Focused Amendments to the Proposed Submission Core Strategy

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Focused Amendments to the Proposed Submission Core Strategy

FA23

Representation ID: 21258

Received: 31/07/2012

Respondent: Marchfield Strategic Land Ltd

Agent: JB Planning Associates Ltd.

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Substantial new information and commentary is provided by the focused amendments regarding 'identification and description of the strategic options considered and how they were identified', which goes some way to addressing the points in our previous representations at Proposed Submission Stage.

Regarding our more detailed representations on the assessment of the different options, the focused amendments do not, in the main, address the points set out in our previous representations at Proposed Submission Stage (particularly points at paras 11-30 of our representations). We therefore reiterate and will rely on earlier representations at Examination.

More detail in full text.

Full text:

1. With regard to the identification and description of the strategic options considered and how they were identified, substantial new information and commentary is provided by the focused amendments, which goes some way to addressing the points set out in our representations made previously at Proposed Submission Stage. However, where necessary, we will reiterate and will rely on our earlier representations at the Examination.
2. With regard to our more detailed representations on the assessment of the different options, the focused amendments do not, in the main, address the points set out in our representations made previously at Proposed Submission Stage (particularly those points set out at paras 11-30 of our representations). We therefore reiterate and will rely on those earlier representations at the Examination.
3. With regard to the additional commentary added in the focused amendments to the assessment of Option C2:
i. Item 11: The detailed additional commentary now provided highlights many potential positives of locating development at West Bexhill, however it then suggests that there would be local opposition to large renewable energy installations that, quite simply, are not relevant to the scale of development envisaged. It further suggests that there would be limited options available to achieve Code for Sustainable Homes Level 6, however this is a level that is far beyond what the Core Strategy requires.
ii. Item 13: The detailed additional commentary now provided appears even more skewed than the previous text. Despite the "Pevensey Levels Appropriate Assessment ... [concluding that] ... if its recommendations for mitigation are followed the ... Core Strategies will not have an adverse effect on the Pevensey Levels Ramsar Site", the additional commentary then disingenuously states that "the possibility of minor adverse impacts has to be acknowledged". (Our emphasis.) This contradiction is clearly unhelpful and misleading.
4. The above refers to the following elements of the Core Strategy:
Spatial Vision (Chapter 5, page 23)
Overall Spatial Strategy - Policy OSS1 (Chapter 7, page 34)
Bexhill to Hastings Link Road - Policy OSS2 (Chapter 7, page 38)
Bexhill Development Strategy - Policy BX3 and Paragraph 8.54 (Chapter 8, pages 52 and 53)
Recreation Facilities - Policy CO3 and Paragraph 14.28 (Chapter 14, page 105)
Affordable Housing - Policy LHN2 and Paragraph 15.24 (Chapter 15, pages 118-119)
Implementation and Infrastructure - Policy IM2 and Appendix 4 (Chapter 19, page 165)
5. For the sake of clarification and confirmation, the focused amendments to the Proposed Submission Core Strategy do not address the points set out in our representations made previously at Proposed Submission Stage. We therefore reiterate and will rely on those earlier representations at the Examination.

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