Box 3 - Preferred Strategy for Overall Spatial Development

Comment

Representation ID: 19748

Received: 30/01/2009

Respondent: Land Securities plc

Agent: CgMs Consulting

The Preferred Strategy for Overall Spatial Development is to:
(d) "focus new development at Bexhill, giving particular attention to promoting economic regeneration and growth of the Hastings and Bexhill area, including through major mixed use developments; " .

Comments:
Land Securities is firmly committed to economic investment in Bexhill. Notwithstanding the current economic climate, Land Securities continues to receive interest from various retailers who wish to be located in Bexhill. The improved retail provision in the Bexhill area is crucial given the neighbouring centres are all expanding. Ravenside Retail Park can provide large retail units which are very limited in the town centre. The town centre's growth could be focused in providing small to medium sized retail units which are more in keeping with the Conservation Area status of the town.

Object

Representation ID: 19759

Received: 30/01/2009

Respondent: Wm. Morrison Supermarkets Plc

Agent: Peacock & Smith Ltd

Within the document, Box 3 outlines the Council's preferred strategy for the Overall Spatial Vision of the District. We note that this includes the current convenience floorspace capacities for the towns within the District. As outlined at para 2.9 of PPS6 we would comment that the Core Strategy should identify the hierarchy of centres within the District in conjunction with the already published retail need.

Object

Representation ID: 19770

Received: 30/01/2009

Respondent: East Sussex County Council

The draft strategy introduces some flexibility to emplyment provision by considering development at Rye Harbour Road. The deliverability of development (20, 000 sqm) at this location is uncertain given its lack of strategic communication links.

The Core Strategy sets out employment land requirements but not job numbers. It is difficult to discern what extent the quantity and distribution of employment land will provide for employment growth.

Comment

Representation ID: 19776

Received: 30/01/2009

Respondent: East Sussex County Council

The preferred strategy for the Economy highlights the roles of key agencies in the regeneration of the area. Emphasis is placed upon the role of the Hastings Bexhill Task Force and Sea Space in securing a step change in the local economy, in accordance with sub regional and local objectives. Whilst this approach is supported, it would be appropriate to amend the Core Strategy's overall aims, objectives and strategy to reflect the joint working with other agencies to secure the regeneration of the area.

Object

Representation ID: 19793

Received: 30/01/2009

Respondent: East Sussex County Council

Preferred strategy for overall spatial development - Box 3

Para (b):
Having regard to para 5.17 of the Secretary of State's Proposed Changes to the SEP the strategy ought to be amended to read along the lines of: "....provide for new development in a timely manner, insofar as it contributes to both strategic and local development needs, making better use of existing infrastructure and the availability of additional infrastructure capacity;"

Comment

Representation ID: 19824

Received: 04/02/2009

Respondent: Crowhurst Society

C Agreed
D Agreed
E Strongly opposed - fringe and ribbon development destroys the local countryside
Crowhurst on the edge of Wilting Development will suffer from that development.
Build a station at Wilting and that in Crowhurst will close. The closer urban development impinges on village life the fewer the services that continue to exist within the village.

Object

Representation ID: 19906

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Disappointing that SHLAA not made available at the level of development which it projects will occur. Without sight of the SHLAA, assumptions made by the Council cannot be commented on, and the robustness of the Strategy cannot be accurately assessed.

Preferred Option 2 is supported in principle, however does not take account of the constraints.It is doubtful that the projected housing numbers at the four locations as set out in the table are realistic.
Option 3 provides the clear indication of where development is likely to continue as this represents where development has recently been delivered. In all therefore, it is considered that a more realistic approach would be a hybrid of Options 2 and 3.

Support

Representation ID: 19912

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

v) Development Boundaries
Support

The preferred option is supported in that it maintains the principle of development boundaries whilst also allowing for the review of existing development boundaries through the Site Allocations DPD.

