Policy RY1: Policy Framework for Rye and Rye Harbour

In earlier rounds of consultation the 450 dwellings were allocated for Rye as part of the plan period. Whilst I appreciate that Rye is constrained by a number of factors outlined in the Core Strategy, I do not consider that enough evidence has been prepared to justify a reduction in dwellings over the plan period to 250-350. Given the good transport links around Rye and to re-affirm its position as a main settlement in Rother I consider 450 to be the appropriate figure for growth over the plan period.

The current problems with deliverability of the existing allocated sites within Rye have correctly been highlighted by the Council. As such I have concern that the allocation cannot be met from the existing sites referenced by the Council, as not all of the dwellings allocated are deliverable. I am aware that this matter will be given due consideration at the Site Specifics stage, however I think the Core Strategy needs to make provision for a modest amount of growth outside of the brownfield town centre sites. The only sensible area for this growth would be in and around Playden to the north of Rye town centre, which is outside of the flood zone and less constrained by transport and congestion yet still within a walking distance to Rye town centre.

Part of this should include incorporating Playden within the Development Boundary of Rye, although I am aware that this will be given more detailed consideration at the Site Specific stage of the process.

For information although my address is in Hertfordshire, the representation is made on behalf of family members that live in Rye.

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.

We note that EN3 (ii) refers to Appendix 4 that has some more detail on what is expected to be addressed under each of the headings (a) to (h) of the policy.

We support the general principles outlined in the Appendix 4(h), however we note that it references back to Chapter 13 Sustainable Resource Management, so subject to Policy SRM2 being amended as suggested above, clearly this part of Policy EN3's effectiveness, in our opinion, will be dependent on our proposed minor changes to SRM2 being incorporated.

Refer to my comments made on policy EC1.

While (xi) refers to cultural assets we do not consider that this is strong enough to cover the recommendations that we have made in respect of Rye's cultural offering.

Introduction

1.1 It is considered that the proposed Policy Strategy for Rye and Rye Harbour as set out in Policy RY1 is unsound for the following reasons:

* The Policy is not 'effective' in that it will not deliver the type, scale and nature of development that is needed to secure the long term social and economic needs of the town.
* The role that Rye can play in the delivery of housing in the district is underestimated in that the generalised reference to the environmental constraints surrounding the town is unjustified, and inadequate consideration has been given to how existing sites within the built up area can be delivered.
* Too much emphasis is placed on additional employment development in Rye Harbour Road Industrial Estate, which is both unlikely to be deliverable and contrary to the air quality constraints set by the Habitat Regulations.
* The policy is not sufficiently flexible to allow for development opportunities in and around the town that would contribute to the delivery of the key objective of the town, which is to provide more and better quality employment and housing.

2.0 Housing Provision

2.1 A key presumption that underlies the Core Strategy is that the Hastings-Bexhill Relief Road will be built within the plan period. This would facilitate significant development at Bexhill that will help to provide the amount of housing land needed to meet the demand for housing in the District. It is clear from the Council's Infrastructure Delivery Plan that while there is a desire for the road to go forward, there is no certainty that it will.

2.2 The implementation of the road is dependent on the provision of public funding, and there is no certainty that the necessary funds will come forward. Further submissions are being made to the Government by East Sussex County Council at the end of 2011 and a decision will be made some time in 2012. Given that a key element of the Core Strategy is based on an eventuality that is, as yet, unknown and uncertain, it must be unsound.

2.3 The constraints that have been identified as restricting the development opportunities at Rye have been over-stated. There are opportunities for development on the edge of the town that will not harm any statutory designations or cause any material erosion of the topographical and landscape context. They will enable the provision of more housing in the town and facilitate economic investment that the town will otherwise find it difficult to attract.

2.4 Policy RY1 should be amended to allow such development to come forward. In this context the number of dwellings that can be provided at the town should be increased to 350-450.

