Box 3 - Preferred Strategy for Overall Spatial Development
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19082
Received: 11/11/2008
Respondent: Courtley Consultants Ltd
Agent: Courtley Consultants Ltd
(c) should not encourage the redevelopment of suitable employment land as previously developed land as this would be contrary to the Districts own policies on retaining employment land. We suggest a specific reference to this point in Box3
(g)should emphasise the specific role of Rural Service Centres in meeting a large proportion of the sustainable local and market housing needs in the rural community.
(c) should not encourage the redevelopment of suitable employment land as prevoiusly developed land as this would be contry to the Districts own policies on retaining empolyment land. We suggest a specific reference to this point in Box3
(g)should emphasise the specific role of Rural Service Centres in meeting a large proportion of the sustainable local and market housing needs in the rural community.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19137
Received: 26/01/2009
Respondent: Tunbridge Wells Borough Council
The urban focus of the approach is broadly consistent with that proposed by Tunbridge Wells Borough Council in its Core Strategy Preferred Options.
Regarding the fact that the next greatest proportion of housing is to be allocated to the villages, this should be closely linked to service provision justification and land release controlled.
We understand that you will be focusing a majority of development within Bexhill, and we support the preferred option in that it pursues an urban focus by preference and is based on a service centre hierarchy. This approach is broadly consistent with that proposed by Tunbridge Wells Borough Council in its Core Strategy Preferred Options Report.
It is noted that this approach would see the next greatest proportion of housing allocated within the villages. Accepting that you are looking to the villages to accommodate development due to the constraints at Rye and Battle, we would be concerned to ensure that it continues to be closely tied to a service provision justification, and that land release is carefully controlled as indicated in Section 9 - Rural Areas. Tunbridge Wells Borough Council is not proposing to allocate greenfield sites abutting villages for general market housing (as indicated in para. 9.24) and would not support their growth based only on land availability.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19138
Received: 26/01/2009
Respondent: Cllr Susan Prochak
In line with the vision of the LDF, village developments should be organic and this should mean small developments to meet housing needs.Village boundaries should be vigorously protected apart from exception sites.
In line with the vision of the LDF, village developments should be organic and this should mean small developments to meet housing needs.Village boundaries should be vigorously protected apart from exception sites.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19141
Received: 26/01/2009
Respondent: Cllr Susan Prochak
To add an ambition to provide buildings and design to reduce the energy use of buildings and to prevent exacerbation of fluvial and surface water flooding.
To add an ambition to provide buildings and design to reduce the energy use of buildings and to prevent exacerbation of fluvial and surface water flooding.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19153
Received: 26/01/2009
Respondent: Mr Nigel Jennings
paragraph (h) refers to allowing small scale infill and redevelopment. This presumably includes gardens of existing houses. There has been some concern expressed in recent years about the effect of building in gardens and the way that can alter the charactor of an area and harm urban biodiversity. I would like to see some qualification to this to prevent harm to the neighbourhood charactor.
paragraph (h) refers to aloowing small scale infill and redevelopment. This presumably includes gardens of existing houses. There has been some concern expressed in recent years about the effect of building in gardens and the way that t can alter the charactor of an area and harm urban biodiversity. I would like to see some qualification to this to prevent harm to the neighbourhood charactor.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19154
Received: 26/01/2009
Respondent: Mr Nigel Jennings
Paragraph 5.69 states that the proposed allocations across the distruct will slightly exceed the housing target set for 'Sussex Coast' part of Rother. As this is already the most crowded part of the district is this wise? Surely the position of Robertsbridge, Etchingham and Ticehurst on the main line to London and Tunbridge Wells would facilitate the expansion of these communities.
Paragraph 5.69 states that the proposed allocations across the distruct will slightly exceed the housing target set for 'Sussex Coast' part of Rother. As this is already the most crowded part of the district is this wise? Surely the position of Robertsbridge, Etchingham and Ticehurst on the main line to London and Tunbridge Wells would facilitate the expansion of these communities.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19187
Received: 28/01/2009
Respondent: Northiam Parish Council
(b)stresses the need to allow development in a timely manner to meet 'local' needs and the availability of infrastructure.NPC is concerned that Northiam is suffering the cumulative effect on infrastructure of a number of smaller developments not felt by RDC to be individually significant.
(g)stresses that meeting local needs is paramount. NPC is concerned that social housing not needed by Northiam residents may be provided within the village and used to re-house families from urban areas who have no wish to be here. This divides rather than stregthens communities.
The method of recording completed dwellings in villages against development quotas requires clarification.
