FA23

(OSS1 & BX3)

The main changes to the Sustainability Appraisal have been considered. The SA's changes related to the Appropriate Assessment (Section 3.13) and clarifications of the other key supporting evidence underpinning the Core Strategy and Sustainability Appraisal (Section 3.15) are noted.
The SA's other main changes related to the Plan Options (Section 5) have been carefully considered. Trinity College consider that it is appropriate for the SA to clearly document the Council's process of option identification, consideration and testing. Trinity College also consider it important for the SA to clearly set out the process for identifying the chosen option, after an assessment of other reasonable options in a transparent way.
Trinity College supports the SA's process of options identification and appraisal. It is considered to represent a robust and comprehensive approach and justifies the Core Strategy's (Submission Version) Spatial Strategy. The changes to Section 5 clearly document the process that the Council has employed to undertake the options appraisal.
The changes to Section 5 clearly document the Council's SA conclusions. Trinity College's comments are: that the SA conclusion that 'ring fencing' development in Bexhill (Option A2) is the most sustainable option is supported; the SA conclusion to take forward a lower rate of development in the District than directed in the South East Plan (B2) is noted. The SA conclusion that focussing large scale development at North East Bexhill (Option C1) represents the most sustainable option is supported. The SA conclusion that the Bexhill Scale of Growth is reduced to take account of delays in the delivery of the Link Road (D1) is noted.
Overall, Trinity College supports the SA's conclusion that the Core Strategy's Spatial Strategy of taking forward the current Local Plan strategy of allocating 1,300 homes and 50,000 sqm of business floorspace at North East Bexhill represents the most sustainable development option when compared against the reasonable alternatives (Section 5.4.2y).
Trinity College can confirm that it is committed to working with the Council and its partners to ensure the timely delivery of development on land in its control at North East Bexhill. Since confirmation of the Link Road's funding in March 2012 (subject to potential legal challenge), progress is being made to identify a developer/promoter partner to bring forward development proposals for the land, in line with the Adopted Local Plan and emerging Core Strategy.

1. With regard to the identification and description of the strategic options considered and how they were identified, substantial new information and commentary is provided by the focused amendments, which goes some way to addressing the points set out in our representations made previously at Proposed Submission Stage. However, where necessary, we will reiterate and will rely on our earlier representations at the Examination.
2. With regard to our more detailed representations on the assessment of the different options, the focused amendments do not, in the main, address the points set out in our representations made previously at Proposed Submission Stage (particularly those points set out at paras 11-30 of our representations). We therefore reiterate and will rely on those earlier representations at the Examination.
3. With regard to the additional commentary added in the focused amendments to the assessment of Option C2:
i. Item 11: The detailed additional commentary now provided highlights many potential positives of locating development at West Bexhill, however it then suggests that there would be local opposition to large renewable energy installations that, quite simply, are not relevant to the scale of development envisaged. It further suggests that there would be limited options available to achieve Code for Sustainable Homes Level 6, however this is a level that is far beyond what the Core Strategy requires.
ii. Item 13: The detailed additional commentary now provided appears even more skewed than the previous text. Despite the "Pevensey Levels Appropriate Assessment ... [concluding that] ... if its recommendations for mitigation are followed the ... Core Strategies will not have an adverse effect on the Pevensey Levels Ramsar Site", the additional commentary then disingenuously states that "the possibility of minor adverse impacts has to be acknowledged". (Our emphasis.) This contradiction is clearly unhelpful and misleading.
4. The above refers to the following elements of the Core Strategy:
Spatial Vision (Chapter 5, page 23)
Overall Spatial Strategy - Policy OSS1 (Chapter 7, page 34)
Bexhill to Hastings Link Road - Policy OSS2 (Chapter 7, page 38)
Bexhill Development Strategy - Policy BX3 and Paragraph 8.54 (Chapter 8, pages 52 and 53)
Recreation Facilities - Policy CO3 and Paragraph 14.28 (Chapter 14, page 105)
Affordable Housing - Policy LHN2 and Paragraph 15.24 (Chapter 15, pages 118-119)
Implementation and Infrastructure - Policy IM2 and Appendix 4 (Chapter 19, page 165)
5. For the sake of clarification and confirmation, the focused amendments to the Proposed Submission Core Strategy do not address the points set out in our representations made previously at Proposed Submission Stage. We therefore reiterate and will rely on those earlier representations at the Examination.