5. Overall spatial Development Strategy

Object

Representation ID: 19908

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Subsection (g) is generally supported, although, the use of the term "limited growth" is objected to. It would be more appropriate to remove the term "limited growth" and replace with an acknowledgement that growth in the rural villages should be in line with the South East Plan's housing requirement for the rest of District area.
It is clear that the Council, in exercising Policy ST5 (and not Policy ST2 as referred to in paragraph 5.70) of the South East Plan, is seeking to adopt a development strategy that falls below the "Rest of District" housing requirement set out by the South East Plan due to reason of sustainability. It is not entirely clear whether the Council can demonstrate this.

Object

Representation ID: 19909

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

iii) Future Allocations and Windfall Sites
Object/Comment

The information referred to in paragraph 5.72, which is set out in Appendix 3, is based on a number of assumptions regarding the deliverability of both large and small committed sites, which together amount to around 1,330 dwellings.
It is highly likely that the remaining housing requirement will increase based on an initial assessment of those committed sites relied upon.
Appendix 3 is reliant on all current allocated sites being carried forward into the LDF. Many have not been subject to planning applications since adoption of the Local Plan and as such casts doubt over the deliverability of those sites.

Support

Representation ID: 19910

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Croudace wholly supports the Council's acknowledgement that the release of allocations should not be withheld arbitrarily. This supports the need for greater flexibility to allow the release of development sites in order to respond to any shortfalls.

Comment

Representation ID: 19934

Received: 29/01/2009

Respondent: Mrs. P.C. Ward-Jones

Agent: Mr Clifford Dann

Comments submitted regarding site specific location for development.

The 'enclosing' area west of Spindlewood Drive, Bexhill, should be included within the development boundary. There remains a serious shortfall of readily available housiing land in the Bexhill area. The Spindlewood site, being immediately available, would help to meet that shortfall.

Comment

Representation ID: 19993

Received: 16/01/2009

Respondent: Lark Row Developments Ltd.

We are supportive of the option based on Service Centre Role for the reasons stated in the document. We also support the statement that this should be taken as a starting point as this will allow variations in both market circumstances and capacity particularly in rural areas.
The potential loss of expansion capacity in Bexhill, should the Link Road not go ahead within the Plan period, also argues for a flexible approach to capacity in rural service centres. The conclusion in relation to the Link Road contingency that the option of faster or additional development in individual service centre villages should be ruled out appears premature in advance of the site assessments.

Object

Representation ID: 20010

Received: 27/01/2009

Respondent: The Newcombe Estates Co. Ltd.

Agent: Martin Robeson Planning Practice

Objection is raised regarding the Council's failure to acknowledge historically low housing completion rates. The Council is "wiping the slate clean" and ignoring historic deficiencies in housing supply from as far back as 1991. There is effectively no opportunity within the Council's current proposals to "catch up".

Object

Representation ID: 20012

Received: 27/01/2009

Respondent: The Newcombe Estates Co. Ltd.

Agent: Martin Robeson Planning Practice

The risks associated with the failure to implement the Bexhill to Hastings Link Road are clear and documented.

It is noted that the significant growth envisaged by the South East Plan for Bexhill and Hastings is entirely dependent on Link Road construction to provide necessary highway capacity. The Link Road therefore represents the single largest risk to housing growth in Rother.

Whilst several alternative options and contingencies have been considered by the Council, a significant objection is raised regarding the Council's preferred strategy relating to the timing of the Bexhill-Hastings Link Road.

Comment

Representation ID: 20076

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

It appears the whole balance of the emerging plan is influenced by the Link Road, since it provides a basis for achieving many of the policies set out within it. The question arising is whether a plan is prepared based on the assumption the road does proceed, subject to further review, whether the plan is delayed until a decision is made or whether some account is taken of possible contingency arrangements in the event the road is delayed or cancelled.

Comment

Representation ID: 20077

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

My preference would be to wait for there to be more certainty regarding the road and therefore, consequential allocations. In my view there is a strong argument that the plan should not proceed until the road issue is sufficiently resolved, since the contingencies add a layer of unnecessary complexity to what should be an absolutely clear policy direction for the district.

