Core Strategy Consultation on Strategy Directions 2008

• Vision for 2026: 'sustainable economic growth will have been secured...' This will only be the case if opportunities to expand and enhance the tourism and leisure facilities are fully explored. The vision needs to recognise a need to accommodate the changing needs and aspirations of visitors by having a flexible approach to expansion and redevelopment of the existing tourist facilities. This is not demonstrated by the policy directions wording.

• Rural areas of the district will have evolved "organically"...etc. This statement is at odds with general intentions elsewhere in policy, to realise opportunities to substantially expand and upgrade existing brown-field sites whether or not in rural areas. In particular this statement does not recognise the opportunities which exist to grow the tourism and leisure industry in coastal resorts such as at Camber. Such opportunities may be significant in scale and not 'organic' in character. Draft PPS4 makes clear the need for Core-Strategy visions to support and encourage economic opportunity:

"Using evidence to plan positively
Regional planning bodies and local planning authorities should use a wide evidence base to understand both existing business needs and likely changes in the market, to prepare policies to support sustainable economic development in their area.

18. To achieve this, regional planning bodies and local planning authorities should:
• Thoroughly assess the existing supply of land available for economic development through an employment land review. Where possible, land use reviews, such as housing and employment, should be undertaken at the same time to ensure a full assessment of competing land uses is made. Where appropriate, local authorities should carry out joint land use reviews;
• Ensure that the strategy addresses the particular needs of rural areas in terms of new economic opportunities..."

• This Planning Policy Statement has been through public consultation and although not yet in its final form, clearly remains a material consideration for the formulation of local planning policy. It is clear that government policy requires Local Planning Authorities to investigate and encourage new economic opportunities - whether or not in rural areas.

• Tourism is the biggest Industry in the world by measure of both income and scale of employment generated. In Rother, your evidence-base recognises the value of both aspects to the functioning of the District. Much of the local tourism and visitor attraction facilities are to be found in rural and coastal areas and many within smaller settlements and villages, simply because it is the natural environment that attracts visitors.

• We do not believe that the overall vision has fully addressed the requirements of PPS4 in this regard. In our view, the vision needs to identify the employment generating opportunities associated with enhancing the range, quality and choice of tourism and leisure-based activity for visitors within the District as a whole and the resort of Camber in particular.

• We object because the Core-Strategy fails fully to take account of the obligations and requirements imposed by draft PPS4. Whilst Para 5.1 of the consultation paper recognises the need for the overall spatial strategy to carry forward the National and Regional policies, it fails to take mention or take account of PPS4 as important and relevant emerging National policy. As a result, we believe that the objectives fail to fully recognise the importance of providing a welcoming approach to opportunities for the tourism and leisure business to expand and improve within the District as a whole and in Camber in particular.

• In particular, the aspirations and needs of tourists are undergoing a significant change both within the UK and internationally. This is a trend now accentuated by the worsening economic background, where visitors expect a broader and higher quality experience. Similarly, leisure habits of the population are changing. Policies being formulated today cannot adequately anticipate how these changes will manifest themselves.

• It is essential therefore that policy to cover the next fifteen years allows flexibility to accommodate unforeseen needs without stifling the economic engine that tourism and leisure has become. This is equally relevant to established and emerging rural and coastal tourism and leisure facilities as it is for the tourism sector within the urban areas of the District.

• Again, draft PPS4 makes clear the Government's new and high priority objectives towards fostering economic growth. In her Introduction, The Minister says...

"As a result of this new policy, regional and local planning bodies will support economic development by ensuring that they understand and take into account what their economies need to remain competitive, and responsive (my underlining) to the needs of business, and factor in the benefits of economic development alongside environmental and social factors."

• In this statement, Government clearly recognises the need for flexibility of approach with policy-making at a local level. As worded, there are a number of Policy Directions and references within the background papers which would inhibit a "responsive" approach, if adopted.

• And in paragraph 24 of PPS4:

"Due to the increasing demands on the land available for development, local planning authorities should seek to make the most efficient and effective use of land and buildings, especially vacant or derelict buildings (including historic buildings).

• And in paragraph 25:

"Encourage new uses for vacant or derelict buildings, including historic buildings and buildings in rural areas, as this can contribute positively to an area's regeneration, provide wider economic benefits, help to preserve historic assets and also reduce the need for Greenfield development"


• The PPS continues:

"....local planning authorities should use a wide evidence base to understand both existing business needs and likely changes in the market, to prepare policies to support sustainable economic development in their area"....

