Proposed Submission Development and Site Allocations (DaSA) Local Plan

Q2b We consider that the DaSa Local Plan to be unsound because it is not Justified
The DaSa is not justified because (in the context of including the CPC recreation ground within the CVCP boundary)
1. It cannot show proof of involving the local community and its key stakeholders.
The background evidence supporting consultation statements was not adequate because the information published was not fit for purpose. The only published information in the DaSA was a relevant to the CRG was a poor-quality map of the CVCP boundary. There is no textual reference.
The policies BX4 and HF1 and HAS1 when read are reasonable and would not require comment other than the inclusion of the CPC recreation ground in the CVCP which is not evident in the text of the policies. None of the policies refer to Crowhurst. The DaSA in total only refers to Crowhurst in the context of strategic gaps, on which we did comment in the 2016 DaSA consultation.
The DaSA and background evidence refer to "the Countryside Park is a long-term project which addresses the deficiency in green space for the towns of Hastings and Bexhill" and that "The Park was set up to facilitate the restoration of the landfill areas and to manage to the countryside between the towns". The background evidence in the DaSA refers to the use of the CVCP (which is essential open countryside) by residents of Hastings and Bexhill. RDC have engaged with Hastings and Bexhill but not with CPC. Clearly the focus is to set up new open Countryside Green space for the use of the two large towns of Bexhill and Hastings. The CPC recreation ground has no relevance to this plan and there is no evidence that RDC communicated at all with CPC concerning the rational for including the CPC recreation ground in the CVCP.
2. The are no Solid Facts and Research.
The DaSA supporting background evidence does not address
o Why the sports field at our recreation needs to be included in a "Countryside Park" whose aims are not consistent with the facilities present at the CRG. The CVCP is essentially defined in the DaSA as open Countryside that can be developed for mass use by the inhabitants of Bexhill & Hasting to providing a tranquil environment for Cyclist, Walkers and outdoor "Countryside" pursuits. The CRG sports field is just a small field of grass.
- Why it is necessary that strategic oversight of the management of a sports field owned, managed and funded by the Parish Council is to be provided by a CiC with a policy aim (HF1) to "set out the strategic importance of the Park in the context of an overall shared approach to future prosperity for Hastings and Bexhill".
- Why a sports field that cannot be accessed from any other area of the CVCP (to access the recreation ground it is necessary to leave the CVCP, use a public highway, and enter via a car park that is not within the CVCP) must be included in the CVCP and how that would to contribute to its policy aims.
- What facilities within the recreation ground will enhance the CVCP. The sports field is in regular use and only available when booked via the Council. There is no access for the public (including users of the CVCP) to the buildings in the recreation ground unless being used by sports teams with agreed access. There are no public toilets. Use of the recreation ground car park is restricted to users of the recreation ground. How will that contribute to the RDC policy aims?

* While there may be a need to define strategic gaps (you don't need a CVCP or CiC to achieve that policy aim), there is clearly no solid fact or research that supports the inclusion of the CPC recreation ground in the CVCP that is consistent with its policy aims.

Q4. What Changes do you consider necessary?

1. The Boundary of the CVCP as show in MAP 2 of the DaSA must be changed to exclude all of the CPC recreation ground and its car park.
This new boundary will then be consistent with the policy aims HF1 and HAS1 and leave the strategic oversight of the recreation ground and the application of any planning within the remit of the Parish Council. This would prevent any changes that may be introduced by the CiC that may apply to the CVCP being introduced to the detriment of Crowhurst.
The Strategic Gap policies in the DaSA do not need to change in this respect. The recreation ground is green space and cannot be developed due to covenants restricting its use for sport activity.
There is no need to change the text of the relevant DaSA policies by removing the CPC recreation ground from the CVCP boundary.