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

Representations to the Public Consultation into the Rother Development and Site Allocations Local Plan Options and Preferred Options December 2016 on behalf of Beaulieu Homes (Southern) Limited in respect of Land at the Former Sidley Sports Ground, Bexhill-on-Sea.

Draft Development Plan Document (DPD) insofar as they affect land controlled by my client, Beaulieu Homes (Southern) Limited, at the Former Sidley Sports Ground, west of Buckholt Lane, Bexhill-on-Sea.

Specifically Beaulieu Homes (Southern) Limited wishes to object to the provisions of Proposed Policy BEX11 which proposes to allocate my client's land for playing pitches for formal sport. The draft policy is ill-founded, unsupported by any evidence and should be deleted. This land should be allocated for housing.
Beaulieu Homes (Southern) Limited purchased the site in 2013 following the site's previous owners, Sidley United F.C., going into administration. The Council also attempted to purchase the site at that time but was unsuccessful, and since that time has tired to use its other powers to achieve what it could not achieve at that time. The site was the subject of a planning application by my client (Ref: RR/2015/2304/P) which sought outline consent for up to 70 dwellings with fully developed proposals to provide a significant financial contribution for the mitigation of the loss of the sports ground on the application site. Three alternative mitigation
options were presented to the Council, each of which would have fully mitigated for the loss in line with Sport England requirements. Unfortunately the Council deliberately refused to engage with my client. The result was that's none of the mitigation packages offered were deliverable since the Council owned the facilities concerned, As a result that application was withdrawn.

Very recently a revised outline planning application on this site has been submitted by my client (Ref: RR/2016/3127/P). It seeks consent for up to 65 dwellings (based on a revised illustrative layout which seeks to address many of the issues raised by the then planning case officer) and also proposes a sports mitigation package which fully meets the Sport England requirements for the loss of the application site as a playing field, and on sites which are not owned by the Council. Specifically, the proposal is the funding of an Artificial Grass Playing Pitch at William Parker School in Hastings, The School itself is very keen to secure this funding and the proposal has the full backing of the Bexhill Rugby Club who use the School's facilities. This mitigation package rectifies a specific and identified deficiency in provision in the Council's own Playing Pitch Strategy and for a well established sports club with a recognised need. The mitigation package can be delivered and is not dependent on the Council fir its implementation, which the Council has made clear would not be forthcoming.

The proposed site is not an appropriate location for a playing pitch. It is surrounded by medium density housing on all sides. Within the site the majority of the land is given over to the former playing pitch. The southern two thirds or so of the site is relatively flat but the ground rises to the north up towards Festival Gardens, making the playing pitch less than perfect. Since its vacation by Sidley United Football Club in 2013 the site has been subject to recurring vandalism.

Proposals for development which result in the loss of a playing field are subject to consultation with Sport England which has clear tests that must be successfully met before such development is allowed. Sport England would oppose the granting of planning permission for any development which would prejudice the use of whole or part of a playing field, unless an assessment has been carried out which confirms that there is an excess in playing field provision in the catchment area and the site has no special significance in the interests of sport, or significant mitigation measures can be put in place. The Council's policies in this area are set out in its Playing Pitch Strategy (2012-2018) and the Open Space Strategy, both of which form part of the Adopted Core Strategy Evidence Base, and are therefore directly relevant to this emerging Development and Site Allocations Local Plan. No new updated studies have been published by the Local Authority in the intervening period.

Following the Council's refusal to even consider the mitigation packages put forward in late 2015, the new planning application puts forward options which seek to deliver specific sports development programmes for Hastings Football Club and Bexhill and Hastings Rugby Club. Both Clubs are prominent in the area and attract a player base form across Rother district. They each run multiple senior and junior teams for both men and women. They have identified specific projects which will increase participation and help accommodate their existing and future fixtures and training programmes. The preferred option relates to William Parker School and Hasting and Bexhill Rugby Club because it is fully deliverable as the School controls the mitigation site. The other option relates to Hastings Football Club and Coombe Valley Park. Because the Council controls Coombe Valley Park it is clear that the option is not deliverable, though it meets the Sport England mitigation test.
Both William Parker School and the Hastings and Bexhill Rugby Club have the shared aspirations to install a synthetic tirf pitch at the school. This aspiration is long established and the rugby club have been in dialogue with the Rugby Football Union for match funding. However, they are unable to deliver the scheme for lack of funds. The financial contribution proposed of £350,000 from the development of the former Sidley Sports Ground for housing will deliver this facility. The synthetic pitch will result in a significant increase in the ability to fulfil formal fixtures and training, alleviating pressure on existing grass provision and enable juniors to play on appropriate sized pitches. Local clubs, the school and the wider community will benefit from the proposal which has been identified as a clear need within the area. The investment in the facilities, in a location which will benefit the wider community and existing clubs that utilise the site, can not be delivered by the Local Authority due to lack of funding. The long term and cumulative benefits associated with this mitigation package materially outweigh any benefits of the former Sidley sports ground remaining in its current unused state.

On this basis alone the Sidley Sports Ground site should be allowed to be developed for a much more appropriate use. The site is in private ownership and it has already been demonstrated that the site is not capable of being viable as a playing pitch. Even if the site ownership was secured by the Council it is clear that it would have no funds to make any effective use of the site. In the light of the above issues my client puts forward the following recommendations for the Council to consider:
Beaulieu Homes (Southern) Limited, therefore, strongly disagrees with the provisions of Proposed Policy BEX11, for the following reasons:

1. There is no evidence adduced either by the Council or any other party that this site has any viable future remaining as a playing pitch for formal sport. On the contrary, all of the available evidence points to the contrary;

2. There is no prospect of any private or public funding available to secure the future of the site as a playing pitch for formal sports;

3. The site is subject to persistent vandalism which will continue to undermine any efforts to retain the site in use as a playing pitch for formal sports.

4. The mitigation proposal put forward in the current planning application RR/2016/3127/P effectively remedies an identified deficit in provision for a major Bexhill Sports Club but on land not controlled by the Council and on which my client can therefore deliver. It also provides a significant additional facility to a large comprehensive school, so that the benefit is further enhanced. The mitigation proposals are fully in line with Sport England requirements.

5 The Council is unable to demonstrate a five year supply of available and deliverable housing land, and this position is worsening rapidly. This site can be quickly developed for housing and make a significant and material contribution to this housing land shortfall. There is therefore a clear and present presumption in favour of this site being allocated for housing.

Proposed Policy BEX11 should therefore be deleted and replaced by a revised Policy BEX11 with the site allocated for housing for up to 65 dwellings.

I trust that the above representations are clear but if any matter requires further clarification please do not hesitate to contact me further.