Object

Representation ID: 19917

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Section 5+ Appendix 3+ Paragraphs 9.28 - 9.29
The total approximate figures should not be treated as a ceiling, but rather as an absolute minimum to be in accordance with the South East Plan. In addition, as referred to in the Core Strategy, the estimates of development yield are subject to more detailed assessment. Croudace has concerns over the Council's calculation of the residual requirement taking into account completions and commitments, as this too is subject to further assessment. In all therefore, whilst the document refers to a residual requirement of some 400 dwellings in rural areas 2008-2026, this may not be truly representative of the current situation.

Comment

Representation ID: 19974

Received: 23/01/2009

Respondent: R & BG Properties LLP

Agent: WS Planning

'Rural Settlement - November 2008' analysed some rural settlements concluding that they would not be suitable for any development. This would appear to conflict with the Council's preferred option set out in the 'Preferred Strategy for Overall Spatial Development'.

Criterion (f) of the General Development Criteria seeks to "embrace the character and amenities of the area, especially the AONB". Whilst this is supported and the statutory duties required the LPA regarding the conserving and enhancement of the AONB are acknowledged, my clients are concerned that sites that are within the AONB should not be automatically precluded from any form of development.

Object

Representation ID: 20004

Received: 27/01/2009

Respondent: The Newcombe Estates Co. Ltd.

Agent: Martin Robeson Planning Practice

An objection is raised in relation to the Council's approach to the spatial distribution of housing figures for the district. Notwithstanding consideration of several alternative spatial distribution options the council has in our view failed to give consideration to whether a combined option may exist.

The Council appear set upon a preferred option "based largely on Option 2". It is considered that a wider range of options should be presented at this stage for further consultation.

Support

Representation ID: 20018

Received: 27/01/2009

Respondent: Mr. A. Miskin

Agent: DMH Stallard

Support the option of locating growth towards Service Centres. it is considered that land at Breadsell Farm would achieve this through its location close to Hastings, where there are a number of key services. It would also reduce the need to travel due to the opportunity to extend existing bus service routes and the potential to locate a number of community services within the site itself.

We strongly support the location of a sustainable urban extension on the Bexhill/Hastings fringe as part of the Core Strategy.

Support

Representation ID: 20120

Received: 30/01/2009

Respondent: Highways Agency

Paragraphs 5.52 to 5.65

The HA supports the 'Service Centre' option chosen for development distribution. This approach, as highlighted in paragraph 5.54 will best utilise existing transport links and help reduce the need to travel by car.

Object

Representation ID: 20139

Received: 20/01/2009

Respondent: Trinity College

Agent: Bidwells

Trinity College objects to the 'Preferred Strategy for Spatial Development' reluctance to acknowledge that the South East Plan expects housing numbers to be minima to achieve and not maximum development ceilings

Suggested change:
Trinity College suggests that the 'Preferred Strategy for Spatial Development' includes the criteria and circumstances and broad growth locations where the South East Plan's housing figures can be exceeded.

The Core Strategy could also acknowledge the need for the site allocations document to identify contingency sites to provide headroom to take account of changing circumstances.

Object

Representation ID: 20164

Received: 28/01/2009

Respondent: Persimmon Homes South East

Agent: Bell Cornwell

The policies referred to should be the most up-to-date. In this case these are the policies included in the Proposed Modifications to the South East Plan rather than to the original draft plan. There is already some inconsistency in that the numbers of dwellings referred to are those in the Proposed Modifications.

There is a lack of clarification as to how the Core Strategy boxes relate to the two main policies in the South East Plan as Proposed to be Modified.

Object

Representation ID: 20182

Received: 21/01/2009

Respondent: The National Trust

Whilst we acknowledge that the Preferred Strategy for the District is based on the draft South East Plan we do not support a strategy that requires substantial green field landtake.

We are particularly concerned at the potential greenfield landtake at Battle and Rye and the potential impact on the setting of these important historic centres.

The National Trust would strongly oppose any Core Strategy option which includes an increase in housing allocation for the District higher than that given in the final South East Plan.

Support

Representation ID: 20183

Received: 21/01/2009

Respondent: The National Trust

Supports in principle, a focus on the major urban areas of the district i.e., Hastings and Bexhill.

