QUESTION 31: Do you agree with the requirements of Policy BEX5? If not, how would you wish to see it amended?

Agree.

I strongly object to this proposal. Planning permission was overturned before, in the High Court I understand, because of its historic significance. This development should not go ahead

This is a greenfield site. A recent High Court decision turned down application for dwellings. Three planning applications have refused housing development. It is obvious the site should be for leisure facilities. The unused part of the bowling green area has good potential for additional leisure use particularily for the over 50's to complement the bowling green.

Yes but need to ensure there is a demand for sheltered dwellings, that they can be filled and enough funding available to provide the support needed. Older Persons schemes have a high level of service charges, this impacts on the amount of money left to pay the rent. With benefit caps affordable housing providers and residents may not be able to afford to build, manage or live in these development

The site has a bad planning history going back to the first application in 2003 for housing, and subsequent applications for retirement accommodation - all of which failed. Given its historic use as a park,croquet club and currently a bowls club, the greenfield site should be re-allocated for leisure use only and the green open space saved to complement its historic setting. It is the last green space immediately to the east of the Town Centre Conservation Area and the proposed new cultural area and the whole site is registered as an Asset of Community Value.

This site would probably be too densely developed and could be insensitively placed within the nearby existing housing stock. Great care should be exercised here.

The comments below are in relation specifically to policy BEX5 - Land at Gullivers
Bowls Club, Knole Road, Bexhill.

In terms of context it is noted that within the current adopted plan period that
within the District Bexhill will need to deliver 3,100 dwellings. Moreover there is no
reference within the latest Annual Monitoring Report, Housing Land Supply, and the
Strategic Housing Land Availability Assessment, to the specific amount of need.
However the Core Strategy Policy CO5 - Supporting Older People would be of
relevance to the site. Further the preamble to the policy sets out that the District
has the highest level of older people within the County and Bexhill specifically is
stated as having a population where 34.3% of people of over 65.

There is a clear need in the Borough for specialist accommodation for the elderly,
and the delivery of specialist accommodation within the Borough should be seen as
critical given the Council's demographic information that has been collected. To this
end the Council must also consider this in the light of the nature and issues
incumbent in with the delivery of such accommodation, such as reduced car
ownership, communal facilities etc.

Policy BEX5 is welcomed as sensible use of the site, to provide much needed
Sheltered Housing within the District, where there is a clear need. In respect of the
wording of the Policy there appears to be some level of conflict. Firstly the policy
states that the site should deliver housing and the first point then states sheltered
housing, this should be made explicit.

Taking the elements of the policy in order;
i) Some 39 sheltered dwellings are provided, of which 30% are affordable;
It is clear that the Council will need to have some degree of assessing the site in terms of providing a view of capacity. However, specifying the number of units on site to "some 39" could restrict the sites potential to accommodate a higher number of dwellings. Moreover this would give no consideration to the mix of units on site, clearly 39 x 1 bed units would be considerably less mass than 39 x 2 bed units. The assessment given the sensitivity on the site should be more focused towards scale than containing the development with an arbitrary number. Whilst the proposed number of sheltered dwellings on site would appear from a historical standpoint to generally be acceptable, this cannot guarantee that the same number is viable.
Any sheltered housing development would facilitate an improved bowls facility along with contributing to the overall housing need of the District. Supporting paragraph 47 of the NPPF seeks to boost significantly the supply of housing in the Country. As such the second part of point i) of the policy and the issue of 30% to be provided on site are not considered appropriate given the nature of a sheltered housing development.

Sheltered housing gives residents are provided with a variety of elements that open marking housing does not cater for these including owners lounge, communal landscaped amenity area, a lodge manager, etc. The buildings are also maintained by management companies. In addition to this a lodge manager is usually employed by the management company to provide assistance and security for the owners of the apartments given their age and often increasing frailty.

Given the nature and management of sheltered accommodation it would not be possible to provide onsite affordable housing, primarily for management reasons. However, a financial contribution towards offsite affordable housing following the submission of a viability assessment in accordance with policy LHN2 would be appropriate. This is set out within the NPPF and also the previous determinations by the Council. As such the reference to a specific deliverable amount on site would make the delivery of the site unviable. Furthermore the Council also has specific policies in place to deal with affordable housing that should be sufficient without repetition on a site by site basis.

ii) An improved bowls facility comprising of an outdoor bowls green, an indoor rink and associated clubhouse and maintenance facilities is provided;
This element would help achieve the policies goal of a mixed use development on the site, and we agree that this should be achieved in line with adopted policy.

iii) Development at the rear of the site is single storey only;
Given the sites location, levels and significant separation distances to adjoining properties to the rear of the site development should not be limited to single storey in this location. A well designed and articulated proposal of over one storey could be achieved as part of the overall redevelopment of the site and would be in accordance with paragraph 58 of the NPPF which seeks to optimise the potential of sites to accommodate development and create and sustain an appropriate mix of uses whilst responding to the local character and surroundings. Moreover this would restrict any ability to expand. This should be related to the review of the submission against the relevant policies in relation to design and setting, rather than be so specific.

iv) Separate access points are provided for the residential and bowls facility part of the scheme;

Whilst it is accepted that separate access points for both the bowls club and sheltered housing may be a preference it should not be discounted that a shared access may be feasible and indeed desirable.