(b)stresses the need to allow development in a timely manner to meet 'local' needs and the availability of infrastructure.NPC is concerned that Northiam is suffering the cumulative effect on infrastructure of a number of smaller developments not felt by RDC to be individually significant.
(g)stresses that meeting local needs is paramount. NPC is concerned that social housing not needed by Northiam residents may be provided within the village and used to re-house families from urban areas who have no wish to be here. This divides rather than stregthens communities.
The method of recording completed dwellings in villages against development quotas requires clarification.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19195
Received: 28/01/2009
Respondent: OCEAN PARCS LIMITED
Agent: Brett Drury Land & Planning
Housing Evidence base is inadequate in range, out of date and fails to take account of financial viabilty as required in PPS. Does not recognise or plan for sub-sectors such as homes for the elderly and retired
Employment section doesn't recognise Holiday Parks as important and large scale businesses. Doesn't anticipate or plan for changing needs of tourism and leisure industry particularly for rural areas.
• HOUSING: The evidence based studies on Housing do not examine the various sectors of housing which make up the overall requirement. The UK has an ageing population and catering for the increasing needs of this growing sector is an essential component of any planning housing policy. There is a wide range of housing need for those who are broadly over 50 yrs of age.
• Many of the sub-sectors are quite specialist and new sectors are continuously evolving. An example of this is the increasing tendency for semi-retirement. For those taking part-time or reduced time employment, leisure and tourism ambitions are often achieved through dividing living between two residences. This has been traditionally manifest through ownership of caravans or mobile homes for weekend and holiday use.
• However, there is now an emerging market for more traditional homes for use on a part-time basis. Sometimes this means occupation during the week but not at weekends and during off-peak seasons where owners choose to avoid holiday crowds. If encouraged, this trend could help to provide a better balance to the peak period pressure on infrastructure and services.
• In this connection, the housing policies need fully to recognise and cater for a range of housing sector types as a specialist and rapidly expanding broader sector for an ageing population. These will include for a range of need including for the following:
• Holiday homes (including caravans, mobile homes and time-share homes),
• 'Life-style' homes' including second homes,
• Sheltered housing,
• Retirement homes,
• Care-homes and,
• Nursing homes.
• As with the overall national trend, at Rother there is a well established and growing demand for specialist housing to cater for older residents (not necessarily the retired). These include those from the indigenous population, as well as those who have resorted to Rother for many years as holiday-makers and new-comers.
• Government policy now gives much greater recognition to meeting the needs of the elderly and is committed to changing the culture of planning to make it "more responsive, positive and proactive". This statement is within the Planning and Compulsory Purchase Act 2004, which explains what is required at a regional and local policy-making level. Diversity and equality are at the heart of this agenda.
• The Government is also committed to creating strong, vibrant and sustainable communities and to promoting community cohesion in both urban and rural areas. These are important elements of delivering sustainable development, which the Government defines as the principle purpose of the planning system.
• Planning Policy Statement 1 (PPS1 2005) states that planning for sustainable development means 'meeting the diverse needs of all people in existing and future communities, promoting personal well being, social cohesion and inclusion and creating equal opportunity for all citizens'.
• It goes on to state that: 'Development plans should promote development that creates socially inclusive communities, including suitable mixes of housing. Plan policies should:
• ensure that the impact of development on the social fabric of communities is considered and taken into account;
• seek to reduce social inequalities;
• address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities;
• take into account the needs of all the community, including particular requirements relating to age, (my underlining) sex, ethnic background, religion, disability or income;
• deliver safe, healthy and attractive places to live; and
• support the promotion of health and wellbeing by making provision for physical activity.'
• Planning Policy Guidance Note 3: Housing (PPG3) is clear in its requirements that:
"Local authorities should plan to meet the requirements of the whole community, including those with 'special needs'. Amongst the 'specific groups' whose needs should be assessed and planned for are 'the elderly'." (My underlining)
• There are several other Government policy documents which have addressed the needs of older people. For example, Quality and Choice for Older People's Housing (DETR 2001) says:
"The increasingly older population poses a challenge for social policy generally and housing policy specifically."
• More recently the Green Paper "Opportunity Age" (Department of Health 2005) sets out the key principles of the Government's strategic approach towards older people, including:
• promoting their well-being and independence and providing them with choice and accessibility;
• tackling discrimination against older people;
• ensuring that local authorities take a lead role in planning for the ageing of their community
• The lack of any reference to this specialised housing sector in the evidence-based supporting documents, results in the CS paragraphs 5.7 - 5.12 also making no mention of providing for this sector.