18. To achieve this, regional planning bodies and local planning authorities (my underlining) should:
• Ensure that the strategy addresses the particular needs of rural areas in terms of new economic opportunities,
• Take account of the different locational requirements of businesses, such as the size of site required, site quality, access and proximity to markets, as well as the locally available workforce;
• Take account of relevant market information -- and economic data, including price signals;
• Ensure the plan supports existing sectors, taking into consideration whether they are expanding or contracting;
• Where possible identify and plan for new or emerging sectors likely to locate in the region/sub-region/local area or which the regional planning body or local planning authority wish to attract to the region or area, but maintain flexibility to accommodate sectors not anticipated in the plan;
• Recognise, and positively plan for, the benefits that can accrue when certain types of businesses locate within proximity of each other or with other compatible land uses ...."

• Paragraph 5.4 of the CS states that the aims and objectives "highlight the main priorities in determining the pattern of activity and development across Rother District. They reflect both the strategic need for economic regeneration and growth of the coastal towns, especially for Bexhill (and Hastings), and the environmental sensitivities in meeting economic objectives and other community needs in Battle, Rye and the smaller settlements, and in the countryside";

• However, we cannot see that this has been taken into account when preparing the overall spatial strategy aims and objectives, since none of the listed objectives refer to 'supporting existing sectors' ; 'identifying emerging sectors'; 'maintaining flexibility'; or 'positively planning for businesses (locating together)' ; etc.

• In this context we object to objective (iii) - because it fails to recognise and plan for the likely benefits of encouraging positive change through re-development and expansion.

• We object to objective (vi) - because tourism and leisure needs are much more than 'local' and visitors need to be encouraged to support economic growth and opportunity for all.

• HOUSING: The evidence based studies on Housing do not examine the various sectors of housing which make up the overall requirement. The UK has an ageing population and catering for the increasing needs of this growing sector is an essential component of any planning housing policy. There is a wide range of housing need for those who are broadly over 50 yrs of age.

• Many of the sub-sectors are quite specialist and new sectors are continuously evolving. An example of this is the increasing tendency for semi-retirement. For those taking part-time or reduced time employment, leisure and tourism ambitions are often achieved through dividing living between two residences. This has been traditionally manifest through ownership of caravans or mobile homes for weekend and holiday use.

• However, there is now an emerging market for more traditional homes for use on a part-time basis. Sometimes this means occupation during the week but not at weekends and during off-peak seasons where owners choose to avoid holiday crowds. If encouraged, this trend could help to provide a better balance to the peak period pressure on infrastructure and services.

• In this connection, the housing policies need fully to recognise and cater for a range of housing sector types as a specialist and rapidly expanding broader sector for an ageing population. These will include for a range of need including for the following:

• Holiday homes (including caravans, mobile homes and time-share homes),
• 'Life-style' homes' including second homes,
• Sheltered housing,
• Retirement homes,
• Care-homes and,
• Nursing homes.

• As with the overall national trend, at Rother there is a well established and growing demand for specialist housing to cater for older residents (not necessarily the retired). These include those from the indigenous population, as well as those who have resorted to Rother for many years as holiday-makers and new-comers.

• Government policy now gives much greater recognition to meeting the needs of the elderly and is committed to changing the culture of planning to make it "more responsive, positive and proactive". This statement is within the Planning and Compulsory Purchase Act 2004, which explains what is required at a regional and local policy-making level. Diversity and equality are at the heart of this agenda.

• The Government is also committed to creating strong, vibrant and sustainable communities and to promoting community cohesion in both urban and rural areas. These are important elements of delivering sustainable development, which the Government defines as the principle purpose of the planning system.

• Planning Policy Statement 1 (PPS1 2005) states that planning for sustainable development means 'meeting the diverse needs of all people in existing and future communities, promoting personal well being, social cohesion and inclusion and creating equal opportunity for all citizens'.

• It goes on to state that: 'Development plans should promote development that creates socially inclusive communities, including suitable mixes of housing. Plan policies should:

• ensure that the impact of development on the social fabric of communities is considered and taken into account;
• seek to reduce social inequalities;
• address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities;
• take into account the needs of all the community, including particular requirements relating to age, (my underlining) sex, ethnic background, religion, disability or income;
• deliver safe, healthy and attractive places to live; and
• support the promotion of health and wellbeing by making provision for physical activity.'