Object

Representation ID: 20184

Received: 21/01/2009

Respondent: The National Trust

We suggest that the Preferred Strategy as set out in Box 3, is amended to state that for Battle and Rye, it allows for development that helps to maintain the small market town roles of these centres, whilst respecting their environmental constraints and their settings.

Support

Representation ID: 20217

Received: 27/01/2009

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

The principle to promote opportunities for extensions to the urban fringe with Hastings Borough Council is supported, notably where this objective applies to land to the east of Breadsell Lane/south of Battle Road.

Comment

Representation ID: 20249

Received: 29/01/2009

Respondent: SEEDA

SEEDA supports the general direction of the Core Strategy which seeks to focus development in a hierarchical manner directing the majority of housing and employment land to the main town of Bexhill to. strengthen regeneration and growth of the Hastings/Bexhill area, followed by commensurate development of the market towns of Battle and Rye, and finally the rural villages within the High Weald AONB. While the approach employed is complimentary vis a vis Hastings, we again consider that the visions and overall spatial development strategy should be more closely aligned to the work of SeaSpace.

Object

Representation ID: 20310

Received: 30/01/2009

Respondent: Millwood Designer Homes Ltd.

Agent: Kember Loudon Williams Ltd

We consider that this approach is far too negative and places too greater weight on the physical features of Rye and its setting, and does not properly balance these against the socio-economic characteristics.

Support

Representation ID: 20338

Received: 15/01/2009

Respondent: Sussex Enterprise

The proposal for increased business space throughout Rother District that will increase the current provision by 32% until 2026 is welcomed by Sussex Enterprise. The Voice of Business Survey 2008 showed that a quarter of businesses in Sussex had found their business growth hampered by inadequate new and existing business premises, and this proposal will go some way to remedying this situation.

Object

Representation ID: 20339

Received: 15/01/2009

Respondent: Sussex Enterprise

This chronic shortage of appropriate office space, if not resolved, could constrain competiveness and growth.

Comment

Representation ID: 20340

Received: 15/01/2009

Respondent: Sussex Enterprise

Without suitable premises businesses could be forced to relocate out of the area. The rents for these premises should also be affordably priced, as 14% of businesses in East Sussex say that their rents have increased in the last 12 months. If high rents are set in the proposed office space, it may price many out of the market, leading to jobs not being created and 'sustainable economic growth' not being achieved.

Comment

Representation ID: 20341

Received: 12/01/2009

Respondent: Sussex Enterprise

Housing needs to be priced within the reach of local people. The mortgage gap in Rother is £34,553.

Support

Representation ID: 20343

Received: 12/01/2009

Respondent: Sussex Enterprise

Sussex Enterprise welcomes up to 3,300 new homes and substantial new business areas in and around Bexhill town centre.

We support a minimum of 40% affordable housing and back new housing as long as it meets these criteria.

Object

Representation ID: 20355

Received: 16/01/2009

Respondent: Messrs. R. & J.C. Stapylton-Smith

Agent: DHA Planning

Support the minimum District-wide housing requirement as set out within the Draft South East Plan.
Propose the District-wide housing distribution strategy (Para 5.66) be amended to reinforce the role, viability and function of Rural Service Centres and underpin a sustainable pattern of development within the Plan period.

Comment

Representation ID: 20395

Received: 29/01/2009

Respondent: Sussex Wildlife Trust

Is evidence available to show that development levels suggested in the South East Plan will meet local requirement? The figures appear excessive and the Draft South East Plan has assessed as failing on sustainability grounds. How has the environmental and ecological capacity of the district been assessed?

Road infrastructure has been cited as necessary to enable development (see comments re Box 4).

We support section (i) but are very concerned that sections (d), (e) and (f) conflict with this and will result in huge loss of greenfield and impact negatively on designated sites, biodiversity and the wider ecological network. There should be far greater protection and improvement of biodiversity in the area within the context of an ecological network if the aspirations of the Vision are to be realised.