• It is our view that specific recognition of this housing sector should be made in this section of the CS and that aims and objectives should plan for its expansion directing development to appropriate areas. We believe that this should include provision for the expansion and re-development of Housing, Chalets, Caravan and mobile home parks where these cater for those who are retired, semi-retired and elderly.
• We reiterate our concern that new policy should provide for a flexible response to emerging and as yet, unidentified market sectors. This is particularly important in order to secure an enhanced and buoyant tourist and leisure-based economy for Rother for the lifetime of the Development Framework and beyond.
• EMPLOYMENT: The preferred spatial strategy makes no mention of the promotion and growth of tourism and leisure industry within rural and coastal settlements such as Camber. Although Camber is specifically recognised as having an established and particular tourism niche by virtue of its natural assets; the way in which the changing patterns of tourist and visitor ambition is to be accommodated is not examined or catered for.
• As already stated, Draft PPS4 requires Local Planning Authorities to support and encourage business expansion where it is sustainable and can be balanced with environmental factors. This expressly includes those within rural areas.
• In paragraph 32, PPS4 states:
"In rural areas, recognising that accessibility - whether by private transport, public transport, walking and cycling - is a key consideration, local planning authorities should:
• Recognise that a site may be an acceptable location for development even though it may not be readily accessible by public transport;
• Support small-scale economic development where it provides the most sustainable option in villages that are remote from, and have poor transport links with, local service centres."
• At Camber, the long-established holiday parks are businesses which contribute significantly to the local economy. Indeed, they are the principle reason for the growth of the settlement itself. Specifically the Pontins Holiday Park employs 250 people (most local) with a significant multiplier for locally-based secondary employment.
• This ranks the holiday park as one of the District's major employers. We find it odd that the policy documents fail fully to recognise the value of the tourism and leisure industry as a driver to economic prosperity that plays a pivotal role in the overall Spatial Development Strategy. That this role should be encouraged to expand and achieve its full potential is without question what is required in draft PPS4
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19224
Received: 29/01/2009
Respondent: Sedlescombe Parish Council
e) This statement is too vague and should specify the area(s) referred to. Sedlescombe Parish Council would not support any extension of the urban fringes of Hastings outwards from the Hastings boundary with Rother District to the south of Baldslow. Large-scale development has already taken place on the Hastings side of the boundary and the area between Baldslow and the parish of Sedlescombe along the A21 should be safeguarded as an important area of countryside. This is especially important now that the Sussex Coast Sub-Region has been identified which touches the boundary of Sedlescombe parish (fig.5, page 15).
e) This statement is too vague and should specify the area(s) referred to. Sedlescombe Parish Council would not support any extension of the urban fringes of Hastings outwards from the Hastings boundary with Rother District to the south of Baldslow. Large-scale development has already taken place on the Hastings side of the boundary and the area between Baldslow and the parish of Sedlescombe along the A21 should be safeguarded as an important area of countryside. This is especially important now that the Sussex Coast Sub-Region has been identified which touches the boundary of Sedlescombe parish (fig.5, page 15).
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19242
Received: 29/01/2009
Respondent: Park Holidays UK
Agent: Rural Solutions
Add:
j. Support and encourage the upgrading and improvement of existing tourism facilities and accommodation. Allow for appropriate tourism development in both urban and rural areas which promote higher value activity and reduce seasonality.
Add:
j. Support and encourage the upgrading and improvement of existing tourism facilities and accommodation. Allow for appropriate tourism development in both urban and rural areas which promote higher value activity and reduce seasonality.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19250
Received: 30/01/2009
Respondent: Aroncorp Ltd
Agent: Broadlands
Acknowledging that the SE Plan figure of 5,600 dwellings is a minimum (paragraph 5.7) and that Rye is located within the "Sussex Coast" part of Rother the Preferred Strategy should provide for more housing at Rye to reflect Option 5 - Housing Needs Based figure of 1,100 dwellings.
Such development would further the objective to plan for balanced communities and support the market town role of Rye and "improve economic and social circumstances" (Box 1 Vision for Rother in 2026) and need not damage the Councils conservation and environmental objectives.
Acknowledging that the SE Plan figure of 5,600 dwellings is a minimum (paragraph 5.7) and that Rye is located within the "Sussex Coast" part of Rother the Preferred Strategy should provide for more housing at Rye to reflect Option 5 - Housing Needs Based figure of 1,100 dwellings. The need for affordable housing in Rye is acknowledged as a contributory factor to poor social and economic conditions (paragraph 8.9). There is a significant need for affordable housing in Rye (paragraph 8.22).