Support

Representation ID: 20078

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

Support para 5.52. The Council's preferred development option based upon settlements' service roles is broadly supported (Option2). This identifies an allocation for Battle of up to 500 dwellings. it is acknowleged that much of the district is environmentally constrained, bar (broadly) Bexhill, but the regional spatial strategy requires allocations for the coastal area and hinterland to be met. Is the distribution of development between Bexhill, Battle, Rye and villages actually achievable?

Comment

Representation ID: 20079

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

There has to be a question mark over the Link Road and Rye allocations. If in addition potential sites identified in SHLAA are not deliverable, and otherwise meet PPS3 requirements, then the distribution may need to be amended. What flexibility is there to achieve that in the emerging plan? Has the SHLAA informed para 5.36 and 5.52?

Comment

Representation ID: 20080

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

Para 5.87: It is noted that in the Council's consideration of contingencies, there may be scope for more development of Battle than currently planned. I also believe that to be the case.

Support

Representation ID: 20083

Received: 29/01/2009

Respondent: Messrs. F. Mitchell and Cartwright

Agent: Batcheller Thacker

Para 7.11: Option 2 - continued development to support Battle's role.

Support

Representation ID: 20088

Received: 29/01/2009

Respondent: Mr. R.T. Caine

Agent: Batcheller Thacker

The Council's preferred development option based upon settlements' service role is broadly supported. Is the distribution between Bexhill, Battle, Rye and villages actually achievable? There has to be a question mark over the Link Road and Rye allocations. If, in addition, potential sites identified in the SHLAA are not deliverable, and otherwise meet PPS3 requirements, then the distribution may need to be amended. What flexibility is there to achieve that in the emerging plan? Has the SHLAA informed para 5.36 and 5.52?

Comment

Representation ID: 20089

Received: 29/01/2009

Respondent: Mr. R.T. Caine

Agent: Batcheller Thacker

Para 5.87: It is noted that in the Council's consideration of contingencies, there may be scope for more development of Battle than currently planned. I also believe that to be the case.

Comment

Representation ID: 20094

Received: 29/01/2009

Respondent: TOM SACKVILLE

Agent: Batcheller Thacker

As I have commented elsewhere, it appears the whole balance of the emerging plan is influenced by the Link Road, since it provides a basis for achieving many of the policies set out within it. The question arising is whether a plan is prepared based on the assumption the road does proceed, subject to further review, whether the plan is delayed until a decision is made (such as happened in Maidstone, with the Kent International Gateway) or, as the Council has attempted, whether some account is taken of possible contingency arrangements in the event the road is delayed or cancelled.

Comment

Representation ID: 20095

Received: 29/01/2009

Respondent: TOM SACKVILLE

Agent: Batcheller Thacker

My preference would be to wait for there to be more certainty regarding the road and therefore, consequential allocations. In my view there is a strong argument that the plan should not proceed until the road issue is sufficiently resolved, since the contingencies add a layer of unnecessary complexity to what should be an absolutely clear policy direction for the district.

Object

Representation ID: 20096

Received: 29/01/2009

Respondent: TOM SACKVILLE

Agent: Batcheller Thacker

Para 5.25: I do not believe it is the case that development must be suspended pending the start and completion of the Link Road. There is some, albeit limited, scope for residential development to the west of Bexhill.

Support

Representation ID: 20097

Received: 29/01/2009

Respondent: TOM SACKVILLE

Agent: Batcheller Thacker

Paras 5.35, 5.52: The basis for the distribution of development (service centres) is broadly supported. However, there is significant uncertainty as to whether the distribution of development as suggested can be achieved.

Comment

Representation ID: 20098

Received: 29/01/2009

Respondent: TOM SACKVILLE

Agent: Batcheller Thacker

Para 5.46: On what basis is it alleged that flatted development does not accord with creating a more economically vibrant town (Bexhill)?

