Proposed Submission Core Strategy

Greater linkage should be made between the two policies to ensure that the promotion of tourism in EC6 is equally reflected in RA2 for the rural areas. Improved economic activity in the District based on tourism should not be limited to the towns and villages. Whilst Policy RA2 (vii) provides a broad policy direction, it needs to be more positive in seeking to attract better levels and quality of tourism including accommodation and self-catering facilities in rural locations. In addition it should promote the improvement of facilities related to existing tourism facilities or the Core Strategy should include a specific tourism policy reflecting and reinforcing paragraphs 12.28 - 12.30. The policy would be more effective in terms of supporting rural-based tourism and would better reflect the importance that tourism plays in the national, regional and local economies, as reflected in current PPS21 and emerging NPPF policy.

In addition, it is felt that Policy EC6 would be more effective in promoting tourism development if the following was added to the list of opportunities under paragraph 16.32:

" for holiday parks to become hotels in towns, villages and in rural locations"

Greater linkage should be made between the two policies to ensure that the promotion of tourism in EC6 is equally reflected in RA2 for the rural areas. Improved economic activity in the District based on tourism should not be limited to the towns and villages. Whilst Policy RA2 (vii) provides a broad policy direction, it needs to be more positive in seeking to attract better levels and quality of tourism including accommodation and self-catering facilities in rural locations. In addition it should promote the improvement of facilities related to existing tourism facilities or the Core Strategy should include a specific tourism policy reflecting and reinforcing paragraphs 12.28 - 12.30. The policy would be more effective in terms of supporting rural-based tourism and would better reflect the importance that tourism plays in the national, regional and local economies, as reflected in current PPS21 and emerging NPPF policy.

In addition, it is felt that Policy EC6 would be more effective in promoting tourism development if the following was added to the list of opportunities under paragraph 16.32:

" for holiday parks to become hotels in towns, villages and in rural locations"

The Policy will result in an under-supply of allocated housing land in the District over the Core Strategy period and has too much reliance on the delivery of the Bexhill-Hastings bypass which was exactly the same position facing the District Council during their Local Plan process. The policy does not meet regional guidance and is unsound on that basis.

The spatial distribution policy does not appear to meet the need for providing a 5 year land supply + 20% as defined in the emerging NPPF.

The spatial policy places too much emphasis on the 'traditional' centres for development where there are long-standing development constraints.

Whilst not entirely ruled out, the Core Strategy has not taken the clear opportunity to support a strategic allocation on the north-western side of Hastings. Although Hastings Borough Council favoured this strategic approach in its earlier Core Strategy, they have not pursued this in their submission CS. The constraints raised against this can be mitigated and therefore it is considered that the District Council have been too readily dismissive of this clear opportunity.

The spatial strategy policy should include a strategic housing allocation on land at Breadsell Lane certainly encompassing the northern part of that area of land. The approach should be carried out in conjunction with Hastings Borough Council because of the mutual authority interests by way of an area action plan. Such an approach would be likely to ensure the provision of sustainable and properly planned short, medium and long development including homes, jobs, community provision and infrastructure in a location that has a strong need for improvement in these areas. A positive allocation on this basis will add further weight to support the need for the Bexhill-Hastings bypass to be delivered.

The effectiveness of the policy would be increased if supported by the added weight of a strategic land allocation for housing, employment and community facilities on land south of Battle Road (Breadsell Lane) at the NW Hastings fringe in association with Hastings Borough Council allowing greater certainty for the early provision of the bypass project and a potentially important source of funding for that project.

Historically through its Local Plan process, the District Council has relied on the Bexhill location to deliver the core part of its housing and employment land. The policy has not delivered in this area and yet remains a cornerstone of the Core Strategy.

Because of the historic weakness of this strategic approach, it is considered that strength can be added to the Core Strategy by introducing a second strategic growth location at the NW Hastings fringe ie land south of Battle Road (Breadsell Lane). This approach will meet the Council's objectives on Policy OSS4 and will provide development in a location where new initiatives are particularly needed between the District Council and Hastings Borough Council.

The Policy as drafted misses a key planning opportunity to provide for an integrated new allocation for housing, employment, community facilities and infrastructure at the NW Hastings fringe on land south of Battle Road (Breadsell Lane) as part of a joint strategic allocation with Hastings Borough Council. The proposed provision in HF1 (vi) is not location specific.

The Policy when considered in the context of OSS1 will result in an under-supply of allocated housing land in the District over the Core Strategy period and has too much reliance on the delivery of the Bexhill-Hastings bypass which was exactly the same position facing the District Council during their Local Plan process. Historically through its Local Plan process, the District Council has relied on the Bexhill location to deliver the core part of its housing and employment land. The policy has not delivered in this area and yet remains a cornerstone of the Core Strategy.

Because of the historic weakness of this strategic approach, it is considered that strength can be added to the Core Strategy by introducing a second strategic growth location at the NW Hastings fringe ie land south of Battle Road (Breadsell Lane). This approach will meet the Council's objectives on Policy OSS4 and will provide development in a location where new initiatives are particularly needed between the District Council and Hastings Borough Council.

The spatial distribution policy does not appear to meet the need for providing a 5 year land supply + 20% as defined in the emerging NPPF and as it stands, the policy does not meet regional guidance and is unsound on that basis.

The spatial policy places too much emphasis on the 'traditional' centres for development where there are long-standing development constraints.

Whilst not entirely ruled out, the Core Strategy has not taken the clear opportunity to support a strategic allocation on the north-western side of Hastings. Although Hastings Borough Council favoured this strategic approach in its earlier Core Strategy, they have not pursued this in their submission CS. The constraints raised against this can be mitigated and therefore it is considered that the District Council have been too readily dismissive of this clear opportunity.

The Core Strategy spatial strategy policy should include a strategic housing allocation on land at Breadsell Lane certainly encompassing the northern part of that area of land. The approach should be carried out in conjunction with Hastings Borough Council because of the mutual authority interests by way of an area action plan. Such an approach would be likely to ensure the provision of sustainable and properly planned short, medium and long development including homes, jobs, community provision and infrastructure in a location that has a strong need for improvement in these areas. A positive allocation on this basis will add further weight to support the need for the Bexhill-Hastings bypass to be delivered.

The effectiveness of the Core Strategy's strategic allocations policies would be increased if supported by the added weight of a strategic land allocation for housing, employment and community facilities on land south of Battle Road (Breadsell Lane) at the NW Hastings fringe in association with Hastings Borough Council allowing greater certainty for the early provision of the bypass project and a potentially important source of funding for that project.

NPPF requires a minimum 5 years land supply to be provided on top of which is a requirement for a further 20% land supply. On the basis that this Government objective is carried through to the final version of this guidance, the Core Strategy would be out of step with national planning policy guidance as it envisages only a 5 year land supply and no more.