Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Transport Strategy & Economic Development
VILLAGES WITH SITE ALLOCATIONS page 219

Overall comment for all villages with site allocations:

The site allocations should maximise accessibility to local services, including schools, shops, public transport provision, through improved or the provision for new walking/cycling infrastructure, to support sustainable development.

Transport DC

The County Council's Transport Development Control team has previously provided comments on the assessed sites and preferred sites that appear in the DaSA. This has been primarily through the site assessment process (generally the SHLAA). We are aware that the planned levels of development and the broad distribution has already been set out in the Rother Core Strategy.

Aside from the site subject to Policy BEX4 (see below), we are content that our previous comments and concerns have been suitably addressed both in terms of the sites identified as preferred sites, and the relevant policy criteria that would apply.

We are aware that concerns have been raised by local residents, in terms of the potential impact upon the local highway network as a result of the proposed housing allocation at Spindlewood Drive (subject to Policy BEX9). However, based on the supporting transport evidence we are content that the proposed allocation can be considered acceptable in terms of its impact upon the local highway network that falls within the jurisdiction of East Sussex County Council. The traffic impact upon the strategic network (A259) will also need to be considered, but this will be for Highways England to do. We do recognise that certain mitigation measures are likely to be required, such as potentially restricting parking along certain parts of Meads Road, but we would expect these to be identified, agreed and implemented at the formal planning application stage.

Transport DC

Policy BEX4: Land at Former High School Site and Drill Hall, Down Road, Bexhill

Transport Development Control have previously raised concerns regarding the site access onto Down Road (due to the problems with the existing junction and filter lanes onto the A259) and have recommended that a transport assessment is carried out to consider the site access options. We consider that this assessment should be undertaken before the Pre-Submission version of the DaSA is published and accordingly inform the policy approach for this site.

Until this additional work is carried out we are unable to provide further comments or advice on the proposed policy approach for this site.

Minerals Planning

Safeguarding

The DaSA document correctly identifies at 2.15 that the East Sussex, South Downs and Brighton & Hove WMP and the WMSP (once adopted) are part of the development Plan for the area. However, apart from the new safeguarded area at Broomhill, it does not refer to the provisions of these Plans which apply to the Rother Local Plan area. These include a number of safeguarded wharves and railheads, facilities for concrete batching, coated materials manufacture and other concrete products, and land-won mineral resources. These are set out in SP 8, SP 9 and SP10 of the WMSP and should be identified in the DaSA.

In particular, the two areas of safeguarded wharves at Rye Port have not been specifically referenced in the DaSA. There is a reference in 15.101 to the use of Rye wharf for aggregate imports (sometimes known as Rastrum's wharf). However, there is a further safeguarded wharf in Rye Harbour Road, which is currently vacant and was previously known as the old "ARC" wharf.

The proposed policy (RHA2), which incorporates the two aforementioned wharves, would permit B1, B2 and B8 uses on this site where various criteria are met. Our policies WMP 15 and SP 9 state that in such areas "capacity for landing, processing and handling and associated storage of minerals at wharves will be safeguarded. Alternative use proposals would need to demonstrate that there is no net loss of capacity within a port. Proposals for non-minerals development on or near the site that would prejudice the use of the facility, or result in incompatible development, should not be permitted".

At this stage in the DaSA preparation it is not possible to determine the exact type of development which could result through Policy RHA2 and the impact it would have on wharf capacity. We would suggest that an additional criterion is added to policy RHA2 to reflect this. E.g. "(v) proposals should demonstrate that the capacity for landing, processing and handling and associated storage of minerals at wharves is safeguarded and that there is no net loss of capacity within Rye Port".

Minerals Planning

Light

At 10.97 the DaSA refers to common sources of light pollution and picks out quarries as one of the sources. This is probably cited from a national perspective but it could be implied to be a problem experienced locally. It would be best if this reference could be qualified or deleted.

Waste Planning

Section 2 Strategic Framework

In this section reference to the National Planning Policy for Waste (NPPW) appears to have been omitted. It is suggested that reference to the NPPW is added with particular reference to paragraph 8 of the NPPW. Likewise, while the acknowledgement of the Waste and Minerals Plan is appreciated, it is suggested that specific reference to Policies WMP21, WMP3a-e & WMP4 and an indication of the implications of these policies for the development proposed within the DaSA should be added.

Waste Planning

Policy DCO2: Equestrian Developments

Equestrian and other developments that involve large-scale landscaping sometimes involve the importation of large quantities of waste soils and other materials from other development sites. Prior to accepting any such application consideration should be given as to where the landscaping material is coming from and if the application is a County Matter. At this time, we are not suggesting that the text of the Plan be altered, but we would ask that your officers remain vigilant for such applications.

Waste Planning

Policy DEN3: Strategic Gaps & Policy HAS5: Combe Valley Countryside Park
It is noted that Pebsham Household Waste Recycling Centre and Waste Transfer Station, which is a safeguarded waste site, and the Pebsham Waste Water Treatment Works are within the Bexhill and Hastings/St Leonards Strategic Gap (DEN3) but excluded from the Countryside Park (HAS5). Additionally, the link between waste management and the Countryside Park as set out in the Pebsham Countryside Park Project Development Strategy (January 2007) appears to have not been pursued. It is suggested that for consistency between these two policies that either the above waste management facilities are excluded from Policy DEN3 or the link between waste management and the Countryside Park is reflected in policy HAS5.

Waste Planning

Policy DHG3: External Residential Areas item (iii) Waste and Recycling
Inclusion of the above policy is welcomed.

Waste Planning

Policy RHA2: Harbour Road Employment Area
Rye Oil and SRM Ltd are both waste management operations safeguarded under Policy WMP6 of the Waste and Minerals Plan (2013) and Policy SP6 of the Waste and Minerals Sites Plan (2017). The site is referenced as SP-WCA/H (Church Fields, Rye Harbour Road) in the Sites Plan. A small part of this safeguarded site is within the Harbour Road Employment Area (Policy RHA2). Future development should not prejudice operations at this site and it is suggested that reference to this is made in the policy.