Main Modifications to the Proposed Submission Core Strategy

On behalf of the landowner, Mr Colin Simmons, we welcome the additional text inserted in respect of land at Breadsell Lane, in particular that residential development should not be ruled out.

We acknowledge that the largest portion of the site falls within Hastings Borough and that therefore that it is for Hastings Borough Council to lead on any future allocation for the site. However, it is important that the background context is clear for the purpose of considering the implications for the Rother Strategy.

The Hastings Core Strategy 'Preferred Approaches' Document (2008) identified Mr Simmons' land at Breadsell Lane as part of a major Greenfield site that had genuine prospects to provide new homes during the Local Plan period (approx. 450 units in Hastings and 150 units in Rother). Within this Preferred Approaches Consultation there was an unambiguous acknowledgement by the Council that a development of this land would provide the very best opportunities for providing essential infrastructure, such as improved transport, community and recreational facilities. It was also acknowledged that a large site would provide opportunities for higher standards of sustainable design and construction, which would assist in combating climate change during the plan period. Essentially, it was stated that Breadsell Lane was the most sustainable option available for providing large-scale new housing.

However, as a result of a Natural England 'holding objection' in respect of the hydrology of the site (highlighting the need for further baseline monitoring of the existing baseline conditions), HBC abandoned its stance and deleted Breadsell Lane as a potential allocation.

We maintain our view that the removal of the site due to Natural England's objection has not been justified in evidence and that the Hastings Strategy is unsound - which we continue to argue is the case through the Hastings Strategy Examination.

Notwithstanding the disparity with HBC on hydrology, we do consider sufficient previous assessment has been undertaken, particularly through the SA process, to demonstrate to the sustainability credentials of developing Breadsell Lane. We therefore consider that Main Modification 7.10 of the Rother Strategy should be restricted to the sole area of outstanding dispute, and be amended to read:

'While current evidence does not support the identification of development at Breadsell Farm, given the housing land supply position, relevant policies are framed in such a way as to not rule out the longer-term prospect of a sustainable scheme if the hydrology impacts are satisfactorily addressed'.

Finally, unlike the Hastings Strategy, we do not consider this a matter that goes to the heart of whether the Rother Strategy is 'sound'. However, we would reiterate that land at Breadsell Lane is the only large greenfield opportunity, not located within a protected Area of Outstanding Natural Beauty, that could provide a valuable strategic housing contribution for both the Rother DC and HBC market area.

Whilst the decision to exclude it only because of a 'holding objection' certainly renders the Hastings Strategy unsound, a negative approach to the site would continue to have an adverse impact for Rother DC by restricting a valuable 150 new homes.