2.5 This will allow greater flexibility in the provision of housing in the District in the light of the uncertainty over the future of the Hastings-Bexhill Link Road. Furthermore, the market for good quality housing in Rye is much stronger than the general housing market in Bexhill, therefore there is a greater likelihood that this housing will come forward within the plan period.

3.0 Economic Development

3.1 The policy is unjustified in relying on the promotion of 10,000 square metres of employment floorspace at Rye Harbour Road to provide economic regeneration for the town. Such development would contribute to the further visual intrusion into the open land between Rye and Rye Harbour. Being in the centre of the gap between the two settlements, further development in this location is much more visually intrusive than modest urban extensions.

3.2 There are significant opportunities to foster economic regeneration close to and within the built up area of the town, particularly adjacent to Rock Channel. These require a more imaginative and innovative form of development than is envisaged in the current policy. A wider range of more deliverable opportunities is required to address the significant pockets of social and economic deprivation within the town.

Broad development areas in Bexhill, Hastings Fringe, Battle, Rye and surrounding villages are identified within the Core Strategy. The scale of development in Bexhill is dependent on the delivery of the BHLR. In the event that the link road is not constructed we support the policies that set out that the level of development at Bexhill will be reduced.

We are pleased to note that proposals within the broad development areas include plans to improve sustainable transport links within and between urban centres. We welcome this approach as it could help reduce development impact on the SRN and is therefore welcomed.

This policy should be amended in order to first of all accept that provision should be made for at least 450 dwellings. The under-provision of housing not only creates its own problems, but also stifles economic development. In current circumstances, such a stance is unrealistic and unacceptable.

Policy RY1: Policy Framework for Rye and Rye Harbour
The supporting text 10.20 raises a number of concerns and measures to address these issues
10.20 "It is acknowledged that there is a requirement for the sensitive management of tourism (from local sources and those further afield) in the Dungeness complex of internationally important wildlife sites. To retain their conservation status and preserve their integrity there will be requirement for effective management measures to be implemented and agreed with the
relevant stakeholders and agencies in parallel with the promotion of future tourism and recreational activity in the area around the Dungeness international sites. These may include increased wardening, dissemination of guidelines/advice to the public, screening of recreational activities, changes in site access/routing of footpaths or managing visitor numbers to areas of interest and will also involve the implementation of appropriate monitoring arrangements and the development of a sustainable access strategy to manage visitor numbers in order to ensure that increased recreational activity does not lead to an adverse effect on the integrity of the sites."
Policy RY1: Policy Framework for Rye and Rye Harbour
(viii) Maintain and enhance navigation on the River Rother and the viability of the Port of Rye as a working harbour, having particular regard to protecting the integrity of internationally designated habitats;
(ix) Promote green tourism initiatives, including careful management of the Rye
Harbour Nature Reserve, which protect the integrity, and where possible enhance the internationally important ecological interests;
Generally Natural England is satisfied with this policy and supportive text in relation to Rye Harbour, tourism and the N2K sites. We would just like clarity around the wording „enhance‟ for bullet (viii). Does this cover future development and expansion at the harbour? This could be made clearer perhaps.
Bullet (ix) should also contain some wording to hook in some of the measures that may be required to protect the N2K sites from tourism and recreation as outline in the supportive text 10.20.
Clarification is needed as to whether, within the Rye Harbour area, green tourism at Camber sands and Broomhill frontages are considered. These experience heavy usage from recreation and leisure pursuits and may require a suite of measures to address these issues should the impact increase towards significant levels.
Section 10.20 goes a long way to describing the type of monitoring and strategic approach required to protect the integrity of Natura 2000 sites in this and the neighbouring district of Shepway. A collaborative program would be the way forward on this and a policy hook in this policy on Rye, the general tourism policy and other related site policies that include designated sites needs to be included.
Finally in addition to the mention of Natura 2000 sites in relation to impacts from development and tourism it would be good to see a policy point here that is about enhancing these areas for their own value this may tie into the policy wording of the Romney Marsh BOA highlighted in the biodiversity policy but it would be good to provide a spatial reference in the plan.