If the shared access meets the required highways standards and is acceptable in terms of an overall layout then a shared access should be allowed. There seems little to no justification for this requirement

v) The design of the scheme does not adversely affect the character of the area or the setting of the listed terrace to the south; and

Given the sites location which is directly adjacent to grade 2 listed buildings it is essential that any proposal preserves the setting of the Grade II Listed terrace and does not have a detrimental impact on the character of the area in line with paragraph 131 of the NPPF and policy EN2 of the Core Strategy.

vi) Provision is made for the retention and enhancement of boundary planting, particularly on the western, northern and eastern boundaries.

It is not clear from the policy what this requirement is trying to achieve. Any proposed development should be accompanied by a robust landscaping strategy that should include treatment of all boundaries including the south which is the most visually prominent and directly adjacent to the listed terrace.

Overall while the policy is broadly welcomed the requirements begin so specific in terms of what form of development happens on the site could easily create future problems. For example with an offsite or commuted sum delivered for affordable housing, or if less units are delivered. The Council are advised to very carefully consider the ramifications of the policy wording of the allocation of the site given its very complex history.

I trust that the above is clear but if any further clarification is sought please contact me and we will be happy to assist.

Following 3 Failed planning applications my view remains the same that no residential development should be approved on this site and that it should remain in it's entirety as an open space leisure facility.
1)This a greenfield site and should remain so for all to enjoy.
2) Parking is always very difficult in the area surrounding the site and will be made impossible by further development here.
3)A development of flats will negatively impact on surrounding properties - especially the elegant Victorian listed buildings.

I have objected each time Churchill has submitted a new application: nothing in the new proposals has altered my views.
I live in a basement flat directly opposite the proposed site in Knole Road which has three original interior "borrowed lights" to help relieve the lack of light; cellars are underneath the pavement and subject to water ingress; sewers are Victorian; parking is already a problem.
This greenfield site, originally covenanted to Bexhill citizens, should never be allocated for development but retain its CASC status catering for the community to promote healthier lifestyles through sport participation for everyone.
Definitely NO.

No, I do not agree. It is a greenfield site which should not be allocated for development. The existing club is a CASC and as such should cater for the community and the need for healthier lifestyles through sport participation. Rother's own Open Space, Sport and Recreation Study singled out the Knole Road site as being of particular high value, has not been fully considered. A green open space within a development boundary should be protected in its entirety and in perpetuity, as it formed part of the very 'English' character of this area.

BEX5 should NOT be included. RDC's Open Space, Sport and Recreation Study not fully considered which stated BEX5, in current condition/size, as being of particular high value. Also shortage of accessible open space in area. Following 'Site Assessment Methodologies', site is inappropriate due to impacts on: flood risk, integrity/setting of Listed buildings, local character/amenities, community facilities to meet local needs, housing and infrastructure priorities/community preferences, provision of leisure/recreation to meet local needs, highway safety, value to local economy, Brownfield/greenfield nature of site (site is greenfield), past contamination, land stability and other site conditions adding to costs and/or risks.

I do not agree that BEX5 should be 'preferred' for housing at all as this site is not 'previously developed land' according to PPG3 (1992-2006), PPS3 (2006-2010) and now NPPF (2010-Present). Previously failed planning applications/appeals/High Court cases (nearly all of which I have attended) on this site, have highlighted increased risk to flooding, subsidence, loss of light, loss of public view, highway problems, loss of protected flora and forna, and harm to the setting of a Listed terrace of buildings. I would like BEX5 removed from list and for protection be designated as an open space site for recreation.

Bex 5
This site should not be allocated for development for the following reason. It is a "greenfield" site. Despite the site being "considered" for development by the Planning Inspectorate the appeal was refused. Building on the site would mean even more pressure on the swindling facilities of residents in the surrounding areas.

A private club which can no longer support itself financially because of unresponsible budgeting, would be better replaced by the public sports facility which would benefit the wider community. "Community first, not profit for the elitist few.

There are too many environmental issues which haven't been thought out sufficiently. Most importantly flooding, especially too many of the properties in the listed buildings in Knole Road. Building would have a disastrous impact on the immediate and surrounding areas. Why build another 39 retiree flats when we already have 51 being built on the corner of Sea Road and Jameson Road.