An average provision of 55 dwellings per annum over the 20 year period should not be too stretching a target with potential for redevelopment within the built area, the housing commitments already in Rye (including the planning permission at Udimore Road and the potential to increase housing numbers on and adjoining that site) and the Council's proposals at Rock Channel. Such development would further the objective to plan for balanced communities and support the market town role of Rye and "improve economic and social circumstances" (Box 1 Vision for Rother in 2026) and need not damage the Councils conservation and environmental objectives. The extent to which the town could accommodate such scale of development could then be assessed in detailed studies leading to the production of the Site Allocations DPD.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19293
Received: 30/01/2009
Respondent: Ian Dunlop
To propose 1,300 dwellings in the villages is to propose the destruction of the identities of these villages,to bring more cars[at least 2000 more], more noise,more traffic in the lanes, all of which will contribute to the continuing destruction of the AONB. All new dwellings should be inside the Hastings/Bexhill boundaries.
To propose 1,300 dwellings in the villages is to propose the destruction of the identities of these villages,to bring more cars[at least 2000 more], more noise,more traffic in the lanes, all of which will contribute to the continuing destruction of the AONB. All new dwellings should be inside the Hastings/Bexhill boundaries.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19333
Received: 30/01/2009
Respondent: Locate East Sussex
Overall Spatial Development Strategy
Employment (pp 23)
There is little reference to SEEDA's Regional Economic Strategy.
Locate East Sussex supports the target for a total additional supply of some 100,000 sq.m. of employment space to improve sustainable economic growth. It is appropriate that a substantial part of this additional supply be implemented through the development of proposed sites in North East Bexhill - an allocation which LES strongly supports.
Reference could be made to the continuing importance to communities of diversified farms / rural business centres.
Para 5.17 alludes to the importance of retaining employment sites and in passing to deliverability issues. A holistic strategy response is also supported.
Support
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19334
Received: 30/01/2009
Respondent: Locate East Sussex
Infrastructure availability (pp 24)
I strongly support the transport related infrastructure priorities outlined in paras 5.23 and 5.24. Improved transport will enhance the attractiveness of Rother District as a business location.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19340
Received: 30/01/2009
Respondent: Sea Space
The provision for 100,000m2 of business floorspace looks to us to be of about the right order for the needs of this area. However, it would have been helpful to include, in the supporting text, an explanation of how it has been arrived at - to demonstrate that it is consistent with the 30,000 net additional jobs by 2016 being sought for the South Coast Sub-Regional Strategy. (Although the chapter on Economy does refer to the Employment Strategy and Land Review, a summarised explanation in this document, as provided for housing, would have been useful).
Support
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19341
Received: 30/01/2009
Respondent: Sea Space
We support priority (d) focus of development in Bexhill and economic regeneration and growth in the Hastings and Bexhill area; and (e) sustainable urban extensions on the edge of Hastings.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19342
Received: 30/01/2009
Respondent: Sea Space
The projected distribution of employment space may be reasonable but, in order to achieve the overall target, we suggest a degree of flexibility is provided for. In other words, if one area proves capable of providing more, it should not be constrained from doing so as it is highly likely that there will be other areas that deliver less.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19343
Received: 30/01/2009
Respondent: Sea Space
The projected retail growth for Bexhill looks rather unambitious (we assume the comparison figure is 4,000m2 not 40,000m2) if the town centre is to thrive. Having said that, the real need in Bexhill is probably more to do with provision of larger better quality retail units, more suited to multiple retailers' requirements, than simply increasing the quantity of shops.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19344
Received: 30/01/2009
Respondent: Sea Space
We believe that the number of dwellings proposed for the Hastings Fringes is too low.
We are of the view that, although the strategy seeks to meet the housing target set out in the South East Plan, 5,600-5,850 should not be seen as a maximum if wider planning and economic arguments arise to justify going beyond that.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19385
Received: 29/01/2009
Respondent: Rother Environmental Group
Development levels. These will need to be downgraded to reflect current conditions
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19429
Received: 30/01/2009
Respondent: Mr. Mrs. Lyons
Agent: Strutt & Parker
Support is given to the promotion of sustainable urban extensions to Hastings, in collaboration with Hastings Borough Council. However, the Core Strategy relies too heavily on strategic locations at Bexhill and the west of Hastings, and economic development would benefit from
additional, smaller allocations in Hastings' eastern fringes. The allocation of smaller sites is
especially important as the more strategic sites are reliant on the delivery of the
Bexhill/Hastings Link Road. The northeast of Hastings is considered to be an equally important
location as it has good road and rail connections with Rye and the Shepway coast.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19436
Received: 30/01/2009
Respondent: Ibstock Brick Limited
The forward planning of Mineral resources falls within the MWDF: however the LDF should carefully consider the allocation of new built development so to avoid sterilization of mineral resources.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19439
Received: 30/01/2009
Respondent: Ibstock Brick Limited
The Bexhill to Hastings Link Road is noted as primary importance to facilitate the future expansion of both housing supply and employment uses. The need to raise £10.85 million locally is a major consideration (para 5.82).
