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

The Background Paper to the DaSA entitled Employment Sites Review (November 2016) identifies Beech Farm in the rural area of Battle as an established employment site measuring 2.2 hectares and containing approximately 12 business units (page 59). The site is identified as being substantially occupied and we can confirm that occupancy rates have been consistently high for a number of years. The site is currently at full capacity with 25 businesses within 19 units.

The site comprises a number of relatively attractive former agricultural barns and stables that have been converted into business units. Three larger, more modern agricultural buildings provide larger units that are predominantly being used for storage and distribution purposes. The smaller units are being used by a variety of businesses, including a beautician's, photography studio, stained glass manufacturer, archery shop, and two mechanics' workshops.

The buildings are grouped together in an old farmstead, which reflects their original intended uses; however an area of undeveloped land lies immediately to the north of the larger, modern buildings which would provide a suitable location for additional buildings at this important rural business site. The Estate has already been approached by one of the current tenants at Beech Farm for a new, larger building (approximately 900sqm) that would accommodate its growing needs, and the area of land to the north would be an ideal location for this. This area has been included within the boundary of the employment site in the Employment Sites Review Background Paper, which suggests that the Council already consider it to form part of the site (rather than as part of the surrounding countryside).
The proposed site is well-screened by existing vegetation along all its boundaries and is not in agricultural use. In fact, it would not be suitable for agricultural use given its proximity to the employment site and separation from the adjacent fields by substantially vegetated boundaries. The land is redundant for this reason and the Estate have therefore put it into temporary use as an archery range. The preferred use of the land would be for an extension to the existing employment site so that the Estate may continue to provide units of various sizes and design to suit the evolving needs of rural businesses.

The Employment Sites Review Background Paper (despite it including proposed aforementioned area within the site boundary), states that there are no expansion opportunities at the site. We do not agree with this, and consider there to be a significant opportunity for additional buildings that meet the growing needs of local rural businesses. The site has proven to be successful to date, and makes an important contribution to the rural economy. Its location in a relatively remote area is inconsequential as there is a specific demand for sites like this in rural areas, as acknowledged in the adopted Core Strategy 2014 and draft DaSA. The success of the site to date, as well as the commitment by the Estate to investing in site improvements (including additional buildings), is a testament to this.

Page 76 of the DaSA confirms the importance of rural business sites:

"(15) the Rural Areas have seen most business development in recent years, as well as accounting for the greatest amount of floorspace with full planning permission, which together approximate to the minimum floorspace target; (16) these findings point to the role that rural areas are playing in meeting the accommodation requirements of businesses and, hence, to the economic growth of the District, and it is recommended this trend should not be frustrated".

We are aware that a Neighbourhood Plan Area has been designated for Battle and the surrounding area, which would include the Beech Farm employment site; however this plan does not appear to have made any progress since the Neighbourhood Plan Area was designated in April 2015. It is therefore crucial that the DaSA provides the necessary policies to support employment development in the Battle area, and allocates sites where appropriate. Policy EC3 (Existing Employment Sites) of the Core Strategy supports a full review of existing employment premises and the allocation of new sites in the DaSA and/or Neighbourhood Plans. The DaSA is now in preparation and, given the lack of progress with the Battle Neighbourhood Plan, the DaSA must provide the necessary supporting policies for additional buildings at the Beech Farm employment site.

Until the DaSA is adopted, Policy EC3 will apply to any proposal for new buildings at Beech Farm and part (ii) of the policy currently supports the "intensification, conversion, redevelopment and/or extension [of sites] having regard to other policies of the Plan". Our concern with relying on part (ii) of Policy EC3 (or Policy DEC3 of the DaSA, if it is adopted) in the submission of a planning application for new buildings at Beech Farm, is that there would be the potential for other policies in the plan (such as restrictive countryside policies or AONB policies) that could prevent the application from being approved. This uncertainty would create risk to any application that is submitted and, as such, the Estate would hesitate to release the funds required for making such a speculative application. Greater certainty would be needed regarding the principle of the development if the Estate is to submit an application for new buildings at Beech Farm, and this could be achieved if the site is allocated.
We therefore request that the area of land immediately north of Beech Farm is allocated for additional business development that would complement the existing, successful, rural business site. The extent of the existing site and extension area would follow the exact same boundary drawn around the site in the Employment Sites Review Background Paper (page 60). We reiterate that the Battle Neighbourhood Plan cannot be relied upon to allocate the site, given the lack of progress demonstrated to date.

