Proposed Submission Core Strategy

It is considered that the Core Strategy should contain a contingency plan to take account of circumstances that may arise if funding for the Bexhill/Hastings link road is not secured.

Given that the 2010 SHMA Up-Date Report projects (Figure 2.7) that 3,918 additional households are expected to form between 2011 and 2026 there is a clear need for the locally based housing target of 3,700- 4,100 dwellings to be met in full, with or without the link road.

The draft Core Strategy should indicate how this would be achieved in the circumstances of there being no link road during the plan period.

Without such a clear contingency the draft Core Strategy is overly reliant on the funding of a major new infrastructure element when there remains uncertainty as to whether such funding will materialise.

Without such certainty and without a contingency plan it is unlikley that the Core Strategy could be found to be sound.

Figure 8 is objected to as it does not indicate how, in circumstances where funding for the Bexhill/Hastings link road is not secured and the Council then seeks to reduce the overall housing target, (notwithstanding the projected need to accommodate some 3,918 additional households during the plan period - Figure 8 2010 SHMA Up-date report), how the Council would manage this situation.

Figure 8 should have 2 versions - a) and b). Version b) would indicate how the Bexhill/Hastings link road related housing (that could not be released without the link road) would be re-distributed across the District, including in the Rural Service Centres (such as Robertsbridge the full potential of which is not being utilised in the draft Core Strategy).

In addition, and in any event, it is considered that the total housing number allocated to the villages is too low and should be increased to 1,250 dwellings to more fully reflect the potential of the Rural Service Centres to accommodate additional development in sustainable locations, serving the rural hinterlands.

In the absence of a contingency approach the Core Strategy could fail as it would be incapable of delivering its poicies are proposals in PPS 12 terms if funding for the road was not secured.

If the housing target of 3,700 to 4,100 dwellings for the period 2011 to 2028 was to be reduced as a consequence of the Bexhill/Hastings link road not receiving funding the result would be that the Core Strategy would fail to make provsion to accommodate the 3,918 additional housholds projected in figure 2.7 of the 2010 SHMA Up-date Report which will form during the plan period. This would be a fundamental failure of the plan.

The Council should include a contingency plan in its Core Strategy indicating how it would address such circumstances and re-distribute the link road dependent housing to other parts of the District, including the Rural Service Centres such as Robertsbridge.

Whilst it is accepted that Battle and Rye have limited capacity to accommodate additional development this is not the case in respect of the Rural Service Centres.

For example, Robertsbridge has greater potential than is currently being utilised in the draft Core Strategy (i.e. 109-119 dwellings - Figure 12).

The village is capable of accommodating at least double this quantum without having any material adverse imapct on the ANOB.

An example would be the land available at Grove Farm which although allocated for only 30 dwellings in Local Plan Policy VL7 and 35 dwellings in the SHLAA has a capacity of about 90 dwellings.

In circumstances where the Bexhill/Hastings link road does not receive funding the Council should re-allocate the link road dependent housing to other parts of the District in order to ensure that the District's housing need is met.

Robertsbridge is rightly identified as a local service centre in terms of the advice in Policy EC6.2 of PPS4 and can make a bigger contribution than is currently attributed to it in the draft Core Strategy.

Further, the village serves a large hinterland in the northern part of the District. Modest additional development in the village would strengthen its sustainability and the services and facilities it provides to the surroundubg rural area.

Whilst the early construction of the Bexhill/Hastings link road is supported, the proposition that should the road not be built that the development targets for Bexhill would be reduced is objected to.

The housing target of 3,700 to 4,100 dwellings is a District-wide target and is needed to provide for the 3,918 new households projected in the 2010 SHMA Up-date Report to form between 2006 and 2026.

The link road dependent housing should be re-allocated to other parts of the District - i.e. to the north and west of Bexhill and by increasing the allocations to the Rural Service Centres.

It is not acceptable to simply abandon the 1,300 dwellings and 50,000 sq m of business floorspace, both of which are key to the future development of the District, if the funding for the link road fails to materialise.

Such an approach is not a sound spatial strategy.

The Core Strategy should contain a contingency plan to demonstrate how such circumstances would be addressed.

There is a grammatical error/typo in the first sentence ... 'around settlements will to between areas'... The wording does not make sense.

The policy should contain a clear indication of how the Council would address circumstances where the funding for the Bexhill/Hastings link road failed to materialise and how, in particular, it would seek to re-allocate the link road dependent development to other parts of the District, including increasing the allocations in the Rural Service Centres.

Whilst the Rural Areas Objectives are generally supported it is considered that the Objectives should be revised to include a reference to meeting the housing needs of the villages, and to strengthening the pivotal role of the Rural Service Centres in serving the wider rural areas.

The identification of Robertsbridge as a Rural Service Centre is supported, having regard to its strategic location, its good connectivitiy by both road and rail and the good range of shops services and faciltiies it provides.

It has been explained in our Representations in respect of Figure 8: Approximate Development Levels, that it is considered that the overall housing allocation for the villages is too low and should be increased to more properly reflect the potential of the Rural Service Centres (in particular Robertsbridge) to accommodate additional housing development. This would strengthen the internal sustainability of the village and help to ensure that its local services and facilities remain viable.

It is proposed that 1,250 dwellings should be allocated to the villages for the period 2011 to 2028.