• Planning Policy Guidance Note 3: Housing (PPG3) is clear in its requirements that:

"Local authorities should plan to meet the requirements of the whole community, including those with 'special needs'. Amongst the 'specific groups' whose needs should be assessed and planned for are 'the elderly'." (My underlining)

• There are several other Government policy documents which have addressed the needs of older people. For example, Quality and Choice for Older People's Housing (DETR 2001) says:

"The increasingly older population poses a challenge for social policy generally and housing policy specifically."

• More recently the Green Paper "Opportunity Age" (Department of Health 2005) sets out the key principles of the Government's strategic approach towards older people, including:

• promoting their well-being and independence and providing them with choice and accessibility;
• tackling discrimination against older people;
• ensuring that local authorities take a lead role in planning for the ageing of their community

• The lack of any reference to this specialised housing sector in the evidence-based supporting documents, results in the CS paragraphs 5.7 - 5.12 also making no mention of providing for this sector.

• It is our view that specific recognition of this housing sector should be made in this section of the CS and that aims and objectives should plan for its expansion directing development to appropriate areas. We believe that this should include provision for the expansion and re-development of Housing, Chalets, Caravan and mobile home parks where these cater for those who are retired, semi-retired and elderly.

• We reiterate our concern that new policy should provide for a flexible response to emerging and as yet, unidentified market sectors. This is particularly important in order to secure an enhanced and buoyant tourist and leisure-based economy for Rother for the lifetime of the Development Framework and beyond.

• EMPLOYMENT: The preferred spatial strategy makes no mention of the promotion and growth of tourism and leisure industry within rural and coastal settlements such as Camber. Although Camber is specifically recognised as having an established and particular tourism niche by virtue of its natural assets; the way in which the changing patterns of tourist and visitor ambition is to be accommodated is not examined or catered for.

• As already stated, Draft PPS4 requires Local Planning Authorities to support and encourage business expansion where it is sustainable and can be balanced with environmental factors. This expressly includes those within rural areas.

• In paragraph 32, PPS4 states:

"In rural areas, recognising that accessibility - whether by private transport, public transport, walking and cycling - is a key consideration, local planning authorities should:

• Recognise that a site may be an acceptable location for development even though it may not be readily accessible by public transport;

• Support small-scale economic development where it provides the most sustainable option in villages that are remote from, and have poor transport links with, local service centres."

• At Camber, the long-established holiday parks are businesses which contribute significantly to the local economy. Indeed, they are the principle reason for the growth of the settlement itself. Specifically the Pontins Holiday Park employs 250 people (most local) with a significant multiplier for locally-based secondary employment.

• This ranks the holiday park as one of the District's major employers. We find it odd that the policy documents fail fully to recognise the value of the tourism and leisure industry as a driver to economic prosperity that plays a pivotal role in the overall Spatial Development Strategy. That this role should be encouraged to expand and achieve its full potential is without question what is required in draft PPS4

The preferred criterion do not include brownfield sites as appropriate starting point for new and expanded business (or other uses). PPS4 requires LPA's to accept such sites as an resource for redevlopment even if lacking sustainable transport and located in rural areas - refer to our linked objections

There is immense scope for providing high quality development by recognising the potential for existing poor quality sites to be redevloped. As a brown-field resource, such sites are often within communities and residential areas where they act to the detriment of wider areas due to the existence of outdated and poorly designed buildings. Criteria should recognise this as a principle and valueable opportunity.

• We object to the use of the word "local" in the first sentence of this box. The Core Strategy needs to cater for wider than just "local" needs, when accommodating the needs of tourists and visitors. The economic performance of Rother and Camber particularly relies on a flexible vision for growth and a restructuring of tourist-related activity in accordance with draft PPS4. This cannot be achieved by narrowing opportunity to just "local" needs.

• Whilst point (viii) supports sustainable tourism and recreation, there is no stated objective to cater for the growing need to accommodate those wishing to adopt semi-retired, fully retired or 'life-style' choice of home or residential environment. Such accommodation already exists within some rural and coastal settlements, including Camber, where significant numbers of residents already occupy premises, chalets, mobile homes and caravans on either a part-time or full-time basis.

