures that there is flexibility to enable the delivery of housing across the District at a sustainable rate in line with the South East Plan annual requirement.

The Council's continual reliance on a single large-scale development is wholly dependent on the delivery of major infrastructure. The Core Strategy should contain sufficient flexibility to enable the delivery of other development sites to meet any shortfall against the minimum housing requirement. Need for the Core Strategy to enable delivery from other short / medium term sites.

The availability of brownfield sites, will likely to reduce in the short term. Small scale greenfield sites should be promoted, which generally have lower development costs, in the early part of the plan period.

Object

Core Strategy Consultation on Strategy Directions 2008

Representation ID: 19907

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Representation Summary:

Subsection (a) refers to a dwelling range of between 5,600 - 5,850 to be provided. It is misleading as this could be interpreted as a minimum and maximum requirement. The imposition of a maximum requirement would be in conflict with the South East Plan It should be clearly noted that both figures are minimum figures.
subsection (b), the Core Strategy should not seek to unduly restrict the delivery of development.

Whilst the principle behind subsection (c) is supported, greenfield land is not supported which represents a very important source of housing land supply. Objection to the wording in paragraph 5.65 which suggests that Greenfield development should be considered as the last option. (c) should acknowledge the contribution that greenfield development can provide in meeting the District's housing requirement.