2. Question 17: Do you agree with the policy approach to existing employment sites and the proposed policy wording?

The current consultation on the DaSA proposes to replace Policy EC3 of the Core Strategy with policy DEC3. The wording of the new policy appears to be identical, apart from a slight discrepancy in part (iv) in the use of the word 'prioritising' instead of 'prioritise'. Whilst perhaps more grammatically correct, we do not consider there to be a need to amend Core Strategy Policy EC3 for this reason alone.

The original intention of the policy amendment appears to include a need for greater flexibility to include 'lack of need' and 'incompatible land uses' as alternative reasons for why a change of use at an existing employment site might be acceptable (along with viability, which is already mentioned), and this is something that we would support in the policy wording. We also support the retention of part (ii) of the policy, which remains as per Policy EC3 (quoted earlier in this letter).

3. Housing Allocations in Battle

Following our comments in relation to the need to include employment site allocations for the Battle area within the DaSA to mitigate a Neighbourhood Plan not coming forward at all, or within a reasonable timeframe, we consider it important to comment on housing sites in this respect as well. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

The adopted Core Strategy sets a requirement of 475-500 dwellings to be brought forward in Battle during the plan period. Paragraph 11.10 states that sites are to be brought forward in the DaSA, although paragraph 7.52 includes the possibility of sites coming forward in Neighbourhood Plan.

The same housing requirements are carried over to the draft DaSA, with an identified residual requirement of 425 dwellings to be allocated on new sites in Battle. This is not an insignificant amount and it makes a valuable contribution to the District's housing supply. Given the lack of progress being made with the Neighbourhood Plan, to rely entirely on it to deliver the required number of new homes would put a question mark over the ability of the plan to deliver the requisite number of dwellings during the plan period (particularly the early part of it). Eight other Neighborhood Pplans are being relied upon in this way - albeit two have made sufficient progress that their delivery can more reasonably be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). However, it is impossible to control this process, and the Council are placing an unreasonable amount of pressure on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale.

The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control. It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA for the Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is currently being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of employment and housing site allocations in the DaSA for Battle would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area could result in little economic or residential development taking place for the early part of the plan period, leaving the Council with an employment and housing land supply shortage when assessed against objective needs.

As such, we submit the following three sites for allocation for residential development on the western edge of Battle, within the Beech Estate:

* Land West of Vale Road
* Land West of Battle Hospital A
* Land West of Battle Hospital B

Plans and forms containing information for each of these sites are enclosed.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

Beech Farm Employment Site:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28093

Land west of Battle Hospital A - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28094

Land west of Battle Hospital B - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28095

Land west of Vale Road - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28096

The Background Paper to the DaSA entitled Employment Sites Review (November 2016) identifies Beech Farm in the rural area of Battle as an established employment site measuring 2.2 hectares and containing approximately 12 business units (page 59). The site is identified as being substantially occupied and we can confirm that occupancy rates have been consistently high for a number of years. The site is currently at full capacity with 25 businesses within 19 units.

The site comprises a number of relatively attractive former agricultural barns and stables that have been converted into business units. Three larger, more modern agricultural buildings provide larger units that are predominantly being used for storage and distribution purposes. The smaller units are being used by a variety of businesses, including a beautician's, photography studio, stained glass manufacturer, archery shop, and two mechanics' workshops.

