Proposed Submission Core Strategy

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Object

Proposed Submission Core Strategy

Policy RA2: General Strategy for the Countryside

Representation ID: 21063

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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. Further consideration in RA2 (viii) should be given to improving tourism accommodation in rural locations. 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 and acknowledges the importance of tourism to the national and local economy reflected in PPS21 and the draft NPPF. Further consideration should be given to textual changes to para 16.32

Full text:

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"

Object

Proposed Submission Core Strategy

Policy EC6: Tourism Activities and Facilities

Representation ID: 21064

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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. Further consideration in RA2 (viii) should be given to improving tourism accommodation in rural locations. 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 and acknowledges the importance of tourism to the national and local economy reflected in PPS21 and the draft NPPF. Further consideration should be given to textual changes to para 16.32

Full text:

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"

Object

Proposed Submission Core Strategy

Policy OSS1 - Overall Spatial Development Strategy

Representation ID: 21066

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

OSS1 is considered to be unsound because of the following:

OSS1 will deliver an under-supply of housing in the district,

The strategy is too dependent on the delivery of the Link Road,

The spatial distribution impacts on the 5 year housing supply and is not considered to be compliant with +20% advocated in the draft NPPF

Further consideration should be given to support a strategic allocation on NW Hastings at Breadsell Lane. Constraints on this location can be mitigated and it is considered this approach should be taken in conjunction with HBC.

Full text:

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.

Object

Proposed Submission Core Strategy

Policy OSS2: Bexhill to Hastings Link Road and development

Representation ID: 21067

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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.

Full text:

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.

Object

Proposed Submission Core Strategy

Policy BX3: Development Strategy

Representation ID: 21069

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The spatial strategy focuses the majority of development on Bexhill but further consideration should be given to a second strategic growth point at NW Hastings fringes (Breadsell Lane). It is considered that this approach would meet the objectives stated in Policy OSS4 and co-ordinate growth between Bexhill and Hastings.

Full text:

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.

Object

Proposed Submission Core Strategy

Policy HF1: The Hastings Fringes

Representation ID: 21070

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Policy misses an opportunity to provide a new mixed-use allocation at the NW Hastings fringe (Breadsell Lane) as a joint strategic allocation with Hastings.

HF1(vi) is not location specific.

The Policy (in the context of OSS1) will result in an under-supply of allocated housing land and has too much reliance on the Bexhill-Hastings bypass.

The spatial distribution policy does not meet the need for providing a 5 year land supply+20% as defined in the emerging NPPF and doesn't meet regional guidance.

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

Full text:

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.

Object

Proposed Submission Core Strategy

Policy IM3: Phasing of Development

Representation ID: 21071

Received: 09/11/2011

Respondent: Crowhurst Park

Agent: Kember Loudon Williams Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

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.

Full text:

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.

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