10.14

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Object

Proposed Submission Core Strategy

Representation ID: 20822

Received: 26/09/2011

Respondent: John Jempson and Son Ltd

Agent: Mr Christopher Atkinson

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Acknowledgement of seasonal economy can be found in the supporting text but not translated into the policies in RY1.

Delivery of housing in Rye is subject to the key sites coming forward like Rock Channel. The relocation of existing uses on the site would be subject to finding a suitable alternative site near good transport links. The recession has impacted on the potential for relocation.

Inconsistency with RY1 and EC3. Housing at Rock Channel would require the relocation of employment uses and would be in conflict with EC3 which seeks to retains existing employment sites. No policy support in RY1 for existing employment uses. Consideration of changes to text.

Full text:

The Core Strategy identifies a weakness in the local economy arising from high seasonal unemployment (10.4). This means that employers offering year-round employment have particular importance and while this is implied via the text, it is not acknowledged via the policy objectives or policy RY1.

Policy RY1 relies upon existing commitments, including allocations, within the built up area for the provision of 250-350 new dwellings. The largest of the allocations is Rock Channel, which includes the operating centre of John Jempson & Sons Ltd, a transport business and one of the town's major employers. Discussions held with the LPA during the period 2007-9 indicated the company's willingness to relocate at that time should a suitable site closer to the national motorway network be made available. No such site was available then, and no such location is identified via policy EC2, which refers only to small-medium size sites and units at towns and villages in the A21 corridor (EC2(iii)). Since the discussions were concluded, economic circumstances have led to the company taking the view that relocation at the present time would not be a viable option.

Policy RY1 is inconsistent with policy EC3, which seeks to protect existing employment sites. It does not offer support for existing businesses, but instead undermines them by implicitly reaffirming the reallocation of major employment sites within the urban area for other uses, while making no provision for the satisfactory accommodation of businesses that would be displaced. It is clear that the evidence upon which the policy is based, most notably the SHLAA, does not take sufficient account of the likelihood of all or part of the Rock Channel allocation not coming forward during the plan period.

The policy is unsound because it relies upon the loss of major employment uses to achieve the housing requirement for the town, thereby being in conflict with Policy EC3, which offers long term protection to such sites. Furthermore, Policy RY1 does not make any provision for supporting existing employment uses, which are particularly important to the local economy because of the high seasonal unemployment that arises from the reliance of the local economy upon tourism-based employment.

The policy does not lend sufficient support to existing business uses, as required by the NPPF Draft dated July 2011.