The buildings are grouped together in an old farmstead, which reflects their original intended uses; however an area of undeveloped land lies immediately to the north of the larger, modern buildings which would provide a suitable location for additional buildings at this important rural business site. The Estate has already been approached by one of the current tenants at Beech Farm for a new, larger building (approximately 900sqm) that would accommodate its growing needs, and the area of land to the north would be an ideal location for this. This area has been included within the boundary of the employment site in the Employment Sites Review Background Paper, which suggests that the Council already consider it to form part of the site (rather than as part of the surrounding countryside).
The proposed site is well-screened by existing vegetation along all its boundaries and is not in agricultural use. In fact, it would not be suitable for agricultural use given its proximity to the employment site and separation from the adjacent fields by substantially vegetated boundaries. The land is redundant for this reason and the Estate have therefore put it into temporary use as an archery range. The preferred use of the land would be for an extension to the existing employment site so that the Estate may continue to provide units of various sizes and design to suit the evolving needs of rural businesses.

The Employment Sites Review Background Paper (despite it including proposed aforementioned area within the site boundary), states that there are no expansion opportunities at the site. We do not agree with this, and consider there to be a significant opportunity for additional buildings that meet the growing needs of local rural businesses. The site has proven to be successful to date, and makes an important contribution to the rural economy. Its location in a relatively remote area is inconsequential as there is a specific demand for sites like this in rural areas, as acknowledged in the adopted Core Strategy 2014 and draft DaSA. The success of the site to date, as well as the commitment by the Estate to investing in site improvements (including additional buildings), is a testament to this.

Page 76 of the DaSA confirms the importance of rural business sites:

"(15) the Rural Areas have seen most business development in recent years, as well as accounting for the greatest amount of floorspace with full planning permission, which together approximate to the minimum floorspace target; (16) these findings point to the role that rural areas are playing in meeting the accommodation requirements of businesses and, hence, to the economic growth of the District, and it is recommended this trend should not be frustrated".

We are aware that a Neighbourhood Plan Area has been designated for Battle and the surrounding area, which would include the Beech Farm employment site; however this plan does not appear to have made any progress since the Neighbourhood Plan Area was designated in April 2015. It is therefore crucial that the DaSA provides the necessary policies to support employment development in the Battle area, and allocates sites where appropriate. Policy EC3 (Existing Employment Sites) of the Core Strategy supports a full review of existing employment premises and the allocation of new sites in the DaSA and/or Neighbourhood Plans. The DaSA is now in preparation and, given the lack of progress with the Battle Neighbourhood Plan, the DaSA must provide the necessary supporting policies for additional buildings at the Beech Farm employment site.

Until the DaSA is adopted, Policy EC3 will apply to any proposal for new buildings at Beech Farm and part (ii) of the policy currently supports the "intensification, conversion, redevelopment and/or extension [of sites] having regard to other policies of the Plan". Our concern with relying on part (ii) of Policy EC3 (or Policy DEC3 of the DaSA, if it is adopted) in the submission of a planning application for new buildings at Beech Farm, is that there would be the potential for other policies in the plan (such as restrictive countryside policies or AONB policies) that could prevent the application from being approved. This uncertainty would create risk to any application that is submitted and, as such, the Estate would hesitate to release the funds required for making such a speculative application. Greater certainty would be needed regarding the principle of the development if the Estate is to submit an application for new buildings at Beech Farm, and this could be achieved if the site is allocated.
We therefore request that the area of land immediately north of Beech Farm is allocated for additional business development that would complement the existing, successful, rural business site. The extent of the existing site and extension area would follow the exact same boundary drawn around the site in the Employment Sites Review Background Paper (page 60). We reiterate that the Battle Neighbourhood Plan cannot be relied upon to allocate the site, given the lack of progress demonstrated to date.

2. Question 17: Do you agree with the policy approach to existing employment sites and the proposed policy wording?

The current consultation on the DaSA proposes to replace Policy EC3 of the Core Strategy with policy DEC3. The wording of the new policy appears to be identical, apart from a slight discrepancy in part (iv) in the use of the word 'prioritising' instead of 'prioritise'. Whilst perhaps more grammatically correct, we do not consider there to be a need to amend Core Strategy Policy EC3 for this reason alone.

