QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

The following comments, related to biodiversity matters, are made on behalf of the Sussex Wildlife Trust.

If a question from the consultation is not included below, please assume that the Trust has no comments to make at this time.

PART B: DEVELOPMENT POLICIES

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside and the need to ensure that these features are safeguarded. In relation to this we highlight that in paragraph 7.16 the last sentence states 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining to add clarity.

We are concerned about equestrian developments being proposed on designated sites such as Local Wildlife Sites. Therefore we welcome an approach to more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per National Planning Policy Framework ( NPPF) section 165.

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Creative approaches and orientation should be considered when designing external spaces. Their setting within the green infrastructure aspirations of the District should be looked at during the planning application stage. This would ensure a holistic and considered approach to green infrastructure.

While bullet point (i) gives clarity to the external spaces of dwellings of 3 or more bedrooms, there is a lack of commitment to the amount of space need for flat and complex developments. The last sentence of this bullet point states that, 'an appropriate level of usable community and amenity space should be provided'. We are concerned that this statement does not give the decision maker a clear enough direction for its interpretation.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF section 109. The council may find the RHS advice leaflet useful www.rhs.org.uk/advice/profile?PID=738

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF section 118 'Opportunities to incorporate biodiversity in and around developments should be encouraged'.

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed policies? If not, what changes would you wish to see?

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Figure 7 demonstrates that an area of the existing Bexhill and Hastings/St Leonards green gaps is proposed to be removed from the strategic gap. However the supporting text (10.19 - 10.21) does not indicate the reasons for the exclusion. We feel the supporting text for this section would benefit from a brief explanation for the reason in inclusion or exclusion of areas.

We ask the council to consider the value of the strategic gaps in harnessing the district's natural capital. This natural capital will be delivering vital ecosystem services to the district and potentially to the authorities adjoining Rother District. Therefore we would suggest that this is reflected in the policy wording by:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'

We believe this additional wording will reflect the importance of strategic gaps for ecosystems service delivery and will also enable the policy to sit in line with NPPF para 109.

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

We are encouraged by the manner in which the supporting text for this policy has been approached. The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to the wording and ethos of Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed. The proposal is either supported in full or it is not, 'in principle' adds nothing to the policy.

Part ii - the word 'significant' should be removed. All developments should aim to avoid harm to biodiversity.

Part iii - should look to reflect the sentiments of the NPPF section 109. The first sentence should be amended to read:
'In addition to ( ii) above , all developments will be expected to deliver net gain to biodiversity by retaining and enhancing biodiversity in a manner appropriate to the local context ....'

Part iv has a requirement for 'larger developments of more than 2 hectare or 50 dwellings...' to produce a green infrastructure (GI) masterplan'. Looking at the allocations, very few meet this requirement. We recognise that there are some larger allocations around Bexhill where we would certainly support the need to produce GI masterplans but we are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings. We also recommend that the policy requires all development to contribute to the aspirations of Rother's Green Infrastructure Strategy.

We suggest that Rother District Council include an Ancient Woodland policy within the Local Plan. This would reflect the ethos of the NPPF which clearly states in section 117:
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?

Reviewing the supporting text and policy wording there is no recognition of Pevensey and Pett being low lying areas (below sea level) and the associated risk of sea and ground water flooding. We suggest that this is included.

QUESTION 23: Do you agree with the policy approach to managing environmental pollution through the planning process and with the proposed policy wording?

The policy would be strengthened by ensuring that there is mention of biodiversity within the policy bullet point relating to lighting.

Lastly, although the supporting text highlights that the district is not subject to any Air Quality Management Areas, with increasing development we suggest that the council recognise the natural capital that helps filter and deal with pollutants.

Increased levels of development in the district means resources may come under increasing pressure. It may benefit the council to consider talking to the Sussex Biodiversity Record Centre about their Ecoserve programme. This programme shows where the district's natural capital is delivering ecosystem services such as air purification in relation to population demand.

QUESTION 24: Do you agree with the policy approach to comprehensive development and the proposed policy wording?

We support recognising the importance of a holistic approach to development which considers the three roles of sustainable development. In order to achieve this within the policy wording we suggest that the policy looks to include wording regarding net gain to biodiversity as per section 109 of the NPPF. We feel that this is important as phased development may overlook the cumulative impact on the district's natural capital and the ecosystem services being delivered.