These developers are like a dog with a bone. Their main incentive is greed. They don't live in this community, just as some of the councillors on the planning committee don't live in this community and yet they are all ready to take away what little green space we have for their own profit. Is this what modern community is all about? Surely there are still people who believe in doing their best for others and one way would be to put a stop to any planning applications for the site to be developed for housing!

Finally I would refer you to your own "Open Space, Sport & Recreation Study". perhaps email copies to the committee members concerned for ease of reference.

Bex 5
Object: this infilling is over development, especially in Bexhill-on-Sea and over-calculation of genuine housing requirement for local people in this specific area. It seems the calculation is to mitigate the migration-drivers, to take up pressure otherwise in the Rother District catchment area (eg historic parishes and/or AONB) and even to assist Hastings Borough directives for allocation. Although I fully agree with the reasons to resist development elsewhere - it does not give justice to negate the value of Bexhill-on-Sea environments and historic features which
should also be retained. The whole area will be spoilt forever and I object to this development plan.

Land at Gullivers Bowls Club, Knole Road, Bexhill-on-Sea
Object: but if it goes ahead I would urge you to only allocate the fewest possible dwellings in this Local Plan - and not to be revisited to add more in a future allocation.

Green spaces
Green spaces and surrounding trees, hedgerows and shrubs should not just be a token here and there , but in walking distance of existing developments in Bexhill-on-Sea. This should be factored into the Local Plan as a resource for leisure, a visual amenity and retaining all wildlife corridors.

Loss of visual amenity value
This proposed allocation for development would have a detrimental impact on the Victorian street scene from Knole Road. It would be out of keeping within the character of the area.

Minimum buffer to trees and hedgerows
Always allow a 15-20 metre buffer between builds and trees/hedgerows
Please stipulate that any tree which is within the boundaries of an individual property in a new development has a 15-20 meter genuine buffer boundary. This it to protect individual trees, hedgerows, ecology areas, heritage assets (including those undesignated). The details plans should also encourage either a Tree Preservation Order and/or Covenants that no tree should be harmed. If it is later deemed diseased or dangerous a full report should be submitted by the owner to the council and a replacement tree would be planted in the same place.

It is with great disappointment we find ourselves, yet again, having to fight to keep the lovely open space in Knole Road as just that. A place of quiet tranquillity, free of any unnecessary buildings other than that of the existing Bowls Club. We have fought tooth and nail to keep this place as a "Green Lung" for the residents overlooking the said lawned area. We really had hoped that, after the last appeal was turned down by the High Court, that once and for all no buildings would be allowed on this site. Yes, make better use of it for sports and recreation and by all means put in some seats so the elderly who live locally and do not have gardens can utilise it. There are many partially-sighted people who cannot, or are frightened to, negotiate the road across to the seafront, and would find this calm and beautiful space a boon. We really do not need any more sheltered housing. We have dozens of available spaces in many locations, spread across Bexhill - some of which are "affordable". Please, please think very carefully before allowing anyone to spread concrete over this lovely open space -which would most probably be completely out of keeping with the existing listed buildings opposite

Re: Gullivers Bowls Club
1. The development will adversely affect the character of the area and the listed terrace to the south.
2. This is a Greenfield site. Developments should preferentially be on brownfield.
3. There are unoccupied retirement homes in Bexhill. We do not need any more.
4. RDC open space, sport and recreation study said this Knole Road site had high value for the community. The community should be considered before developers' profits.

I make the following amendment to policy BEX5:

Exterior of new buildings to be of a similar construction and style to the listed terrace to the south.

Construction other than improvements to the current leisure facility would be detrimental to the Greenfield/ recreational/historical aspect of the area.

Any buildings taller than the current facilities would not be in keeping, depending on height they would block out light to two storey properties in Brassey Road and surrounding roads.

There would be a flood risk, as it is our garden becomes very water-logged for weeks after heavy rainfall often to the extent of an inch or so in depth. I feel sure further building on the floodplain would compromise the structure of our blocks of flats as well as preventing us from enjoying our garden.

No. Leave it as it is and allow the Club to run its affairs without interference.

The two tennis courts between Middlesex Road and Bolebrook Road have already gone and been replaced by modern housing. Gulliver's was established in 1925 as a Bowling Club and sold by the private owner to the Club on generous terms in 1970. This area was intended to be an amenity space.

There have been four applications rejected in the last fourteen years.

Affordable sheltered dwellings are unnecessary as sheltered dwellings are offered to a restricted market and are, therefore, sold below the value of similar properties on the open market. Bexhill has a large number of sheltered dwellings and a vast number of flats that are suitable for occupants with limited mobility.