The generation of local contributions will no doubt arise partially through planning gain from planned development. The importance of embracing proposed development to assist in achieving this objective is therefore highlighted.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19442
Received: 24/02/2009
Respondent: Environment Agency
It is encouraging that the 'Preferred Option' for the distribution of development follows the principle of sustainable development directing development towards existing service centres. This will reduce the reliance on the car reducing emissions and contributing to the improvement of air quality. It is encouraging that it is noted that there may be environmental impacts which will limit the potential for growth in settlements that may otherwise be suitable, such as Rye, Battle and the rural settlement of Robertsbridge, both of which have significant flood risk and land contamination constraints.
Recommendation 1:
Paragraph 5.61 - Include land contamination as a significant environmental constraint to development in Rye which coupled with the element of flood risk has the potential to result in unacceptable impact on the environment.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19464
Received: 24/02/2009
Respondent: Fairlight Parish Council
Box 3 (e) Hastings Outskirts development.
It should be clarified that this does not refer to the Fairlight (east) side of Hastings, perhaps by a cross reference Box 11a(iii)
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19498
Received: 30/01/2009
Respondent: Guestling Parish Council
Box 3 (e) "promote in concert with Hastings BC, opportunities for sustainable urban extensions on the edge of Hastings in line with a shared vision for it..." raises concerns in the Parish which have already been mentioned above
Support
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19536
Received: 25/02/2009
Respondent: Trustees of the Glyndebourne 1991 L & P Trust
Agent: Mr. Dale Mayhew
The preferred strategy for Overall Spatial Development includes giving particular attention to meeting local needs and supporting vibrant and mixed rural communities, including limiting growth for a number of villages that contain a range of services, where new development will support such services.
It is acknowledged within the Core Strategy Consultation Document that the district is a predominantly rural area. Given this, the importance of maintaining services and infrastructure in villages is fundamental to the quality of life of a significant proportion of the District's residents. Associated with this, is an average fall in household size. The consequence of this is likely to be a reduction in services and facilities in villages which do not experience housing growth over the plan period. It is therefore of importance that the Overall Spatial Development strategy acknowledges the need for growth in those villages which contain a range of services and therefore positively contribute to residents of the village and its hinterland, in order to maintain and enhance the levels of services, and so sustainability of the rural areas of the District.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19592
Received: 02/03/2009
Respondent: Evison & Company
There are acknowledged constraints on the ability of Bexhill and the market towns to absorb development. Some development will be required in villages to meet targets but also to allow them to contribute to the development of a more sustainable development in rural areas. This not only means development in rural service centres but selective growth in the smaller villages where this will support local services and modernisation of existing facilities. This may require more substantial releases of land on the edge of villages or redevelopment within existing boundaries that will permit the development of mixed communities with a range of house types and affordability and support the modernisation and improvement of run down and relatively deprived areas.
While Option 2 is supported in principle it should therefore be sufficiently flexible to allow greater growth in those villages more remote from the existing service centres which are in danger of becoming increasingly deprived and where services can only be effectively accessed by car owners.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19604
Received: 30/01/2009
Respondent: Rother and Hastings CPRE
Page 29 Box 3 This should specify sustainability for both housing and employment to underpin all ideas, focusing particularly on public transport and energy efficiency.
What do HBC think of the idea in para e)?
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19741
Received: 30/01/2009
Respondent: RSPB
It is essential that full regard is given to climate change and sea level rise when allocating major development, especially residential, around the coastal areas of the district. Areas of particular concern are Rye Harbour and Camber, which have significant and moderate levels of flood risk.
Preferred Option
Our preferred option would be to direct maximum development away from designated conservation sites and flood risk areas. Option 3 would seem to be the best choice to achieve this requirement. Until an Appropriate Assessment is undertaken that can demonstrate no adverse effect to the integrity of Natura 2000 sites no option can be endorsed.