PART C: SITE ALLOCATIONS

General Comments
The Trust recognises that the presence of designated sites and priority habitats and species has been a contributing factor in the assessment of the suitability of site allocations. We very much support the council's approach to exclude designated sites and sites of high biodiversity value for development. However we note that the site assessments were primarily based on desk-top studies. With the exception of North Bexhill and Spindlewood Drive it does not appear that any on the ground assessments have been carried out.

Given the council's commitment in the Core Strategy objectives 'To protect important ecological resources in the district' and in policy EN5 to 'support opportunities for management, restoration and creation of habitats...' we recommend that preliminary ecological appraisals are carried out for the preferred sites before they are officially allocated. This will ensure that any issues relating to ecology are identified before the plan reaches the examination stage.

We are pleased to see that the 'Key constraints/opportunities' sections for many of the preferred site allocations consider ecological impacts. However, these considerations are again inconsistently reflected in policy wording. For example, policy IDE1 requires that an ecological assessment is undertaken and that any impact on protected species mitigated. Further to this, policy MAR1 states that development proposals should be subject to an ecological survey.

By singling out only two of the site allocations, this may give the impression that proposals for other allocations may not require ecological surveys. The NPPF has a clear requirement for planning decisions to be based on up to date information and for development to achieve net gains for biodiversity. It would not be acceptable for proposals to proceed without the inclusion of up to date ecological information, especially given that thus far the sites have only been assessed at a desk-top level. This position needs to be reflected in the Biodiversity Policy (please see comments for QUESTION 20) and in all the site allocation policies. Therefore the following wording should be added to all site allocations:
'Prior to determination:
A site wide landscape and ecological management plan that is informed by up to date ecological information, including information on the site's utilisation and delivery of ecosystems services, will be produced. Mechanisms needed for implementation will be identified and secured. This will be to the
satisfaction of the local planning authority to ensure long term maintenance of retained and newly created habitats.'

We recognise that information regarding a site's utilisation of ecosystem services maybe too onerous for small allocations. However, we take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Ecoserve. This programme uses biodiversity and habitat data to look at the ecosystems services currently provided by an area's natural capital. It also assesses where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider as an aid to helping smaller developments see how they could make a contribution or enhancements to the continued delivery of those services through their site.

Additionally, many of the site allocations are adjacent to ancient woodland. Again whilst this is usually noted in the 'Key constraints/opportunities' section, it is not consistently reflected in the policy wording for the allocation. For example Policy BRO1 part (v) specifies that 'a buffer zone of at least 15 metres is provided to the Ancient Woodland', while the presence of an ancient woodland is not mentioned in, for example, policy BEX1 or BEX2. Conversely policy BEX 9 does specify the need for a buffer to protect the adjacent ancient woodland, but the width of the buffer is not specified.

Core Strategy policy EN1 and NPPF paragraph 118 require the protection of ancient woodland in the district. Additionally, Natural England's Ancient Woodland standing advice is clear that a minimum buffer must be at least 15 metres. We therefore recommend that an Ancient Woodland policy is included in the DaSA and that any site allocation policy with the potential to impact on ancient woodland includes a requirement of a buffer zone of at least 15 metres.

We also note that most of the allocations require the 'retention and enhancement of boundary planting'. We understand that this requirement is primarily to mitigate visual impacts on the AONB, however this is also an opportunity to ensure that each allocation contributes to the creation of an ecological network for the district. We therefore recommend that when boundary planting is specified, additional wording is used, such as:
'Provision is made for the retention and enhancement of boundary planting, for the benefit of biodiversity and for screening purposes'.

The majority of the site allocation policies use the term 'some' when describing the number of dwellings or size of employment space required within a development. This is not a standard planning term and hence we are concerned that its use leaves the policies open to broad interpretation. Given the landscape and ecological sensitivities of many of the site allocations, we recommend that a maximum figure is proposed in each policy. This will provide clarity and ensure that the policy can be robustly applied.

Alternatively, if an approximate value is preferred, we recommend the use of the word 'approximately' rather than 'some' as this is more frequently used in a planning policy context. However, if the council is minded to use this approach, we would ask that an additional requirement is added to the policies to ensure that overdevelopment does not occur. We recommend the following:
'The final number of dwellings/employment size selected must be based on up to date environmental information that demonstrates the current ecosystem delivery of the site and its capacity to absorb the proposed level of development. '

QUESTION 26: Do you agree with the requirements of Policy BEX1? If not, how would you wish to see it amended?