The original intention of the policy amendment appears to include a need for greater flexibility to include 'lack of need' and 'incompatible land uses' as alternative reasons for why a change of use at an existing employment site might be acceptable (along with viability, which is already mentioned), and this is something that we would support in the policy wording. We also support the retention of part (ii) of the policy, which remains as per Policy EC3 (quoted earlier in this letter).

3. Housing Allocations in Battle

Following our comments in relation to the need to include employment site allocations for the Battle area within the DaSA to mitigate a Neighbourhood Plan not coming forward at all, or within a reasonable timeframe, we consider it important to comment on housing sites in this respect as well. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

The adopted Core Strategy sets a requirement of 475-500 dwellings to be brought forward in Battle during the plan period. Paragraph 11.10 states that sites are to be brought forward in the DaSA, although paragraph 7.52 includes the possibility of sites coming forward in Neighbourhood Plan.

The same housing requirements are carried over to the draft DaSA, with an identified residual requirement of 425 dwellings to be allocated on new sites in Battle. This is not an insignificant amount and it makes a valuable contribution to the District's housing supply. Given the lack of progress being made with the Neighbourhood Plan, to rely entirely on it to deliver the required number of new homes would put a question mark over the ability of the plan to deliver the requisite number of dwellings during the plan period (particularly the early part of it). Eight other Neighborhood Pplans are being relied upon in this way - albeit two have made sufficient progress that their delivery can more reasonably be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). However, it is impossible to control this process, and the Council are placing an unreasonable amount of pressure on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale.

The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control. It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA for the Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is currently being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of employment and housing site allocations in the DaSA for Battle would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area could result in little economic or residential development taking place for the early part of the plan period, leaving the Council with an employment and housing land supply shortage when assessed against objective needs.

As such, we submit the following three sites for allocation for residential development on the western edge of Battle, within the Beech Estate:

* Land West of Vale Road
* Land West of Battle Hospital A
* Land West of Battle Hospital B

Plans and forms containing information for each of these sites are enclosed.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

Beech Farm Employment Site:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28093

Land west of Battle Hospital A - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28094

Land west of Battle Hospital B - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28095

Land west of Vale Road - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28096

The Background Paper to the DaSA entitled Employment Sites Review (November 2016) identifies Beech Farm in the rural area of Battle as an established employment site measuring 2.2 hectares and containing approximately 12 business units (page 59). The site is identified as being substantially occupied and we can confirm that occupancy rates have been consistently high for a number of years. The site is currently at full capacity with 25 businesses within 19 units.

The site comprises a number of relatively attractive former agricultural barns and stables that have been converted into business units. Three larger, more modern agricultural buildings provide larger units that are predominantly being used for storage and distribution purposes. The smaller units are being used by a variety of businesses, including a beautician's, photography studio, stained glass manufacturer, archery shop, and two mechanics' workshops.

The buildings are grouped together in an old farmstead, which reflects their original intended uses; however an area of undeveloped land lies immediately to the north of the larger, modern buildings which would provide a suitable location for additional buildings at this important rural business site. The Estate has already been approached by one of the current tenants at Beech Farm for a new, larger building (approximately 900sqm) that would accommodate its growing needs, and the area of land to the north would be an ideal location for this. This area has been included within the boundary of the employment site in the Employment Sites Review Background Paper, which suggests that the Council already consider it to form part of the site (rather than as part of the surrounding countryside).
The proposed site is well-screened by existing vegetation along all its boundaries and is not in agricultural use. In fact, it would not be suitable for agricultural use given its proximity to the employment site and separation from the adjacent fields by substantially vegetated boundaries. The land is redundant for this reason and the Estate have therefore put it into temporary use as an archery range. The preferred use of the land would be for an extension to the existing employment site so that the Estate may continue to provide units of various sizes and design to suit the evolving needs of rural businesses.

The Employment Sites Review Background Paper (despite it including proposed aforementioned area within the site boundary), states that there are no expansion opportunities at the site. We do not agree with this, and consider there to be a significant opportunity for additional buildings that meet the growing needs of local rural businesses. The site has proven to be successful to date, and makes an important contribution to the rural economy. Its location in a relatively remote area is inconsequential as there is a specific demand for sites like this in rural areas, as acknowledged in the adopted Core Strategy 2014 and draft DaSA. The success of the site to date, as well as the commitment by the Estate to investing in site improvements (including additional buildings), is a testament to this.

