MOD 9.1

Showing comments and forms 1 to 4 of 4

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21315

Received: 02/09/2013

Respondent: Devine Homes

Agent: Courtley Consultants Ltd

Representation:

The Council acknowledge that no evidence exists for the support of development at Breadsell Farm, yet has included a figure of 150 dwellings as a proportion for this site. Clearly the Council would prefer to a consider a site with NO supporting evidence yet fail to undertake its on Landscape Capacity Study that would deliver the evidence that might support a greater housing provision at other sustainable settlements e.g. Robertsbridge

Full text:

The Council acknowledge that no evidence exists for the support of development at Breadsell Farm, yet has included a figure of 150 dwellings as a proportion for this site. Clearly the Council would prefer to a consider a site with NO supporting evidence yet fail to undertake its on Landscape Capacity Study that would deliver the evidence that might support a greater housing provision at other sustainable settlements e.g. Robertsbridge

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21400

Received: 25/09/2013

Respondent: Crowhurst Parish Council

Representation:

Crowhurst Parish Council on the whole supports the modifications to the Proposed Submission Core Strategy but is very concerned about any development on the proposed Breadsell Lane site. There is no infrastructure to support such a development, Natural England do not support it and it will infringe severely on our very small village.

Full text:

Crowhurst Parish Council on the whole supports the modifications to the Proposed Submission Core Strategy but is very concerned about any development on the proposed Breadsell Lane site. There is no infrastructure to support such a development, Natural England do not support it and it will infringe severely on our very small village.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21448

Received: 27/09/2013

Respondent: Mr Alan Miskin

Agent: DMH Stallard LLP

Representation:

We consider that this paragraph is drafted too negatively and as a consequence the plan would not be effective. The plan as currently drafted is therefore not positively prepared and should be found unsound. In order to make the plan sound we consider that this paragraph should be redrafted in a more positive light on the basis that development would be possible subject to overcoming highway concerns. In addition the site should be considered suitable for development seperately, and would be a suitable allocation for development in the mid to latter part of the plan period.

Full text:

Whilst we support the recognition that Land at Breadsell Farm could form a longer term development in order to support the delivery of housing, the Paragraph as currently drafted is not sufficiently positive and leaves a significant level of doubt that an application for such would be supported. We therefore object to the paragraph as drafted as it fails to provide certainty and is not positively prepared. It is considered that this Paragraph should be a lot more positive in its stance. The paragraph is currently based on an assumption that development would not be supported and therefore would be considered negative and restrictive with regards the Council achieving its development needs. In order to be made sound, the paragraph should be based on an assumption that development would be supported subject to the provision of evidence that environmental, access to services and transport constraints could be satisfactorily addressed. This approach would generally be in line with the NPPF which sets out at Paragraph 14 a presumption in favour of sustainable development which for plan making means that Local Planning Authorities should positively seek opportunities to meet the development needs in their District. Paragraph 17 (Core Planning Principles) of the NPPF states "Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth". It is our view that in order to be sound this Paragraph should be worded more positively, in a way that would seek to overcome potential constraints to development rather than an assumption that development could not presently be supported, and so that the plan is sound in that is responds positively in respect of wider opportunities for growth.

It is generally recognised that Land at Breadsell Farm would only come forward as part of a strategic expansion west of Hastings, the significant part of this land lies within Hastings District itself. The Hastings Borough Council Local Plan is currently undergoing a period of Public Examination. It is understood that the wider area of Breadsell Farm lying within the Hastings Borough Council area is currently being promoted by the respective landowners (through their Agents) as part of the Hastings Public Examination. The wider area was initially included within the Hastings 2008 draft Core Strategy for a strategic development of 1,000 dwellings but was later removed from the Strategy due to a Natural England objection which was raised on grounds of an adjacent SSSI and potential impacts on a population of Bryophyte plants. However, the objection from Natural England was on the basis that insufficient evidence had been provided as regards the potential for residential development to have an impact on this designation, it was not an objection in principle. The landowners have subsequently submitted a detailed Surface Water Strategy which includes detailed technical mitigation measures which seek to overcome the Natural England objection. The landowners are hopeful of being able to resolve these issues through a mitigation strategy. We support the landowners (and their Agents) stance and reiterate again the points made within the NPPF that Local Planning Authorities should plan positively to meet the needs of their District. In particular, there are a number of environmental issues throughout Rother and Hastings District, the most significant of which being the large expanse of the Area of Outstanding Natural Beauty (AONB) which restricts development. An extension west of Hastings is one of a few opportunities to provide a sustainable strategic development within the two Districts. It is considered that it would be possible to be more positive in allocating the site subject to the submission of appropriate technical evidence relating to drainage and the withdrawal of Natural England's objection.

It is recognised that the wider area of land can only be allocated by Hastings Borough Council, however, the duty to cooperate should be recognised. Both authorities are part of the same 'Housing Market Area' and subsequently should be jointly working to achieve the development needs within this area. An urban extension west of Hastings is considered the only viable option to provide the significant level of housing need within Hastings (due to other significant development constraints, notably the Area of Outstanding Natural Beauty), and Rother should support this proposal through a positive stance within its own Core Strategy. It is considered that land at Breadsell Farm should be allocated within the forthcoming Development Management strategy in order to ensure that the long term housing needs are met. This would be acting positively in order to meet the development needs of the District as required by the NPPF and therefore would assist in delivering a sound plan.

Although a strategic extension of Hastings to include land at Breadsell Farm is supported, it is also considered that the site itself is suitable for development separately in order to ensure that Rother District Council are able to meet their housing requirements within the Hastings Fringe area. Land at Breadsell Farm could accommodate up to 350 dwellings, 40% of which would be affordable. A proposal which was previously put forward through the 2003 Local Plan inquiry shows that the site could comfortably accommodate 250 dwellings with an extensive landscaping strategy and leisure provision. There's no reason to assume that the site would necessarily be unsustainable, as indicated within this paragraph as amended.

Any development would be easily accessible from Hastings road, which runs along the northern boundary of the site. The site access options have been considered within a technical note written by Motion Transport Planning. The Technical Note indicates that a number of options would be acceptable in order to provide access to the site from Hastings Road. The road is served by frequent bus services, giving access to the surrounding towns, including Crowhurst Railway Station. The site is within easy access of shops in Battle, a superstore on John Macadem Way and primary and secondary schools. The site is, in our view, within a sustainable location that would support residential development. In addition, residential development itself would support further infrastructure, shops and services within the local area.

In order for the Core Strategy to be found sound, it is our view that this paragraph should be amended to recognise that the allocation of a development at Breadsell Farm could be achievable as a single entity subject to overcoming highway constraints. At present, the Core Strategy identified the need for 100 - 250 dwellings to the urban fringe of Hastings. However, it does not identify how this figure could be met. By allocating land at Breadsell Farm the requirement for 250 dwellings would be achievable and would ensure that the Core Strategy is sound by making provision for the development needs within the District. If land at Breadsell Farm is not allocated then it is questioned how up to 250 dwellings to the Hastings Fringe could be provided. In order to support the possibility of development at Breadsell Farm this paragraph ought to be amended to read in a more positive fashion, identifying that the land would be suitable, subject to overcoming relevant constraints, for development either on its own or as part of a strategic extension of West Hastings.

It is envisaged that this development could be secured through an allocation that would provide for an urban extension in this area within the mid to latter part of the plan period.

Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21508

Received: 23/09/2013

Respondent: Strategic Land Kent Ltd

Representation:

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

Full text:

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'