Policy BEX5: Gullivers Bowls Club, Knole Road, Bexhill

RDC's 2006/7 Open Spaces, Sport and Recreation Study by PMP Consultancy, (included in the proposed submission documentation) highlights "Sites which scored most highly and are judged to have a high value to the District include ...Knole Road Bowling Greens, Bexhill (Site ID 223)..."

The SA conclusion (Appendix 4: Assessment of Site Policy Options) refers to the Playing Pitch Strategy only.

Re Environment (6.44) Town Centre green spaces provide an important service in filtering pollutants.

Re communities, sites of social and economic value should be retained, "and their real loss resisted unless it is evident that they cannot be maintained or that their continued use would perpetuate real harm to local amenities... ". (3.3)

Since May 2013, the entire site has been listed as an Asset of Community Value.

The club itself is a Community Amateur Sports Club.

Bexhill Local Action Plan 2010 states that "89% want better protection and community use of green open spaces (44% strongly*). Suggested action: Clear policy to protect green open spaces. Increase amount of communal spaces available for exercise and enjoyment." *of over 1300 completed questionnaires with over 5000 written comments submitted. Plan was incorporated into Rother Local Plan Core Strategy adopted 2014 (8.13 p.46)

Development And Site Allocations Local Plan

Representations of Bexhill Heritage
Bexhill Heritage is a new, locally-founded and based charitable organisation dedicated to the care and protection of the heritage built environment of the town. Despite its recent creation the charity has already attracted over 200 members, some professionally qualified in planning, architecture or building surveying. Bexhill Heritage has already carried out three high profile and practical projects, and has reviewed all the planning applications submitted to the Council in 2018 within Bexhill.

We have reviewed the current document and believe that the plan has been thoroughly and professionally prepared. We understand it is to be assessed by an independent person appointed by the Planning Inspectorate. We wish to make the following representations on the soundness of the plan, all of which are specific to Bexhill-

1) Lack of height restriction policy town centre and sea front

Whilst there has long been a recognition and appreciation by the Council and residents of the special qualities of the sea front and town centre, and a significant part of the town centre is covered by a Conservation Area designation, such recognition has proved insufficient. The only whole site redevelopments carried out in the last ten years have resulted in buildings which are too high to relate satisfactorily to their surroundings and they thus detract from the appearance of the vicinity. These are the eight storey buildings at the seaward end of Sackville road and in Sea road, the flats which are known as South Beach.

Thus it is clear that a specific policy is needed to guide developers, landowners, Councillors and staff and to give reassurance to the public, which restricts new buildings to a more reasonable maximum height both in the town centre and on the sea front, much of which is outside the Conservation Area.
The following policy is suggested -

"Within the Town Centre and on the sea front the redevelopment of sites will be limited to a height commensurate and compatible with adjacent buildings and the area within which the site lies. This will generally mean a maximum of four storeys".

2) Town Centre - need for policy amendment - Social Zones

The Council and the public have for many years been concerned that the Town Centre is blighted by the dominance of vehicles to the detriment of pedestrians and cyclists but little has been done to address this. There are changes afoot and the plan recognises this in para 9. 154 and mentions the potential for Social Zones. However. schemes for management / parking must have at their core the need for such social zones where pedestrians be they residents, visitors, shoppers can take pleasure in their activities freer from accompanying worries about moving traffic, dangers, noise and pollution. However, policy 8X12 - Bexhill Town Centre does not sufficiently recognise this and should be strengthened.

Accordingly the following amendment is suggested to paragraph three of BEX12 -
Insert "social zones and" after "provide" and instead of "will be supported" replace by "will be implemented".

3) Suburban Redevelopments - Policy omission - Need for new policy

There is a noticeable trend towards the replacement of individual dwellings by flats.

This is not new and is inevitable. Its effects have so far been moderate. As the process gathers pace its townscape effects are becoming more adverse even with the most attentive development management regime the Council can put in place.

Too often the redevelopment will result in the gardens and vegetation which softens suburban areas giving way to three and four storey buildings seeming to fill the plots and with car parking occupying much of the remaining area.

Existing development management policies, and those proposed in the plan are important in curbing the worst aspects of such redevelopments but a general policy which guides developers, aids Councillors and reassures residents would further help - the following is suggested -
"The redevelopment of one or two dwellings in sections of road largely comprising
one and two storey dwellings will normally be limited to three storeys."

4) Site Allocations - Land off Spindlewood Drive - Objection

Bexhill Heritage has submitted objections to the current application at this site on heritage grounds. These relate to adverse effects of the new dwellings on the setting of the "historic medieval farm complex" (para 9. 100), namely Barnhorn Manor and to the related gateway features fronting Barnhorn Road. We maintain these objections, the "care" required by the text is not reflected in the Figure 29 Detail Map.

5) Site Allocations - Land at Gulliver's Bowls Club Knole Road - Reasons Unsound Alteration Needed

It is not clear why this site is specifically allocated for sheltered housing. No such specific allocation has been placed on a site which, in or view, is far more suitable for sheltered housing given that it is close to the town library and a large supermarket - land south of Terminus Road (policy BEX8).

At Knole Road the specific allocation reduces the possibility of a development that sufficiently reflects the need for a high quality building appropriate to the setting of the listed buildings opposite.

Policy BEX5(v) calls only for the development to "not adversely affect the character of the area or the setting of the listed terrace to the south". This is insufficiently robust and BEX5(v) should be altered to read -

(i) "some 40 flats are provided of which 30% are affordable"

(v) "the design of the scheme with a maximum of 4 storeys should be of the
highest architectural quality".

Site Allocation BEX6 - land adjacent to 276 Turkey Road - amendment

Here, for the first time, at para 9.72 is a specific reference made to the "potential future redevelopment of the Cemetery Lodge site". The implication of this wording is that there is the possibility of Cemetery Lodge being demolished. We are entirely opposed to the demolition of this fine Edwardian building which our surveys have proved to be in good condition. We therefore seek the deletion of the offending final
sentence of para 9.72.

We trust the Inspector will take due notice of our representations and afford Bexhill Heritage the opportunity to appear at the Examination hearing to explain and expand upon these further, and respond to questions.

Rother District Proposed Submission Development and Site Allocations Local Plan

Thank you for your email of 26 October 2018 inviting comments on the above document.

As the Government's adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process, and welcomes the opportunity to comment upon this key planning document.

Historic England's comments are set out detail below:

The adopted Local Plan Core Strategy contains a range of detailed policies, relating to Strategic Objectives, Spatial Strategies for significant character areas, and Core Policies for the historic built environment (e.g. Policies EN1 - EN4) that, in our view, meet the test of providing a positive strategy for the historic environment required by the NPPF paragraph 185 (July 2018). While there are not specific policies for the historic environment within the draft Development and Site Allocations DPD, we are content that alongside the Core Strategy policies there are sufficient references throughout the policies in the draft DaSA Local Plan to protecting and enhancing historic character and heritage assets (e.g. DHG9 (v), DHG11 (i), DEC1 (i), BEX2 (v), BEX4 (vi), BEX5 (v), CAT1 (v), FAC1 (vii), NOR1 (iv), etc. ) that the historic
environment will be appropriately taken account of in development management and site planning decision-making.

We are content that the Strategic Environmental Assessment (Sustainability Appraisal Environment Report) appropriately assesses the potential impacts on the historic environment of the policies and programmes set out in the draft DaSA Local Plan.

These comments are based on the information provided by you at this time and for the avoidance of doubt does not reflect our obligation to advise you on, and potentially object to, any specific development proposal which may subsequently arise from this or later versions of the plan and which may, in our view, have adverse effects on the historic environment.