Page 76 of the DaSA confirms the importance of rural business sites:

"(15) the Rural Areas have seen most business development in recent years, as well as accounting for the greatest amount of floorspace with full planning permission, which together approximate to the minimum floorspace target; (16) these findings point to the role that rural areas are playing in meeting the accommodation requirements of businesses and, hence, to the economic growth of the District, and it is recommended this trend should not be frustrated".

We are aware that a Neighbourhood Plan Area has been designated for Battle and the surrounding area, which would include the Beech Farm employment site; however this plan does not appear to have made any progress since the Neighbourhood Plan Area was designated in April 2015. It is therefore crucial that the DaSA provides the necessary policies to support employment development in the Battle area, and allocates sites where appropriate. Policy EC3 (Existing Employment Sites) of the Core Strategy supports a full review of existing employment premises and the allocation of new sites in the DaSA and/or Neighbourhood Plans. The DaSA is now in preparation and, given the lack of progress with the Battle Neighbourhood Plan, the DaSA must provide the necessary supporting policies for additional buildings at the Beech Farm employment site.

Until the DaSA is adopted, Policy EC3 will apply to any proposal for new buildings at Beech Farm and part (ii) of the policy currently supports the "intensification, conversion, redevelopment and/or extension [of sites] having regard to other policies of the Plan". Our concern with relying on part (ii) of Policy EC3 (or Policy DEC3 of the DaSA, if it is adopted) in the submission of a planning application for new buildings at Beech Farm, is that there would be the potential for other policies in the plan (such as restrictive countryside policies or AONB policies) that could prevent the application from being approved. This uncertainty would create risk to any application that is submitted and, as such, the Estate would hesitate to release the funds required for making such a speculative application. Greater certainty would be needed regarding the principle of the development if the Estate is to submit an application for new buildings at Beech Farm, and this could be achieved if the site is allocated.
We therefore request that the area of land immediately north of Beech Farm is allocated for additional business development that would complement the existing, successful, rural business site. The extent of the existing site and extension area would follow the exact same boundary drawn around the site in the Employment Sites Review Background Paper (page 60). We reiterate that the Battle Neighbourhood Plan cannot be relied upon to allocate the site, given the lack of progress demonstrated to date.

2. Question 17: Do you agree with the policy approach to existing employment sites and the proposed policy wording?

The current consultation on the DaSA proposes to replace Policy EC3 of the Core Strategy with policy DEC3. The wording of the new policy appears to be identical, apart from a slight discrepancy in part (iv) in the use of the word 'prioritising' instead of 'prioritise'. Whilst perhaps more grammatically correct, we do not consider there to be a need to amend Core Strategy Policy EC3 for this reason alone.

The original intention of the policy amendment appears to include a need for greater flexibility to include 'lack of need' and 'incompatible land uses' as alternative reasons for why a change of use at an existing employment site might be acceptable (along with viability, which is already mentioned), and this is something that we would support in the policy wording. We also support the retention of part (ii) of the policy, which remains as per Policy EC3 (quoted earlier in this letter).

3. Housing Allocations in Battle

Following our comments in relation to the need to include employment site allocations for the Battle area within the DaSA to mitigate a Neighbourhood Plan not coming forward at all, or within a reasonable timeframe, we consider it important to comment on housing sites in this respect as well. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

The adopted Core Strategy sets a requirement of 475-500 dwellings to be brought forward in Battle during the plan period. Paragraph 11.10 states that sites are to be brought forward in the DaSA, although paragraph 7.52 includes the possibility of sites coming forward in Neighbourhood Plan.