• Neither is any reference made to the need to re-focus and upgrade tourist and visitor accommodation. Yet this sector represents a significant part of the overall housing requirement, albeit part-time in many cases. An objective should be to cater for this in a flexible way, having full regard to the advice and requirements of draft PPS4.

• We object to the evidence-based paper 'Rural Settlements' Nov 2008, because the economic profile makes no mention of the tourism and leisure sector as an employment-generating activity. This is most surprising since significant numbers of jobs are provided through this. We believe that Pontins Holiday Park is the largest single employer in Camber, but again this is not recognised.

• We object to the Rural Settlements background paper's findings as incorporated in paragraph 9.16 of the CS. These findings offer no opportunity to expand and enhance the important tourist and visitor facilities and accommodation within villages, including at Camber. This is contrary to the aims and requirements of draft PPG4 and risks harming the significant economic role already established by the businesses in this sector.

• The preferred option of a mixture and selection of those options stated does not in our view therefore, represent an optimum solution. The Council's preferred option is not therefore based on all the available evidence for the functional requirements of villages and is flawed in this respect.

• Whilst Camber is recognised in the Rural Settlements paper as a village which would benefit from more local employment, we view the lack of any reference to the village's largest employment sector or of its potential for growth and improvement to be a serious oversight.

• We note and have studied the several local studies including the Camber Visitor Management Initiative and the Camber Environmental Strategy. However, we consider it premature to decide on a 'preferred option', without a thorough examination of the precise nature and character of the existing tourist and visitor facilities and more particularly the various types of associated accommodation within Camber.

• The object of the CS is to provide a framework for carrying forward the Vision to 2026. The vision is lacking a clear direction and focus for the tourism and leisure sector and this is essential given the rapidly changing character of demand. The evidence base documents recognise the need to provide a better visitor experience as clearly expressed in the Camber Visitor Management Initiative 2004.

• Yet whilst the Tourism section of the CS following box 26, sets out to recognise and support the role of tourism in Rother, we believe that these aims will be potentially frustrated by the restrictive approach set out in this Rural Areas section. For example, the 'scope' and 'Strategy Directions' sections do not recognise any potential to improve or expand visitor and tourist accommodation within rural settlements and make no reference to Camber in particular.

• We object to the findings of the Rural Settlements background paper as expressed in paragraph 9.20 of the CS for service centre settlements. Camber is one of the largest villages within Rother and although lacking a Primary School, does have a wide range of other community and social facilities. It is fundamentally different from most other villages, because its historic growth results from tourism and it remains a settlement based overwhelmingly on providing for the needs of visitors and tourists.

• The inclusion of holiday parks and leisure facilities within the settlement, alongside the ready access to sea, dunes and ecologically rich habitats and high quality landscape; make Camber a particularly sustainable community since all of these attractions are readily accessible on foot. Moreover, those wishing to experience these assets generate a wide variety of permanent and part-time jobs for local residents, further enhancing the service centre role in a sustainable way.

• Given the number and range of facilities to be found at Camber - as identified in the Rural Settlements Appraisals background document, we consider that Camber should be classified as a Local Service Village.

• Whilst we note that the section on the (rural) Economy at paragraph 9.39 recognises the importance of tourism including at Camber, this does not focus on the opportunities we believe exist to expand and enhance the facilities and the accommodation that services them. We note that the paragraph simply refers the reader to the employment section of the CS. In our view this fails to show clear direction in aims, objectives or vision.

• We object to the wording of section (a) 'for the economy' because it doesn't offer any opportunity for larger scale development or redevelopment of the existing tourist, leisure and associated accommodation facilities.

• We object to section (e) 'For Housing' because no provision is made for tourist accommodation as part of the existing housing stock, some of which is already occupied on a semi-permanent basis; we also object to the lack of provision of housing and sites specifically for the elderly, the retired and the semi-retired. For the reasons set out in our objections in Box 3, this does not accord with Government policy which requires policies to be inclusive and also requires Local Planning Authorities to proactively cater for the needs of the elderly and retired.

Although the wording advocates the retension and expansion of employment sites it does not include this for villages

• We object to the wording of section b 'For the Countryside Economy' for making no references to tourism which is rurally based. Such businesses are supported and encouraged by policies in draft PPS4 and are essential to the rural economy across the UK and to Rother District in particular.

