Proposed Submission Core Strategy

1. It is considered that the proposed Overall Spatial Development Strategy is unsound because it seeks to focus too much development on Bexhill.

2. A key presumption that underlies the Core Strategy is that the Hastings-Bexhill Relief Road will be built within the plan period. This will facilitate significant development at Bexhill that will help to provide the amount of housing land needed to meet the need for housing in the District. It is clear from the Council's Infrastructure Delivery Plan that while there is a desire for the road to go forward, there is no certainty that it will.

3. The implementation of the road is dependent on the provision public funding, and there is no certainty that the necessary funds will come forward. Further submissions are being made to the Government by East Sussex County Council at the end of 2011 and a decision will be made some time in 2012. Given that a key element of the Core Strategy is based on an eventuality that is, as yet, unknown and uncertain, it must be unsound.

4. It is also the case that the market for housing in Bexhill is not particularly strong and there is considerable doubt that the numbers of houses proposed to be built at the town will actually be delivered.

5. There are other locations in the district that are fully capable of delivering more housing than the Council has identified. There is more scope for development at Rye, Battle and on the fringes of Hastings than the Council has allowed for. Focussing too much development on Bexhill is an unbalanced approach, which will not deliver the amount of housing that the District needs.

1. It is considered that the strategy for the provision of Business Land and Premises set out in this policy is unsound because it recognises that the majority of the 100,000 square metres of floorspace to be created is dependent on the provision of the Hastings Bexhill Link Road. As the deliverability of this key element of the Core Strategy is unkown and uncertain, the document itself must be unsound.

2. The various items in this policy are all heavily dependent on public investment in services, which, at a time when public spending is extremely constrained, is an unjustified approach. There is no recognition of what the Council can do, through the Core Strategy, to foster private investment in economic activity and growth.

Introduction

1.1 It is considered that the proposed Policy Strategy for Rye and Rye Harbour as set out in Policy RY1 is unsound for the following reasons:

* The Policy is not 'effective' in that it will not deliver the type, scale and nature of development that is needed to secure the long term social and economic needs of the town.
* The role that Rye can play in the delivery of housing in the district is underestimated in that the generalised reference to the environmental constraints surrounding the town is unjustified, and inadequate consideration has been given to how existing sites within the built up area can be delivered.
* Too much emphasis is placed on additional employment development in Rye Harbour Road Industrial Estate, which is both unlikely to be deliverable and contrary to the air quality constraints set by the Habitat Regulations.
* The policy is not sufficiently flexible to allow for development opportunities in and around the town that would contribute to the delivery of the key objective of the town, which is to provide more and better quality employment and housing.

2.0 Housing Provision

2.1 A key presumption that underlies the Core Strategy is that the Hastings-Bexhill Relief Road will be built within the plan period. This would facilitate significant development at Bexhill that will help to provide the amount of housing land needed to meet the demand for housing in the District. It is clear from the Council's Infrastructure Delivery Plan that while there is a desire for the road to go forward, there is no certainty that it will.

2.2 The implementation of the road is dependent on the provision of public funding, and there is no certainty that the necessary funds will come forward. Further submissions are being made to the Government by East Sussex County Council at the end of 2011 and a decision will be made some time in 2012. Given that a key element of the Core Strategy is based on an eventuality that is, as yet, unknown and uncertain, it must be unsound.

2.3 The constraints that have been identified as restricting the development opportunities at Rye have been over-stated. There are opportunities for development on the edge of the town that will not harm any statutory designations or cause any material erosion of the topographical and landscape context. They will enable the provision of more housing in the town and facilitate economic investment that the town will otherwise find it difficult to attract.

2.4 Policy RY1 should be amended to allow such development to come forward. In this context the number of dwellings that can be provided at the town should be increased to 350-450.

2.5 This will allow greater flexibility in the provision of housing in the District in the light of the uncertainty over the future of the Hastings-Bexhill Link Road. Furthermore, the market for good quality housing in Rye is much stronger than the general housing market in Bexhill, therefore there is a greater likelihood that this housing will come forward within the plan period.

3.0 Economic Development

3.1 The policy is unjustified in relying on the promotion of 10,000 square metres of employment floorspace at Rye Harbour Road to provide economic regeneration for the town. Such development would contribute to the further visual intrusion into the open land between Rye and Rye Harbour. Being in the centre of the gap between the two settlements, further development in this location is much more visually intrusive than modest urban extensions.

3.2 There are significant opportunities to foster economic regeneration close to and within the built up area of the town, particularly adjacent to Rock Channel. These require a more imaginative and innovative form of development than is envisaged in the current policy. A wider range of more deliverable opportunities is required to address the significant pockets of social and economic deprivation within the town.