The same housing requirements are carried over to the draft DaSA, with an identified residual requirement of 425 dwellings to be allocated on new sites in Battle. This is not an insignificant amount and it makes a valuable contribution to the District's housing supply. Given the lack of progress being made with the Neighbourhood Plan, to rely entirely on it to deliver the required number of new homes would put a question mark over the ability of the plan to deliver the requisite number of dwellings during the plan period (particularly the early part of it). Eight other Neighborhood Pplans are being relied upon in this way - albeit two have made sufficient progress that their delivery can more reasonably be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). However, it is impossible to control this process, and the Council are placing an unreasonable amount of pressure on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale.

The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control. It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA for the Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is currently being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of employment and housing site allocations in the DaSA for Battle would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area could result in little economic or residential development taking place for the early part of the plan period, leaving the Council with an employment and housing land supply shortage when assessed against objective needs.

As such, we submit the following three sites for allocation for residential development on the western edge of Battle, within the Beech Estate:

* Land West of Vale Road
* Land West of Battle Hospital A
* Land West of Battle Hospital B

Plans and forms containing information for each of these sites are enclosed.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

Beech Farm Employment Site:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28093

Land west of Battle Hospital A - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28094

Land west of Battle Hospital B - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28095

Land west of Vale Road - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28096

The Background Paper to the DaSA entitled Employment Sites Review (November 2016) identifies Beech Farm in the rural area of Battle as an established employment site measuring 2.2 hectares and containing approximately 12 business units (page 59). The site is identified as being substantially occupied and we can confirm that occupancy rates have been consistently high for a number of years. The site is currently at full capacity with 25 businesses within 19 units.

The site comprises a number of relatively attractive former agricultural barns and stables that have been converted into business units. Three larger, more modern agricultural buildings provide larger units that are predominantly being used for storage and distribution purposes. The smaller units are being used by a variety of businesses, including a beautician's, photography studio, stained glass manufacturer, archery shop, and two mechanics' workshops.

The buildings are grouped together in an old farmstead, which reflects their original intended uses; however an area of undeveloped land lies immediately to the north of the larger, modern buildings which would provide a suitable location for additional buildings at this important rural business site. The Estate has already been approached by one of the current tenants at Beech Farm for a new, larger building (approximately 900sqm) that would accommodate its growing needs, and the area of land to the north would be an ideal location for this. This area has been included within the boundary of the employment site in the Employment Sites Review Background Paper, which suggests that the Council already consider it to form part of the site (rather than as part of the surrounding countryside).
The proposed site is well-screened by existing vegetation along all its boundaries and is not in agricultural use. In fact, it would not be suitable for agricultural use given its proximity to the employment site and separation from the adjacent fields by substantially vegetated boundaries. The land is redundant for this reason and the Estate have therefore put it into temporary use as an archery range. The preferred use of the land would be for an extension to the existing employment site so that the Estate may continue to provide units of various sizes and design to suit the evolving needs of rural businesses.

The Employment Sites Review Background Paper (despite it including proposed aforementioned area within the site boundary), states that there are no expansion opportunities at the site. We do not agree with this, and consider there to be a significant opportunity for additional buildings that meet the growing needs of local rural businesses. The site has proven to be successful to date, and makes an important contribution to the rural economy. Its location in a relatively remote area is inconsequential as there is a specific demand for sites like this in rural areas, as acknowledged in the adopted Core Strategy 2014 and draft DaSA. The success of the site to date, as well as the commitment by the Estate to investing in site improvements (including additional buildings), is a testament to this.

Page 76 of the DaSA confirms the importance of rural business sites:

"(15) the Rural Areas have seen most business development in recent years, as well as accounting for the greatest amount of floorspace with full planning permission, which together approximate to the minimum floorspace target; (16) these findings point to the role that rural areas are playing in meeting the accommodation requirements of businesses and, hence, to the economic growth of the District, and it is recommended this trend should not be frustrated".

We are aware that a Neighbourhood Plan Area has been designated for Battle and the surrounding area, which would include the Beech Farm employment site; however this plan does not appear to have made any progress since the Neighbourhood Plan Area was designated in April 2015. It is therefore crucial that the DaSA provides the necessary policies to support employment development in the Battle area, and allocates sites where appropriate. Policy EC3 (Existing Employment Sites) of the Core Strategy supports a full review of existing employment premises and the allocation of new sites in the DaSA and/or Neighbourhood Plans. The DaSA is now in preparation and, given the lack of progress with the Battle Neighbourhood Plan, the DaSA must provide the necessary supporting policies for additional buildings at the Beech Farm employment site.