General comment
The Sussex Wildlife Trust supports a plan-led planning process and acknowledges that site BEX1 is included in the adopted North East Bexhill SPD. However, we question whether the district's natural capital can absorb this level of development around Bexhill. All the allocated sites around the north east of Bexhill should be treated holistically and assessed for their impact on ecosystem services (NPPF paragraphs 109, 114 and 117). There must be a strategic approach to the development of these sites to ensure that ecological networks are retained across the sites.

Policy BEX1
We support the protection of the adjacent ancient woodland and the retention of the tree line through the centre of the site, as shown in the detailed map. However, this protection does not appear to be repeated in the policy wording. Additionally, the 'Key constraints/opportunities' section recognises that the land along the Combe stream to the north-west of the site should be retained as an amenity/wildlife corridor. Again, this is not reflected in policy wording. If requirements are not included in the policy, we are concerned that they may be disregarded at the application stage. This could also lead to confusion for developers and inconsistency in the decision making process. Therefore, policy BEX1 should be strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 The retention of the central belt of trees and enhancements to create a robust corridor between the ancient woodland and the wider countryside.
 The retention of the land along the Combe stream as an amenity/wildlife corridor
The Trust supports the retention of the central tree belt; however, the proposed access appears to sever this corridor. We recommend that the access is reconfigured to ensure the corridor is preserved in its entirety. If this is not deemed feasible wording should be added to ensure that the tree belt still functions as and ecological corridor.

It is vital that any green infrastructure within the site connects well to the surrounding area. We recommend additional wording in section (iv) to insure this:
'landscape and woodland belts are developed, implemented and connected to the wider landscape as an integral part of proposals'.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

The Trust questions whether the district's natural capital is able to absorb this level of development around Bexhill. Before finalising site allocations, especially larger greenfield sites around the development boundary, we recommend that the council assesses the capacity of these sites to provide ecosystem services. We take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Eco serve which uses biodiversity and habitat data to look at the ecosystems services the natural capital is currently providing and where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider.
QUESTION 28: Do you agree with the requirements of Policy BEX2? If not, how would you wish to see it amended?

General comment
As per our comments for QUESTION 26, site BEX2 should be assessed strategically with allocation BEX1 and BEX3. Overall, these allocations cover a significant area of greenfield, which will be providing vital ecosystem services to the district. The cumulative impact of these allocations on the district's natural capital needs to be assessed and accounted for to ensure that the expansion of Bexhill is truly sustainable as per the NPPF. Additionally, any green infrastructure strategy should cover all these sites to ensure permeability throughout the developments and multifunctional benefits across the north east of Bexhill are achieved.

Policy BEX2
As per our comments for QUESTION 26, we are concerned that some of the intentions in the 'Key constraints/opportunities' section and the detailed map are not reflected in the policy wording. We recommend that policy BEX2 is strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 Part (ii) should include a requirement for the pond to be retained as an ecological feature with landscaping to connect it to the wider countryside

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

Notwithstanding our general comments in QUESTIONS 26 and 28, if development is to occur here then option 1 would be preferable. This would retain a larger proportion of greenfield and allow more creative approaches to green infrastructure and ecological enhancements. We recommend that information on the site's utilisation and delivery of ecosystem services should be produced and used to inform the site's layout.

The Trust is concerned that the now approved North Bexhill Access Road severs the ghyll woodland at Kiteye Wood.

Any development in this area should seek to mitigate this impact through appropriate habitat creation and/or management. Additionally, the policy should make reference to the retention of the land along the Combe stream as an amenity/wildlife corridor, as per policy BEX1. These requirements could be included in part (vii) of the policy, which we support.

As with previous comments the wording to protect ancient woodland should be strengthened to include a requirement for a 15 metre buffer.

We also recommend that the policy protects the 'Woodland Complex at Buckholt Farm' Local Wildlife Site, to the north east of the site allocation. Whilst it sits outside the development boundary, this ancient woodland could still be harmed by the indirect impacts of the development. These need to be assessed and avoided at the master planning stage.

QUESTION 33: Do you agree with the requirements of Policy BEX7? If not, how would you wish to see it amended?

The Trust supports the retention of the southern section of the site as an ecology area. However, the wording of section (iv) should be strengthened to include a requirement to enhance the area as per core strategy policy EN5. We recommend:
'The southern section of the site remains undeveloped as an ecology area. Ecological enhancements should be implemented to improve the area for biodiversity. Provision should be made for the long term management of this area.'
QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

The Trust supports the retention of the tree belts in the centre of the site, the designation as a natural green space and the wording of part (vi). However, it is not clear to us how this corridor will be retained intact given that vehicle access is only proposed from the east of the site. This indicates that internal roads will sever the corridor in order to access the residential area in the North West. This should be a consideration in designing the layout of the site. At the very least we recommend wording to ensure that the integrity of the green corridor is maintained.

