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

Policy BEX15: Land south-east of Beeching Road

Sainsbury's Supermarkets Ltd supports identification of new sites to meet identified retail need. However, the preferred site option (site BX122) is located outside of the town centre boundary and has poor connectivity to the town centre. As such, the site does not comply with national policy requirements identified within the National Planning Policy Framework (NPPF).

The Council should, in line with the NPPF be promoting and allocating, either new or enhanced sites within the town centre. Paragraph 23 identifies Local Plans should "allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre where suitable and viable town centre sites are not available." Whilst it is identified in the draft plan that the proposed site is considered to be edge of centre as it is within 300m walking distance of the town centre, it has poor connectivity and there is no visibility between the site and the town centre itself. Furthermore, paragraph 24 of the NPPF states "preference should be given to accessible sites that are well connected to the town centre." The preferred site is located to the west of the town centre, north of the railway line and there are no existing unimpeded pedestrian routes between the town centre and the site at present. Also, as acknowledged within the Plan, there is no existing pedestrian crossing of Terminus Road between Beeching Road and Sackville Road/ Buckhurst Place. As such, the site cannot be considered to be well connected to the town centre and therefore does not comply with paragraph 24 of the NPPF.

Furthermore, the site is situated primarily within a residential area and development of a foodstore in this location will not enhance the town centre and provide the opportunity for linked trips. Instead it will draw trade away from the town centre by creating a new retail destination with poor accessibility that deters combined trips to the town centre.

We note that the supporting text within the Options and Preferred Options document states that "it is highly unlikely" that there is a large scale redevelopment opportunity in the town centre to accommodate the level of convenience floorspace required. The two other sites considered as options for development have been discounted on the basis that they are in mixed ownership, however we would suggest that this in itself is not reason enough to dismiss the sites. Indeed, National Planning Practice Guidance states (in reference to the use of the sequential test in decision taking):

Use of the sequential test should recognise that certain main town centre uses have particular market and locational requirements which mean that they may only be accommodated in specific locations. Robust justification must be provided where this is the case, and land ownership does not provide such a justification.

It would be somewhat illogical if the same did not apply to plan making, particularly given that there are measures open to Local Authorities to encourage cooperation or indeed compulsorily purchase land if required. As such, it is not considered that the preferred site complies with the sequential approach to identification of suitable retail development sites.

In response to question 42, we do not agree with the preferred site for retail development at Bexhill on the basis that it does not comply with the sequential assessment as established above. The Council risks the decline of Bexhill Town Centre, if site BX122 were allocated as it would result in a trade draw to the detriment of the existing shopping and other services located within the town centre.

We trust these representations are of assistance and look forward to receiving confirmation of receipt in due course.