Support

Representation ID: 20105

Received: 29/01/2009

Respondent: Mr. J. Auer

Agent: Batcheller Thacker

Para 5.52: As indicated in para 5.7 some 5,600 dwellings are identified for Rother District up to 2026 in the South East Plan. About 4,000 would be built in the coastal sub region, defined within that plan (Bexhill, Rye, Camber, Catsfield and Crowhurst), with the balance of 1,600 dwellings provided inland covering Battle and all other rural wards. The Council's development distribution suggested in its Strategy Directions document is based upon settlements service roles and is broadly supported. This identifies an indicative distribution of 3,400 dwellings for Bexhill, 500 for Battle, 500 for Rye and 1,200 for villages (including Catsfield).

Comment

Representation ID: 20106

Received: 29/01/2009

Respondent: Mr. J. Auer

Agent: Batcheller Thacker

Para 5.52 cont. There is a question as to whether the distribution is realistic, given the uncertainty surrounding the Link Road and Rye allocations. Clearly, if the potential development sites identified in the SHLAA are not deliverable, and otherwise meet PPS3 requirements, then the distribution may need to be amended. What flexibility is there to achieve that in the emerging plan? To what extent has the SHLAA informed the current consultation plan?

Support

Representation ID: 20107

Received: 29/01/2009

Respondent: Mr. J. Auer

Agent: Batcheller Thacker

Para 5.57: Development within villages should contribute to their character and the sustainability of services, as well as meeting local needs. The Rural Settlement Study referred to, suggests the possibility if development to the west of the A269 in the Catsfield village appraisal - this is taken to mean the B2204 - subject to further investigation. My client owns land within this sector and reaffirms his interest in bringing it forward for development, preferably earlier rather than later, within the plan period.

Object

Representation ID: 20135

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

The purpose of achieving sustainability appraisal process and testing is to seek to balance environmental issues with economic and social objectives. In some circumstances, it may be that to achieve social and economic objectives, environmental protection policies may need to be reviewed.

Suggested Change:
Trinity College suggests that Para 5.10 is amended to read ''as highlighted is Section 2: Spatial Portrait there are also very significant environmental constraints. However. these need to be balanced aqainst the pursuit of social and economic goals.

Comment

Representation ID: 20136

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

Trinity College suggests that the retailing section acknowledges the role new urban extensions will have in contributing to the District's and in particular Bexhill's retail offer.

Suggested Change:
Trinity College suggest that para. 5.19 include a further sentence along the lines of "The new urban extensions in Bexhill will also provide opportunities for increases in the district's retail offer".

Object

Representation ID: 20137

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

Objects to the Council's view that it is inappropriate to plan for higher levels of development in the coastal part of the district.

Suggested Change:
The Core Strategy should provide a spatial planning framework capable of accommodating scales of development beyond those minimum figures set out in the draft South East Plan. This would help to provide the strategy with the 'in-built' flexibility to deal with changing circumstances, such as RSS reviews, brownfield sites not coming forward as anticipated, changing market conditions and to aid the viability of existing commitments by providing scope for allocated sustainable urban extensions to be increased in size.

Support

Representation ID: 20138

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

Supports the spatial strategy's broad option to focus the highest levels of development at Bexhill.

Object

Representation ID: 20140

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

Paragraph 5.66

Trinity College objects to the omission of further growth at North East Bexhill beyond the existing commitment

Suggested change:
Trinity College suggests that the table should also indicate the potential for further growth at North East Bexhill (see other Trinity College representations).

Object

Representation ID: 20156

Received: 01/01/2009

Respondent: Crowhurst Parish Council

The Preferred Policy Direction for the distribution of housing states '200-400 dwellings on the fringes of Hastings with Rother district'. We understand this to be bordering Crowhurst and we have concerns about this number on the boundary of the village, the impact on roads and the infrastructure.

Object

Representation ID: 20166

Received: 28/01/2009

Respondent: Persimmon Homes South East

Agent: Bell Cornwell

The South East Plan make it clear that it is not an acceptable option to consider only the minimum number of dwellings required to comply with the RSS.

So as to ensure compliance with the emerging South East Plan the core strategy should show how it is intended to deliver the respective totals of 4,000 (200 per annum) in the Sussex Coast part of the District and the 1 ,600 (80 dwellings per annum) in the rest of the District.