We support the inclusion of section (vii), however this should be strengthened with a requirement for the ancient woodland buffer at least 15 metres wide.

Additionally, it should be specified that the pond is retained as an ecological feature, rather than as part of any SuDS scheme for the site.

QUESTION 36: Do you agree with the requirements of Policy BEX10? If not, how would you wish to see it amended?

The Trust supports requirement (ii), however this should be expanded to specify that integration includes an integrated scheme of green infrastructure to ensure that the entire site remains permeable and receives multifunctional benefits.
The words 'where possible' should be removed from part (v). The pond should be retained and enhanced; this cannot be seen as unduly onerous given the site of the scheme.

QUESTION 37: Which of the development options for Northeye do you prefer? Should other options be considered?

Any policy for this site must include protections against the potential negative impacts of the creation of sports pitches such as flood lighting and impermeable surfaces. We recommend wording is included to ensure that there are no harmful impacts of this type of development.

QUESTION 38: Do you agree with the requirements of Policy BEX11? If not, how would you wish to see it amended?

This policy should include wording to manage the type of playing pitches which might be suitable on this site. Consideration should be made to the use of artificial pitches and associated lighting. In particular, potential impacts on bats which are likely to be present in the area should be considered.

QUESTION 43: Do you agree with the requirements of Policy BEX15? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that 'a large proportion of the site suffers from surface water flooding'. Therefore, we recommend that an additional criterion is added to the policy to ensure that a SuDS scheme is implemented to rectify this issue. We also recommend that green infrastructure is included to both help with the flooding issue and to connect the site to the wider GI network in the town.

QUESTION 47: Do you agree with the preferred site for housing development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust supports the allocation of brownfield sites of low ecological value over the allocation of greenfield sites. A large amount of development is already proposed for the fringes of Hastings through the Hastings Development Management Plan. We would not support any further urban sprawl into the surrounding countryside without full accounting of the area's natural capital and assessment of the area's utilisation and delivery of ecosystem services.

QUESTION 49: Do you agree with the preferred sites for employment development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust does not support further urban sprawl at the Hastings fringe; however of the four sites recommended, the preferred sites seem to be the least damaging. As stated previously we recommend that preliminary ecological appraisals are carried out before sites are formally allocated to ensure that there is no significant harm to biodiversity.

Additionally, a wider green infrastructure plan should be required, covering both of these sites in conjunction with the adjacent Hasting allocations to ensure a holistic approach.

QUESTION 50: Do you agree with the requirements of Policy HAS2? If not, how would you wish to see it amended?

We recommend that point (iv) is strengthened as follows to ensure net gains to biodiversity as per the NPPF:
'provision is made, in conjunction with the adjoining employment allocations, for the retention, enhancement and long-term future management of woodland to the north of the site for the benefit of biodiversity'.

QUESTION 51: Do you agree with the requirements of Policy HAS3? If not, how would you wish to see it amended?

We support criterion (iv), however any green infrastructure should be integrated into the surrounding employment allocations, to ensure multifunctional benefits are seen across the whole area.

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

We recommend an addition to criterion (ii) to ensure net gains to biodiversity as per the NPPF.
'...the Site of Nature Conservation Importance within it, and creates net gains to biodiversity within the Park...'

QUESTION 54: Do you agree with the recommendation regarding the Hastings Fringes development boundaries? If not, please explain how you wish the development boundaries to be applied to this area?

The Trust strongly supports the designation of a strong development boundary which prevents further urban sprawl into the wider countryside. (Please see QUESTION 47).

QUESTION 56: Do you agree with the requirements of Policy BEC1? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 57: Do you agree with the requirements of Policy BEC2? If not, how would you wish to see it amended?

We recommend that the policy is strengthened to better reflect the contents of the 'Key constraints/opportunities' section. In particular, reference should be made to the requirement to keep the remaining area as amenity land and to the retention of the pond as an ecological feature rather than as part of any SuDS scheme deemed necessary.

QUESTION 59: Do you agree with the preferred sites for development at Broad Oak? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value such as BO14. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 60: Do you agree with the requirements of Policy BRO1? If not, how would you wish to see it amended?

The Trust strongly supports the wording of requirement (v) and the specification of a buffer of at least 15 metres. We recommend that this wording is replicated in other policies for sites adjacent to ancient woodland.

