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

The comments below are in relation specifically to policy BEX5 - Land at Gullivers
Bowls Club, Knole Road, Bexhill.

In terms of context it is noted that within the current adopted plan period that
within the District Bexhill will need to deliver 3,100 dwellings. Moreover there is no
reference within the latest Annual Monitoring Report, Housing Land Supply, and the
Strategic Housing Land Availability Assessment, to the specific amount of need.
However the Core Strategy Policy CO5 - Supporting Older People would be of
relevance to the site. Further the preamble to the policy sets out that the District
has the highest level of older people within the County and Bexhill specifically is
stated as having a population where 34.3% of people of over 65.

There is a clear need in the Borough for specialist accommodation for the elderly,
and the delivery of specialist accommodation within the Borough should be seen as
critical given the Council's demographic information that has been collected. To this
end the Council must also consider this in the light of the nature and issues
incumbent in with the delivery of such accommodation, such as reduced car
ownership, communal facilities etc.

Policy BEX5 is welcomed as sensible use of the site, to provide much needed
Sheltered Housing within the District, where there is a clear need. In respect of the
wording of the Policy there appears to be some level of conflict. Firstly the policy
states that the site should deliver housing and the first point then states sheltered
housing, this should be made explicit.

Taking the elements of the policy in order;
i) Some 39 sheltered dwellings are provided, of which 30% are affordable;
It is clear that the Council will need to have some degree of assessing the site in terms of providing a view of capacity. However, specifying the number of units on site to "some 39" could restrict the sites potential to accommodate a higher number of dwellings. Moreover this would give no consideration to the mix of units on site, clearly 39 x 1 bed units would be considerably less mass than 39 x 2 bed units. The assessment given the sensitivity on the site should be more focused towards scale than containing the development with an arbitrary number. Whilst the proposed number of sheltered dwellings on site would appear from a historical standpoint to generally be acceptable, this cannot guarantee that the same number is viable.
Any sheltered housing development would facilitate an improved bowls facility along with contributing to the overall housing need of the District. Supporting paragraph 47 of the NPPF seeks to boost significantly the supply of housing in the Country. As such the second part of point i) of the policy and the issue of 30% to be provided on site are not considered appropriate given the nature of a sheltered housing development.

Sheltered housing gives residents are provided with a variety of elements that open marking housing does not cater for these including owners lounge, communal landscaped amenity area, a lodge manager, etc. The buildings are also maintained by management companies. In addition to this a lodge manager is usually employed by the management company to provide assistance and security for the owners of the apartments given their age and often increasing frailty.

Given the nature and management of sheltered accommodation it would not be possible to provide onsite affordable housing, primarily for management reasons. However, a financial contribution towards offsite affordable housing following the submission of a viability assessment in accordance with policy LHN2 would be appropriate. This is set out within the NPPF and also the previous determinations by the Council. As such the reference to a specific deliverable amount on site would make the delivery of the site unviable. Furthermore the Council also has specific policies in place to deal with affordable housing that should be sufficient without repetition on a site by site basis.

ii) An improved bowls facility comprising of an outdoor bowls green, an indoor rink and associated clubhouse and maintenance facilities is provided;
This element would help achieve the policies goal of a mixed use development on the site, and we agree that this should be achieved in line with adopted policy.

iii) Development at the rear of the site is single storey only;
Given the sites location, levels and significant separation distances to adjoining properties to the rear of the site development should not be limited to single storey in this location. A well designed and articulated proposal of over one storey could be achieved as part of the overall redevelopment of the site and would be in accordance with paragraph 58 of the NPPF which seeks to optimise the potential of sites to accommodate development and create and sustain an appropriate mix of uses whilst responding to the local character and surroundings. Moreover this would restrict any ability to expand. This should be related to the review of the submission against the relevant policies in relation to design and setting, rather than be so specific.

iv) Separate access points are provided for the residential and bowls facility part of the scheme;

Whilst it is accepted that separate access points for both the bowls club and sheltered housing may be a preference it should not be discounted that a shared access may be feasible and indeed desirable.

If the shared access meets the required highways standards and is acceptable in terms of an overall layout then a shared access should be allowed. There seems little to no justification for this requirement

v) The design of the scheme does not adversely affect the character of the area or the setting of the listed terrace to the south; and

Given the sites location which is directly adjacent to grade 2 listed buildings it is essential that any proposal preserves the setting of the Grade II Listed terrace and does not have a detrimental impact on the character of the area in line with paragraph 131 of the NPPF and policy EN2 of the Core Strategy.

vi) Provision is made for the retention and enhancement of boundary planting, particularly on the western, northern and eastern boundaries.

It is not clear from the policy what this requirement is trying to achieve. Any proposed development should be accompanied by a robust landscaping strategy that should include treatment of all boundaries including the south which is the most visually prominent and directly adjacent to the listed terrace.

Overall while the policy is broadly welcomed the requirements begin so specific in terms of what form of development happens on the site could easily create future problems. For example with an offsite or commuted sum delivered for affordable housing, or if less units are delivered. The Council are advised to very carefully consider the ramifications of the policy wording of the allocation of the site given its very complex history.

I trust that the above is clear but if any further clarification is sought please contact me and we will be happy to assist.