Until the DaSA is adopted, Policy EC3 will apply to any proposal for new buildings at Beech Farm and part (ii) of the policy currently supports the "intensification, conversion, redevelopment and/or extension [of sites] having regard to other policies of the Plan". Our concern with relying on part (ii) of Policy EC3 (or Policy DEC3 of the DaSA, if it is adopted) in the submission of a planning application for new buildings at Beech Farm, is that there would be the potential for other policies in the plan (such as restrictive countryside policies or AONB policies) that could prevent the application from being approved. This uncertainty would create risk to any application that is submitted and, as such, the Estate would hesitate to release the funds required for making such a speculative application. Greater certainty would be needed regarding the principle of the development if the Estate is to submit an application for new buildings at Beech Farm, and this could be achieved if the site is allocated.
We therefore request that the area of land immediately north of Beech Farm is allocated for additional business development that would complement the existing, successful, rural business site. The extent of the existing site and extension area would follow the exact same boundary drawn around the site in the Employment Sites Review Background Paper (page 60). We reiterate that the Battle Neighbourhood Plan cannot be relied upon to allocate the site, given the lack of progress demonstrated to date.

2. Question 17: Do you agree with the policy approach to existing employment sites and the proposed policy wording?

The current consultation on the DaSA proposes to replace Policy EC3 of the Core Strategy with policy DEC3. The wording of the new policy appears to be identical, apart from a slight discrepancy in part (iv) in the use of the word 'prioritising' instead of 'prioritise'. Whilst perhaps more grammatically correct, we do not consider there to be a need to amend Core Strategy Policy EC3 for this reason alone.

The original intention of the policy amendment appears to include a need for greater flexibility to include 'lack of need' and 'incompatible land uses' as alternative reasons for why a change of use at an existing employment site might be acceptable (along with viability, which is already mentioned), and this is something that we would support in the policy wording. We also support the retention of part (ii) of the policy, which remains as per Policy EC3 (quoted earlier in this letter).

3. Housing Allocations in Battle

Following our comments in relation to the need to include employment site allocations for the Battle area within the DaSA to mitigate a Neighbourhood Plan not coming forward at all, or within a reasonable timeframe, we consider it important to comment on housing sites in this respect as well. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

The adopted Core Strategy sets a requirement of 475-500 dwellings to be brought forward in Battle during the plan period. Paragraph 11.10 states that sites are to be brought forward in the DaSA, although paragraph 7.52 includes the possibility of sites coming forward in Neighbourhood Plan.

The same housing requirements are carried over to the draft DaSA, with an identified residual requirement of 425 dwellings to be allocated on new sites in Battle. This is not an insignificant amount and it makes a valuable contribution to the District's housing supply. Given the lack of progress being made with the Neighbourhood Plan, to rely entirely on it to deliver the required number of new homes would put a question mark over the ability of the plan to deliver the requisite number of dwellings during the plan period (particularly the early part of it). Eight other Neighborhood Pplans are being relied upon in this way - albeit two have made sufficient progress that their delivery can more reasonably be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). However, it is impossible to control this process, and the Council are placing an unreasonable amount of pressure on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale.

The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control. It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA for the Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is currently being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of employment and housing site allocations in the DaSA for Battle would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area could result in little economic or residential development taking place for the early part of the plan period, leaving the Council with an employment and housing land supply shortage when assessed against objective needs.

As such, we submit the following three sites for allocation for residential development on the western edge of Battle, within the Beech Estate:

* Land West of Vale Road
* Land West of Battle Hospital A
* Land West of Battle Hospital B

Plans and forms containing information for each of these sites are enclosed.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

Beech Farm Employment Site:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28093

Land west of Battle Hospital A - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28094

Land west of Battle Hospital B - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28095

Land west of Vale Road - Plan:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28096