• Whilst the wording of section c 'For Development in the Countryside' goes some way towards recognising the value of tourism within rural areas, we object to the lack of specific references to the need to accommodate visitors within the rural communities; the countryside and the coastal areas. The last bullet point in this box should include reference to potential for expansion; for redevelopment and for improvements to tourist and leisure based activities.

• In paragraph 9.74, we object to the lack of references to Tourism South East as being the appropriate 'lead' agency for (a) the economy within villages and also for (b) the Countryside economy within the countryside itself.

• Whilst we support references in this box to the inclusion of adequate accommodation for the elderly, we are concerned that no specific reference is made for the retired, the semi-retired and for those who resort to and occupy tourist accommodation on a semi-permanent basis. PPS1 requires Local Planning Authorities to adopt policies that "take into account the needs of all the community, including particular requirements relating to age, sex, ethnic background, religion, disability or income".

• It is noted that the proposed CS addresses the imbalance of resident population which has a higher than average proportion of residents over the age of 45. However, whilst we support the aim to use development proposals as a means to fund the provision of affordable housing, we do not believe it appropriate to apply this across all sectors.

• Developments aimed at different housing sectors such as sheltered Housing, retirement housing, holiday chalets, time-share, etc. will produce quite different financial viabilities. Specialist services and care facilities necessary to support homes designed for the elderly impose an increased financial burden on the development and may restrict its ability to contribute an affordable housing component.

• It is government policy that housing provision should provide for all sectors including for the elderly. However, housing designed specifically to meet the needs of specialist housing groups (for example as with student accommodation) doesn't necessarily lend itself to a haphazard mix of occupants forced upon it by affordable housing policy. The suggested blanket approach to affordable housing comprised in the SPD and these policy documents represents a crude and inappropriate tool when applied in these circumstances.

• As a result, we believe that the affordable housing policy presents a serious risk to both the financial and the functional viability of many types of housing scheme resulting in the abandonment of many potentially valuable schemes. As a result, attainment of the higher order aims and objectives of the Government and of Rother Council will not be realised. Accordingly we do not agree that the Council's adopted SPD on Affordable Housing is likely to achieve its aims of providing more affordable housing within the District.

• The recent Court of Appeal case - Blyth Valley Borough Council v Persimmon Homes (North East) Ltd and others - demonstrated that local planning authorities must recognise the 'crucial requirement of the PPS that an economic viability assessment of any percentage figure was a central feature of the policy on affordable housing'. The evidence base listed on the Council's web-site as background papers upon which the policy directions are based includes a Housing Needs study dated 2005, a housing strategy document dated from 2004 and a Hastings and Rother Housing Market Assessment 2007.

• The work leading up to the publication of these documents was of course undertaken some time before these dates all of which not only pre-date the current economic recession, but also were formulated during the height of a long period of inflationary pressure on land transactions and within the housing market in general. The Court of appeal held that Blyth Valley 'failed to reflect the requirement of the PPS as to the need for an informed economic viability study as part of the process leading to a policy requiring a particular percentage of affordable housing.' We do not believe that the Council's data is adequately up to date to fulfil this requirement.

• The background papers show no evidence of any financial viability work having been undertaken to inform the process of selecting a particular percentage affordable housing requirement. Even had it done so, such evidence would not have taken account of the dramatic changes in housing market viabilities resulting from the world-wide economic down-turn and housing recession in the UK resulting in falling land and property prices. We believe that this would leave an Inspector with no alternative than to find a core strategy legally flawed and unsound.

• Moreover, the fragility of the housing market in terms of viability is unlikely to meet the overall objective of providing additional housing to meet the needs set out in the draft RSS for the SE. To universally and without up to date financial viability tests, apply punitive costs to housing schemes further increases the likelihood of allocations and housing permissions being unimplemented. Delivery of (appropriate) development is the principle aim of the Development plan process and this will fail without proper regard to viability.

• We suggest that it would be appropriate to aim for an overall increase in affordable housing provision within Rother District, in line with the emerging regional policy. However, we suggest that it should generally only apply to open market schemes and not at all to those specifically designed for specialist sectors such as for retirement and for student accommodation. In any event, all applications of such a policy should be subject to up to date financial viability tests for any given site.

• In this regard we suggest that it will be necessary for the Council to indicate in the framework documents a system of ranking 'planning gain' requirements in order for infrastructure; service & utility; social; community; carbon reduction and all other development costs to be prioritised in order to inform the development process in a transparent way.