Appendix 4: Key Design Principles

Showing comments and forms 1 to 2 of 2

Support

Proposed Submission Core Strategy

Representation ID: 20977

Received: 11/11/2011

Respondent: Mr Richard Comotto

Representation Summary:

This is so important that it needs to be expanded and elaborated into a working document for planners and developers.

Full text:

This is so important that it needs to be expanded and elaborated into a working document for planners and developers.

Object

Proposed Submission Core Strategy

Representation ID: 21013

Received: 11/11/2011

Respondent: Marchfield Strategic Land Ltd

Agent: JB Planning Associates Ltd.

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Core Strategy lacks any robust assessment of the inter-relationship between infrastructure and the Spatial Strategy. The supporting text to Policy IM2 refers to an Appendix 4 that does not exist, and the separate background paper on infrastructure delivery fails to clearly identify the 'critical' infrastructure upon which the Core Strategy depends, and fails to set out (or justify) the relationship between the stated infrastructure projects identified in the background paper and the delivery of the Spatial Strategy in the Core Strategy.

Full text:

Policy IM2 starts by setting out a general statement to the effect that the infrastructure needed to serve new development should be provided by that development. On a case by case basis, this is obviously common practice, and is achieved through the normal development control basis.

Paragraph 19.17 of the supporting text notes that to comply with PPS12, the Core Strategy needs to demonstrate that the essential infrastructure required to deliver the Spatial Strategy as a whole can be delivered, but the Core Strategy is in fact largely silent on the overall strategic infrastructure requirement.

Paragraph 19.18 states that Appendix 4 of the Core Strategy sets out an Infrastructure Schedule, but no such schedule exists, and Appendix 4 is actually an appendix on Design Principles.

Policy IM2 and its supporting text therefore relies solely on the separate Infrastructure Delivery Plan to explain the strategic infrastructure requirements, but this is a document not forming part of the Core Strategy and therefore technically not part of the Examination, and it is also a 'live' document which is subject to change. As a result, the Core Strategy itself fails to explain anywhere what the essential infrastructure is, or link this in any justified or meaningful way to the Spatial Strategy.

The Infrastructure Delivery Plan (IDP) itself provides an interesting discussion around various potential infrastructure requirements, but it is frequently inconclusive in terms of what might be required. The discussion, for example, in relation to strategic and local health facilities on pages 43 and 44 provides a good example, where the outcome of the IDP essentially appears to be "don't know" and the result is Policy CO2 which refers generally to meeting future health needs should they arise, without any assessment or knowledge as to what these may be.

Many of the topic areas in the IDP are similarly inconclusive, and therefore do not translate either in to effective policies are clear position statements as to the implications of that infrastructure on the development strategy.

Elsewhere, the IDP does appear to come to firm conclusions as to the need for specific items of infrastructure, but there is no evidence to substantiate the conclusion, with the Bexhill-Hastings Link Road being a good example.

Furthermore, even where the IDP does identify specific items of infrastructure, there is no explanation as to what the effective limitation on the Spatial Strategy is without that infrastructure in place. Again, the Bexhill-Hastings Link Road is a good example. It is identified as being of 'high' importance, but the IDP does not specify the practical effects of it not being delivered, and indeed from Policies such as OSS2 (iii) (b) it is apparent that the Council do not as yet know the effects, since this part of Policy BX3 makes clear that in the absence of the Link Road, the assessment has yet to be done as to the scale of development that might otherwise be achieved.

On a point of clarity, the IDP states at section 9 (page 13) that part of its purpose is to clearly identify what is 'critical' as opposed to 'desirable' infrastructure, but then the subsequent use of the terms 'high', 'medium' and 'low' to describe the importance of infrastructure serves to obscure the distinction between critical and desirable items.

Throughout the IDP, we would question the manner in which the Council has applied the 'high', 'medium' and 'low' terminology. For example, the second item on infrastructure (sustainable modes of travel) lists Bexhill Real Time passenger information as one part of a package of measures, all of which are identified as being 'high'. Does that mean that if there is no Real Time passenger information, all development in Bexhill must stop, because of a lack of "critical" infrastructure?

Under the next item, a Glyne Gap railway station is identified as being of "medium" importance, but there is no real explanation as to whether this is actually 'critical' or 'desirable' infrastructure, and when one consults the IDP text on this item (see para 13.21 on page 27), it appears that there is in fact very little likelihood of such a scheme ever being delivered.

Another key concern with the IDP is the large number of items where the costs and funding arrangements are "TBC", which therefore provides no clarity at all as to whether the required infrastructure would be delivered.

It would be somewhat tedious to go through the schedules in the IDP in line by line detail, but in addition to the above, the most obvious concern is that the IDP does not, in fact, explain the consequential relationship between the specific items of infrastructure and the delivery of the Spatial Strategy, and without this clear 'cause and effect' linkage, the IDP cannot provide any confidence that the Core Strategy is deliverable.

In our view, it is at least in part because the Core Strategy has failed to set out clear and justified 'triggers' for infrastructure delivery that the strategy has been so heavily influenced by the perceived constraints in highways infrastructure associated with the Council's promotion of the Bexhill-Hastings Link Road.

Having regard to the above, we consider that Policy IM2, coupled with the lack of a clear infrastructure delivery assessment setting out the critical thresholds and requirements for infrastructure, render the Core Strategy unsound in terms of being both Effective and consistent with National Policy, whilst in addition, many of the IDP entries appear unjustified.