MOD 7.10

On behalf of the landowner, Mr Colin Simmons, we welcome the additional text inserted in respect of land at Breadsell Lane, in particular that residential development should not be ruled out.

We acknowledge that the largest portion of the site falls within Hastings Borough and that therefore that it is for Hastings Borough Council to lead on any future allocation for the site. However, it is important that the background context is clear for the purpose of considering the implications for the Rother Strategy.

The Hastings Core Strategy 'Preferred Approaches' Document (2008) identified Mr Simmons' land at Breadsell Lane as part of a major Greenfield site that had genuine prospects to provide new homes during the Local Plan period (approx. 450 units in Hastings and 150 units in Rother). Within this Preferred Approaches Consultation there was an unambiguous acknowledgement by the Council that a development of this land would provide the very best opportunities for providing essential infrastructure, such as improved transport, community and recreational facilities. It was also acknowledged that a large site would provide opportunities for higher standards of sustainable design and construction, which would assist in combating climate change during the plan period. Essentially, it was stated that Breadsell Lane was the most sustainable option available for providing large-scale new housing.

However, as a result of a Natural England 'holding objection' in respect of the hydrology of the site (highlighting the need for further baseline monitoring of the existing baseline conditions), HBC abandoned its stance and deleted Breadsell Lane as a potential allocation.

We maintain our view that the removal of the site due to Natural England's objection has not been justified in evidence and that the Hastings Strategy is unsound - which we continue to argue is the case through the Hastings Strategy Examination.

Notwithstanding the disparity with HBC on hydrology, we do consider sufficient previous assessment has been undertaken, particularly through the SA process, to demonstrate to the sustainability credentials of developing Breadsell Lane. We therefore consider that Main Modification 7.10 of the Rother Strategy should be restricted to the sole area of outstanding dispute, and be amended to read:

'While current evidence does not support the identification of development at Breadsell Farm, given the housing land supply position, relevant policies are framed in such a way as to not rule out the longer-term prospect of a sustainable scheme if the hydrology impacts are satisfactorily addressed'.

Finally, unlike the Hastings Strategy, we do not consider this a matter that goes to the heart of whether the Rother Strategy is 'sound'. However, we would reiterate that land at Breadsell Lane is the only large greenfield opportunity, not located within a protected Area of Outstanding Natural Beauty, that could provide a valuable strategic housing contribution for both the Rother DC and HBC market area.

Whilst the decision to exclude it only because of a 'holding objection' certainly renders the Hastings Strategy unsound, a negative approach to the site would continue to have an adverse impact for Rother DC by restricting a valuable 150 new homes.

We are pleased that the document no takes on board the thrust of the new LPPF document and no longer refers to the defuncy South East Plan. The increases in housing supply are welcomed which will aid to create a more prosperous local economy which will in turn be significantly beneficial to local communities.

MOD2.2 The inserted text is welcomed but we see no necessity for the final sentence which makes reference to the South East Plan which is no longer applicable, by referencing it as a document only causes unnecessary confusion. Future infrastructure investment should now be based on the new LocalPlan. The final sentence should be deleted.

MOD 7.1 The new reference to the 4,800 dwellings as set out in the South East Plan is unnecessary.

MOD 7.5 The increased supply to at least 5,700 is to be welcomed.

MOD-7.6 We seek to alter the proposed paragraph 7.30 as follows: (changes in CAPS)

7.30 This growth is justified primarily in terms of COMPLYING WITH THE NPPF TO INCREASE HOUSING SUPPLY AND contributing to the projected demand for new homes, as well as in meeting the local need for housing and the need to support economic regeneration. The possibility of further opportunities for sustainable housing (as well as employment) development arising over time is A DISTINCT POSSIBILITY; hence the requirement is expressed as a minimum QUANTUM for the purposes of plan making. These will be further assessed as part of site allocations/neighbourhood planning processes.

MOD 7.9 With regard to the additional sentence; please consider adding 'modest' prior to 'potential' and insert 'detailed' prior to 'assessment'.

MOD 7.10 Please delete the additional modification as it is not necessary.

MOD 7.12 The increased housing provision figures at 5,700 are welcome as a minimum provision.

MOD 7.13 After the words 'sites are assessed' please add 'or subject to planning applications'.

MOD 7.14 Figure 8; the increase for the Villages to have 1,670 dwellings is welcomed.

MOD 7.18. At the proposed paragraph 7.57 the Council is taking windfalls into account. In terms of making an assessment of the 5 year land supply, is the Council making an allowance for the non­ implementation of planning permissions. We suggest that a percentage figure based on evidence be used in order to have a fair methodology.

MOD 8.5. Add on to the modification 'and that this delivery rate will be monitored on an annual basis'.

MOD 8.7. Delete 'support' or 'deliver' and add on to the final sentence 'or to allocate fresh housing land via planning permissions or alternative allocations'.

MOD 8.10. Delete 'marginal but critical' for 'strategically important'.

MOD 9.1 We object to the inclusion of the modification and seek that it be deleted.

MOD 12.4. We support the additional dwelling supply.

MOD 12.6. After 'Neighbourhood Plans', please add on 'or newly approved planning permissions'