Core Strategy Consultation on Strategy Directions 2008

Object

Representation ID: 19762

Received: 30/01/2009

Respondent: East Sussex County Council

This section does not specifically mention the need to conserve minerals as a natural resource. For Rother District this includes clay, gypsum and aggregates. To underline this omission the key indicators for this section are concerned with water, energy and the use of brownfield land.

It should be made clear that the core strategy has a significant role in minimising construction waste and the recycling of materials.

Moreover, it is not clear how the Core Strategy has taken into account the RPG9 and it s requirements for local planning authorities to support the delivery of effective waste management and the prudent management of mineral resources
Given the requirements of the RSS the strategy should be amended accordingly.

Comment

Representation ID: 19763

Received: 30/01/2009

Respondent: East Sussex County Council

Rye Harbour (Box 15 (ii) and supporting text.

Although no obvious conflict is evident the County Council would be concerned if the strategy option to promote additional port activities were to compromise the operation of the existing permitted minerals wharf.

The County Council would welcome the opportunity to work with the District Council on the matters outlined above.

Comment

Representation ID: 19764

Received: 30/01/2009

Respondent: East Sussex County Council

Key to the pressing need for the District to provide affordable housing is the issue of viability and ability of developers to deliver the percentages of affordable housing proposed in the Core Strategy.
The County Council would wish to maintain its engagement with the District Council on this matter.
Clarification is sought on the statement at paragraph 10.28 where a small amount of market housing, effectively to incentivise the development of affordable housing allocations in the rural areas would be appropriate. It is not clear whether this is a reference to exception sites or not. Structure Plan saved policy H5 and Planning Policy Statement 3 (Housing) state that rural exception sites for affordable housing must not contain an element of market housing.

Object

Representation ID: 19765

Received: 30/01/2009

Respondent: East Sussex County Council

Archaeology and archaeological potential does not seem to be mentioned - there is little time depth to the core strategy. Understanding of the layers of historical environment built and rural would help define the various distinct elements that go to make up Rother.
Historic Landscape Characterisation is now completed for Rother and should be mentioned in the Core Strategy to help define the character and potential of discrete areas.

This evidence should be used to bridge the gap between the strategies for Landscape Stewardship and Design Quality and the Built Environment. Policy development in this area would contribute greatly to understanding what makes Rother distinctive and is considered essential to the delivery of the Core Strategy's objectives, as set out in Box 2.

Comment

Representation ID: 19766

Received: 30/01/2009

Respondent: East Sussex County Council

Whilst it is acknowledged that this consultation document is strategic in nature and greater detail will be provided in subsequent DPDs and SPDs, it is important the housing needs of older people and other vulnerable groups including those with learning disabilities are recognised in the core strategy.

Additional comments are as follows

Para 10.40 (page 94) replace elderly with older people

Para 10.61 (page 100) whilst it is understood that the majority of older people live in Bexhill, over 40% of older people live in the rural areas. The core strategy should acknowledge this and the challenges it presents in terms of meeting their needs.

Para 10.65 (page 100) it should be noted that the Housing and Support Strategy covers the period 2007 - 2027 and the Joint Older People's Commissioning Strategy was published in 2007.

Comment

Representation ID: 19768

Received: 30/01/2009

Respondent: East Sussex County Council

The emphasis is on mitigation (reducing green house gas emissions). Planning Policy Statement 1 (climate change supplement) requires LPAs to minimise vulnerabilities and provide resilience to climate change. Work on meeting the requirements of NI188 (key climate vulnerabilities) is at an early stage and is being undertaken jointly by all East Sussex authorities .Consequently, the timing of the core strategy and the development of climate change resilience throughout the County is misaligned. The Core Strategy would benefit from an understanding of the climate effects and impacts on key sectors and what this would mean for spatial planning policy. This would also align the draft core strategy with the objectives of the South East Plan (proposed changes) policy CC2.

Comment

Representation ID: 19769

Received: 30/01/2009

Respondent: East Sussex County Council

Without the BHLR there is no realistic prospect of providing sustainable growth on the level required by the RSS in Rother District.
The proposals for the development of the Hastings Fringes at Breadsell and Wilting are subject to varying degrees of uncertainty.
Windfall sites within Bexhill will contribute to the overall development requirement, but have not been included in the Core Strategy's estimation.
The Core Strategy claims to provide for a range of 5,600 - 5,850 dwellings, the components of supply provides a range of 5,500 - 6,000. This undershoots the requirements. Clarification is sought on the actual level of development the Core Strategy is planning for, and how the uncertainty surrounding the Hastings fringes can be managed.

Object

Representation ID: 19770

Received: 30/01/2009

Respondent: East Sussex County Council

The draft strategy introduces some flexibility to emplyment provision by considering development at Rye Harbour Road. The deliverability of development (20, 000 sqm) at this location is uncertain given its lack of strategic communication links.

The Core Strategy sets out employment land requirements but not job numbers. It is difficult to discern what extent the quantity and distribution of employment land will provide for employment growth.

Comment

Representation ID: 19771

Received: 30/01/2009

Respondent: East Sussex County Council

Chapter 12

A reference to following should be added to the text:
The need to identify, protect and manage Local Sites (which in Rother are called Sites of Nature Conservation Importance)
Note: reporting on management is required under the National Indicator: NI197 - Improved Local Biodiversity - proportion of Local Sites where active conservation management is being achieved.

Comment

Representation ID: 19772

Received: 30/01/2009

Respondent: East Sussex County Council

In box 30: The Preferred Strategy for Biodiversity and Green Space

Paragraph (b) makes a reference to "mitigation" that should be a reference to "compensation". The last phrase should read: including measures to mitigate against or compensate for any losses;

(Note:: 'mitigation' - provisions to avoid or reduce adverse impacts on species or habitats;
'Compensation' - measures to provide for replacement or enhancement of species populations and habitats lost or damaged).