Core Strategy Consultation on Strategy Directions 2008

The draft South East Plan requires the Council to provide for 4,000 of the 5,600 dwellings to be built in Rother between 2006 and 2026 in the coastal sub-region of the district to promote its regeneration.

It would therefore be appropriate for the Distribution Options Table at Paragraph 5.36 to separate the villages in the coastal sub-region from those inland.

This would provide a more accurate picture of whether the distribution between the two areas complies with the emerging South East Plan.

Paragraph 5.36
We do not agree that Option 2 - 'Service Centres' is the most appropriate distribution of development for the area.

The figure of 3400 dwellings for Bexhill proposed under Option 2 is based on the assumption that the Bexhill to Hastings Link Road will go ahead as set out in the 2008 Regional Transport Programme, with work commencing in 2009/10 and finishing in 2012/13.

Paragraph 5.79 recognises that this significant growth for Bexhill is reliant upon the construction of this road. However, there is currently considerable uncertainty regarding its timing and implementation.

The cost of the scheme has more than doubled since 2004 and the Regional Transport Board is in the process of considering whether it can continue to support the scheme given the increased cost. Even if it does, it is doubtful that the road will be provided on the proposed timetable.

Paragraph 5.84 sets out the implications of any delay in the opening of the Link Road on the number of houses built.

It states that a three year delay would result in 500 fewer houses.

Paragraph 5.86 sets out a number of options or contingencies in the event of delay or cancellation of the Link Road.

We support the proposal that additional sites in other towns and villages would be allocated to maintain development levels and the recognition (Paragraph 5.87) that there may be a margin for more development than currently planned at Battle.

However the inference is that the Core Strategy would be amended after its adoption to address any shortfall. This would presumably need to be done through a review of the Core Strategy and the Site Allocations DPD which would require a new round of consultation and examination.

An alternative would be to adopt the approach which has been used by other authorities and which directly addresses the issue of infrastructure uncertainty and that is the concept of 'reserve sites' (see East Hampshire District Council et al).

We believe infrastructure delay needs to be considered now and additional sites identified that could be reserved in the event of a delay because it is highly likely that the situation on the Link Road will become clear between now and the public examination of the Core Strategy.

If a delay (or cancellation) was clear at that stage the Core Strategy may well fail to meet the Council's obligation to provide the necessary land supply upon the adoption and thus run the real risk that it is found to be unsound. The Inspector would not be able to accept an early review of the CS/Site Allocatons as an acceptable contingency plan.

The higher level of housing required to cover the possibility of infrastructure delay would not be contrary to Government aims or objectives.

Government has made it clear that it wishes to see a step change in housing delivery and that the housing figures in the draft South East Plan are considered to be minima rather than maxima not to be exceeded.

An increase of c 500 dwellings at the other towns or villages, either allocated/phased or as 'reserve sites' would cover any likely potential delay to the Link Road and associated development at Bexhill.

The proposal that such an allocation or allocations should include prioritising the higher order service centres such as Battle is supported.

In summary
The strategy proposed is considered to be unsound as it does not include any contingency plans which would address the issue of delayed (or cancelled)infrastructure.

The Council should include specific contingency plans that the Inspector can examine for soundness when considering the CS.

It is suggested that the Council consider additional allocations of c. 500 dwellings either as phased provision or as reserve sites.

Paragraph 5.59 says that the degree of growth proposed for Battle under Option 2 is moderated due to environmental constraints.

However, we consider that the constraints are not as great as suggested and that the town has the capacity for further residential growth without significant detriment to the environment.

In particular we contend that Battle is able to accommodate the 920 dwellings identified in Option 5 of paragraph 5.36 and which the Council acknowledges is the level that is required to meet the housing needs in the town.

We do not agree that the environmental constraints at Battle are so severe that the town should not make provision to meet its locally generated need.

Appropriately located development could be accommodated without having a detrimental effect on the environment.

Paragraph 7.19 identifies 5 sectors within Battle which the Council is considering with a view to accommodating additional development.

Sectors 4 & 5 to the south and east are considered in Paragraph 7.20 (subject to further investigation) to offer the most potential for development in the longer term.

We do not support this view.

As the Council notes sector 5 encroaches on land that is in the strategic gap between Hastings and Battle.

We contend that sector 1 should be seriously considered for some of the required housing development for the following reasons:

Battle's existing primary school, which the County has committed to expand, and Battles secondary school are both located within sector 1.

Developments in sectors 4 or 5 (see fig 2 Urban Options background paper)would generate cross town movements associated with trips to and from the Battle's primary and secondary schools.

Development in sector 1 would generate cross town movements associated with commuter trips to and from the station.

Station bound commuter trips from development to the west of the town are likely to cause less overall traffic congestion as these generally leave and return outside of travel to school time when traffic congestion is at its highest.

Locating development in sector 1 makes walking to and from school a real possibility.

Sites within this sector are also potentially within walking distance of the town centre via public footpath 82.

This footpath could be resurfaced and radically improved utilising developer contributions.

Thus development associated with a footpath improvement would have the added benefit of potentially increasing access to the town centre on foot and reducing car journeys of some existing residents.

In summary we submit that:

i) The environmental constraints at Battle are not as great as suggested

ii) Battle should provide 920 dwellings, sufficient to meet its locally generated need

iii) Sites in sector 1 should be considered as these are closer to the existing schools which will encourage walking to school thus cause less additional congestion than those located in sectors 4 and 5

iv) Development located to the south west of the town in association with improvements to footpath ... would provide improved walking access to the school and town centre

Under the Preferred Strategy Direction for Battle (f) Development and Housing section i) should say 'Providing for 920 additional dwellings in Battle over the Plan Period...' and Section iv) should include 'land to the south of North Trade Road, west of High Street', within its area of search for the reasons given in representation 19174