We support requirement (iv), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 61: Do you agree with the requirements of Policy BRO2? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 65: Do you agree with the requirements of Policy CAM2? If not, how would you wish to see it amended?

This policy needs to be strengthened to ensure that the adjacent Local Wildlife Site, Local Geological Site, SSSI and Special Protection Area are protected from harm. Whilst the protection and management of the dunes is a key landscape and ecological objective of the SPD, there does not appear to be a specific requirement to protect and enhance these designated sites. This should be addressed in the policy.

QUESTION 66: Do you agree with the proposed development boundary? If not, how would you wish to see it amended?

The Trust strongly supports the deletion of the SSSI from the development boundary. Dungeness, Romney Marsh & Rye Bay SSSI is of national importance to biodiversity and should not be degraded through encroaching development.

QUESTION 68: Do you agree with the requirements of Policy CAT1? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that buffer planting should be informed by ecological surveys, however this requirement is not reflected in the policy wording. Given that the site appears to contain well developed scrub, any application for this site must include a thorough ecological survey to assess if the site can absorb the level of development suggested whilst producing net gains for biodiversity.

QUESTION 69: Do you agree with the requirements of Policy CAT2? If not, how would you wish to see it amended?

Requirement (iii) should be subject to ecological surveys to assess the impact of severing the hedgerow. We also recommend that 'for the benefit of biodiversity' is added to the end of requirement (iv)(b) to ensure that any tree and hedgerow planting contributes to the wider ecological network in Catsfield.

QUESTION 72: Do you agree with the requirements of Policy HUR1? If not, how would you wish to see it amended?

As the stream/ditch that sub-divides the two lower fields is recommended to be retained for both heritage and ecological reasons, this should be reflected in the policy. We recommend that requirement (vii) is amended to:
'...is retained and incorporated within the layout as an ecological feature. Development should ensure that the biodiversity value of the feature is enhanced and that it is integrated into the wider blue/green infrastructure plan for the site...'

QUESTION 73: Do you agree with the requirements of Policy HUR2? If not, how would you wish to see it amended?

This site is adjacent to Hurst Green Meadows and Woodland Local Wildlife Site. This should be acknowledged in the policy and a requirement to protect and enhance the LWS should be included.

QUESTION 76: Do you agree with the requirements of Policy IDE1? If not, how would you wish to see it amended?

We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species. Opportunities to incorporate biodiversity gains throughout the development should be taken.

QUESTION 79: Do you agree with the requirements of Policy NOR1? If not, how would you wish to see it amended?

Enhancements to the existing tree belts should be sought for the benefit of biodiversity.

QUESTION 82: Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?

The Trust strongly supports the protection of the traditional orchard and the aims to bring it into long-term sustainable management. This is a priority habitat and as such its protection and enhancement is fundamental to the council's aims in the Core Strategy. We strongly support requirement (v) and recommend that there is a requirement for a long-term ecological monitoring and management plan for the site.

Requirement (vi) should include 'enhancement' as well as retention to ensure net gains to biodiversity. We also recommend that the requirement for a SuDS scheme is included in the policy.

QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

The Trust strongly supports the exclusion of the traditional orchard from the development boundary. This will help to protect the site in the long term.

QUESTION 84: Do you agree with the preferred site for development at Rye Harbour? If not, which site should be preferred?

The Trust strongly supports the exclusion of sites designated as SSSI. These would clearly not be suitable for development and their allocation would be contrary to the Core Strategy and NPPF.

QUESTION 85: Do you agree with the requirements of Policy RHA1? If not, how would you wish to see it amended?

The site is also adjacent to the SPA and this should be acknowledged in the policy. We recommend that requirement (iv) is extended as follows:
'...development of RH10 does not adversely impact upon the Rye Harbour SSSI and avoids impacts on the SPA'.

QUESTION 86: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

It appears a typo is included in paragraph 15.98. The reference to Donsmead, Station Road should be removed.

We support the proposed development boundary as it should prevent further development encroaching onto sites designated for their biodiversity value.

QUESTION 87: Do you agree with Policy RHA2 regarding the Harbour Road Industrial Estate and the proposed boundary changes? If not, how would you wish to see it amended?

Given the ecological sensitivity of the land surrounding this allocation, we recommend that requirement (iii) is strengthened as follows:
'...a comprehensive landscaping strategy and an ecological monitoring and mitigation plan to improve the overall appearance and the biodiversity value of development.'