It is impossible to design a scheme that would not adversely affect the character of the area, which is already subject to crowded parking during the summer, bearing in mind that the flats on Knole Road, The Sackville and Normanhurst are densely occupied without parking facilities. Their residents and visitors have no option but to park on Knole Road and the surrounding streets. Although there will, presumably, be allocated parking in any development, it unlikely to be sufficient to allow for residents' visitors.

Churchill Retirement Living's plans included buildings of four storeys. This is not in keeping with the area. Building of several storeys are likely to be the only way of achieving the target of thirty-nine units.

In granting permission for Churchill's development during 2015, Rother failed to consult the Victorian Society on the impact the development would have on the surrounding area, which includes De La Warr Parade, a Grade-II listed terrace of houses. A report, produced by a council officer and distributed to members of the planning committee ahead of the decision being made, suggested the Victorian Society had been consulted on the scheme and raised no objections, when in fact the information had never been received as it was sent to a defunct email address. The impact on the Victorian listed building was a key issue in the determination. Whilst there was no legal obligation to consult the Victorian Society, the society had objections and its views on the scheme would have been relevant. (Case No: C1/2015/2398) There is also a problem with flooding which will have to be dealt with.

There are many brownfield sites in Bexhill, indeed I live in a home developed from one and the brownfield site adjacent to my building is currently under development on Cantelupe Road. Once a decent size of green space has been lost, it cannot be regained. Rother District Council has designated it an Asset of Community Value.

Excerpt from Open Spaces, Sport and Recreation Study undertaken during 2006/07
OUTDOOR SPORTS FACILITIES

10.14 When judging the quality scores for individual sites it should be remembered that there are a large of outdoor sports facility providers in the District including the Local Education Authority, private operators and Parish Councils. Therefore the average quality score of 63% for the District is a reflection of all providers. The highest scoring sites included

* Highwood's golf course, Bexhill (Site ID 150)
* Knole Road Bowling Greens, Bexhill (Site ID 223)
* Canada Way Recreation Ground, Bexhill (Site ID 192)

Leave Gullivers as it is, operating as a Community Amateur Sports Club and allow the Club to run its affairs without interference. 'It is a private club run for members by members.'

Gullivers Action Group does not agree with the site allocation of Policy BEX5 on the
following grounds:

Policy PO1 sets the principles for retaining sites and premises currently in community use, and Gullivers Bowls Club is a registered Community Amateur Sports Club which has been proved to be viable.

Policy EN5 provides an over-arching policy commitment to protect and enhance green space including the array of 'multi-functional' green spaces that variously provide recreational opportunities.

This consultation document acknowledges some over-provision of sites. Therefore
BEX5 is wrong to specify 39 retirement apartments, with no planning permission and
objections from statutory consultees.

It is contrary to the stated aim for Bexhill to have a 'more balanced demographic profile'.

I wish to register my comments on the above documents, in particular, the proposal to build sheltered accommodation flats along Knole Road and to enclose a playing field in the interior of the site.

I object, not to the idea of sheltered accommodation, but to the construction of flats on the only large green open space in this neighbourhood. There are other sites in Bexhill where these flats could be built. Such construction should not occur on a green space that is an integral part of the character of this area.

Claims that the green space will not disappear because the playing fields will be moved to the interior of the development are spurious. The green space will not (except for the odd glimpse) be visible from Knole Road and will therefore, in effect, disappear. As a result, the entire aspect of the neighbourhood will be adversely affected.

The construction of flats in this green space will also have a negative effect on parking in this area - despite claims to the contrary. At the moment it is often impossible to park on Knole Road itself - spaces are taken up by residents, those who work in the town centre, visitors to the promenade, members of the bowls club and their guests, and workmen carrying out and repairs and deliveries to surrounding properties.

It is dishonest to deny the negative impact on parking that the construction of 39 addition flats on Knole Road - with all the additional medical visitors, deliveries and workmen needed to attend to the needs of additional residents.

I fear that such construction will also have a negative impact on the environment of the immediate area, such as wildlife and water drainage.

In conclusion, I object to the construction of 39 flats on the site of Gullivers Bowling Green. I believe that any construction on this site will adversely affect the character, and day-to-day functioning, of the area.

Transport Strategy & Economic Development
BEXHILL Page 128
-Policy BEX5: Land at Gullivers Bowls Club, Knole Road, Bexhill

BEX5, 6, 7, 9, 10 will be taken into consideration when a cycle network for this part of the town is being developed.

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 BEX5: Land at Gullivers Bowls Club, Knole Road, Bexhill

The site has a medium potential to contain prehistoric, and Roman remains. Any planning application would be expected to include an archaeological assessment in line with NPPF.
-GREEN

Ecology

BEXHILL Page 128

Yes