Policy BX2: Bexhill Town Centre

Bexhill Town Centre is an important place, providing shops, services, jobs and homes to residents of the town. It is a complex place and therefore it is appropriate, in principle, for the Core Strategy to include a policy relating to it. Draft Policy BX2 promotes appropriate uses within the centre, along with a related approach to movement around it and to the design and development within it.

The draft policy draws upon research undertaken to quantify shopping needs and recognises that it is highly unlikely that such provision can be met within the Town Centre. Accordingly, edge of centre expansion to the north of the railway is proposed. This is consistent with, but less detailed than paragraph 8.38. Our clients own commercial land at Beeching Road which is now of poor quality for industrial purposes. They consider that it can be brought forward for redevelopment to meet needs for retail development identified at BX2(iii) and paragraph 8.38. Therefore, they consider that the approach of the Core Strategy towards Bexhill Town Centre is both sound and deliverable.

My comments relate to Para.3 Spatial Strategies Section 8 Bexhill

Whilst commending the overall format of the proposed Submission Core Strategy I find that Policy BX2 Bexhill Town Centre (Page 50) is really stating the obvious, and much of it has been expressed in one way or another, in newspaper articles and Council reports, for a number of years, as well as at Bexhill Town Forum meetings. But little to no progress has been made on them.

Whilst Strategy for Development (Page 51) is again reiterated the dependence upon the LINK road is a cause for concern - for the road to be constructed, in a sense, leads to 'no-where' at the Hastings end.

Meanwhile the overall parking facilities etc. still remain an on-going problem in Bexhill Town Centre. Some years ago plans were published of the railway station offices being removed to Devonshire Square, with a bridge over to Terminus Road, and the prospect of a multi/2storey car park being agreed with Sainsburys, but presumably that no longer is a possibility!

Para's (i)to (vi) are not written in crystal clear English. Para (i) is a hotchpotch of ideas which somehow makes out that after n years the RDC has only just thought of having a co-ordinated town centre initiative, whatever that is supposed to mean, when it should have been an ongoing activity for a standing committee. Para (ii) makes what I would call good commonsense and can be seen as an ongoing activity of improvement. Why should this be considered a proposal? You might say that many of these proposals are the daily responsibilities of a properly run council.

Policy BX2 does nothing to protect the existing office use in the town centre as does RDLP BX7. It is therefore unsound because it is unable to be effective and cannot therefore comply with current national policy. It is also unjustified because there has not been enough consultation with residents and businesses. It consequently cannot comply with national policy in particular the Sustainable Communities Act 2007.

Policy BX2(i) is imprecise and therefore open to abuse. It is unsound because it is unjustified, not effective, lacks an overall vision for the town and does not comply with current national policy, in particular PPS12: Local Spatial Planning.

The reference to "increased parking capacity" is dealt with in BX2(ii) so there is no need for it to appear here too.

Policy BX2(iii) omits any reference to an important valued asset of Bexhill. It does nothing to safeguard the existing shop use within the town centre of Bexhill, predominantly already highly regarded small independents. Such a strategy is therefore open to abuse. It is unsound because it is not justified, not effective, lacks an overall vision for the town centre and does not comply with current local policies RDLP BX5 and EM13 and also regional and national policies, particularly the Government's presumption in favour of sustainable development in the forthcoming National Planning Policy Framework.

Policy BX2(v) is imprecise and too general. It does nothing to protect the existing Conservation Area of the town centre and surrounding area. There is also no mention of 'sustainability'. Such a strategy is unsound because it is unjustified and not effective. It lacks an overall vision for the town centre as it presumes development without any protection to the heritage and character. It therefore does not comply with current local, regional and national policies, particularly the Government's presumption in favour of sustainable development in the forthcoming National Planning Policy Framework and PPS 5: Planning for the Historic Environment.

Policy BX2(vi) does not make adequate provision for protection of conservation areas, all listed buildings and valued open spaces as recognised as a top priority in the Bexhill Local Action Plan 2010, the previous November 2008 draft version of this Core Strategy and the RDLP. It is therefore an unsound policy as it is not justified, not effective and also not consistent with national policy as well as local and regional policies.

BX2(vi) is too vague as there are important buildings and places of public value (including open spaces) outside as well as inside the Conservation Area.

The Strategy for Bexhill Town Centre is to:

(iii) 'Provide for some 2,500 sqm additional convenience goods and 4,000 sqm comparison goods floorspace, primarily through 'edge of centre' retail expansion on the north side of the railway, as well as effective use of town centre accommodation.'

Paragraph 8.38

Supporting text of Policy BX2 sets out that "north side of the railway" will include the area from Sea Road through to Terminus Road, including the southern end of Beeching Road.

Comments:

Policy EC3 of PPS4 states local planning authorities should set out a strategy for the management and growth of centres over the plan period by (a) setting flexible policies for their centres which are able to respond to changing economic circumstances and encourage, where appropriate, high-density development accessible by public transport, walking and cycling.

We consider that policies in the Core Strategy should be flexible and feasible to meet the short, medium and long term demand.

There is currently no scheme coming forward to develop the identified land at north side of the railway for retail development. The certainty and timescale of delivery for this edge of centre site remains unknown and this site is unlikely to be available in the short or medium term. In order to be consistent with the objectives of national policy PPS4, Policy BX2 should allow retail provision to meet the short and medium term demand, subject to the sequential assessment as set out in PPS4 Policy EC15.

In addition, local planning authorities should also consider setting floorspace thresholds for the scale of edge of centre and out of centre developments which should be subject to an impact assessment under (EC16.1 of PPS4) and specify the geographic areas these thresholds will apply to as set out in EC3d of PPS4.