QUESTION 88: Do you agree with the preferred sites for development at Westfield? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 89: Do you agree with the requirements of Policy WES1? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. Further to this, as identified in the 'Key constraints/opportunities' section, the previous ecological appraisals suggested biodiversity gains. The Trust strongly supports the inclusion of wording to support biodiversity gains but seeks that these are not limited to bird and bat boxes. Instead biodiversity gains should be implemented depending on the findings of the up to date ecological surveys submitted at the time of the application. We remind the council that if they are minded to suggest bird and bat boxes as part of the gains for this site in future, wording should be included to highlight the need to incorporate natural features supporting these artificial homes.

QUESTION 90: Do you agree with the requirements of Policy WES2? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. The aerial photograph shows the degraded formal gardens and it would be interesting to see if this allocation could consider how these former gardens might be integrated into the layout of the development site, as it may enable the retention of features of interest.

QUESTION 91: Do you agree with the requirements of Policy WES3? If not, how would you wish to see it amended?

The southern section of the allocations lies within the Hasting Fringes Biodiversity Opportunity Area (BOA). We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species.

Opportunities to incorporate biodiversity gains throughout the development as per the ecological surveys and aspirations of the BOA should be taken.

QUESTION 92: Do you agree with the requirements of Policy WES4? If not, how would you wish to see it amended?

We note this allocation falls outside the 2006 development boundary. However, we are supportive of measures taken to encourage modes of sustain able transport and to interlink those benefits with biodiversity gains. The text accompanying the allocated site states that there are locally present protected species. Therefore we recommend that (iii) reads:
'ecological improvements are based on up to date ecological surveys and are implemented in accordance with these findings and those of the Hasting Fringes Biodiversity Opportunity Area and Rother Green infrastructure Strategy'.

Question 93 - 103

We support the retention of gaps between settlements. While these gaps are often retained for reasons of coalescence and visual sensitivities, we highlight that the Sussex Wildlife Trust also sees the need to recognise the importance of these green gaps in delivering ecosystem services to the local communities (NPPF section 109).

QUESTION 105: Do you agree with the requirements of Policy GYP1, including the boundary as defined on the Policies Map? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per are general comments at the start of this section.

QUESTION 109: Do you agree with the requirements of Policy (MAR1)? If not, how would you wish to see it amended?

We support the requirement for an ecological survey. We recommend that criterion (i) includes 'for the benefit of biodiversity' and the criterion (iv) requires the use of SuDS.

QUESTION 110: Do you agree with a policy to support the continued allocation for the re-instatement of the railway link from Robertsbridge to Bodiam along its original route?

The Sussex Wildlife Trust support sustainable modes of transport. However, we do not have enough information about this particular scheme to offer an opinion on this policy. It is unclear whether the application has been progressed with the consideration of the existing landowners and the level to which biodiversity interests have been considered.

QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?

We highlight the need for a specific Ancient Woodland Policy as per section 117 of the NPPF.
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

We welcome the inclusion of the green infrastructure study as an evidence base for the local plan. We would like to know if this will progress into a clear strategy identifying delivery mechanisms. We suggest that the local plan may benefit from a specific policy on green infrastructure/ecological networks to ensure consistent integration of this infrastructure within development.

Should you have any further questions regarding our consultation response please feel free to contact me.

Yours sincerely,
Laura Brook
Conservation Officer

Designated sites - Combe Haven SSSI; within 'Impact Risk Zone' (IRZ) for the
SSSI.

If the allocation is likely to have a significant effect on the SSSI, appropriate mitigation measures need to be specified.

One example would be hydrological impact; such as increased water levels entering the SSSI and from SuDS/ground water/surface water run-off and pollutants entering the ditch network feeding the SSSI, with potential to harm the botanical,
invertebrate and bird interest of the SSSI.

Transport Strategy & Economic Development
BEXHILL Page 128

-Policy BEX3: Land at North Bexhill

Agree with policy BEX3, and the need for an SPD, to manage development alongside associated infrastructure (i.e. transport) coming forward. This policy is in alignment with the development of the Bexhill Cycle Network (v, x), and with the development of NBAR (i,xi) along with the need to improve safety (xii) (xiii).

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

BEXHILL Page 128


-Policy BEX3: Land at North Bexhill

The site has high potential for prehistoric, Roman and medieval archaeological remains, so should be subject to archaeological assessment before being allocated.
-AMBER

Ecology

BEXHILL Page 128

-Policy BEX3: Land at North Bexhill

viii) should be amended to state "... with arrangements for its implementation and long term management."

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194