Proposed Submission Development and Site Allocations (DaSA) Local Plan

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

DEC3: Existing Employment Sites and Premises

Representation ID: 24351

Received: 07/12/2018

Respondent: John Jempson & Son Ltd

Agent: MDA Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

John Jempson & Son Ltd are bringing forward re-development proposals for all three of their major sites in Rye that together will provide housing and employment facilities. However to allow the consolidation of their business onto one site at Harbour Road it is necessary that all three of their sites MUST come forward together and be economically viable if all the existing employment is to be maintained.

In order to accommodate this relocation there cannot be a policy disconnect between the DaSA and the Rye Neighbourhood Plan in relation to the policies designed to protect existing employment sites, namely DEC3 and DC01. The Jempson sites in the town centre are allocated for residential led re-development in the Rye Neighbourhood Plan. These sites should therefore not be subject to the tests set out in Policy DEC3 and DEC01 and this should be noted at para 5.39 of the DaSA Local Plan.

Policy DEC3 should only relate to how existing employment sites can be used for that purpose. Criteria iv) relates to situations where redevelopment of existing employment sites would occur and it is wholly inappropriate for inclusion in this policy.

This criteria should therefore be deleted.

Full text:

John Jempson & Son Ltd are bringing forward re-development proposals for all three of their major sites in Rye that together will provide much needed new housing and modern employment facilities. However to allow the consolidation of their business onto one site at Harbour Road it is necessary that all three of their sites MUST come forward together and be economically viable if all the existing employment is to be maintained.

In order to accommodate this relocation of their business and tenants from Rye town centre and ensure a smooth transition, there cannot be a policy disconnect between the Rother DaSA Local Plan and the Rye Neighbourhood Plan in relation to the policies designed to protect existing employment sites, namely DEC 3 and DC01. The Jempson sites in the town centre are allocated for residential led re-development in the Rye Neighbourhood Plan. These sites should therefore not be subject to the tests set out in Policy DEC3 and DEC01 and this should be noted at para 5.39 of the DaSA Local Plan.

Amendment to Para 5.39

Insert an additional sentence:- "in these instances Policies DEC01 and DEC3 would not apply."

Amendment to DEC3

Policy DEC3 should only relate to how existing employment sites can be used for that purpose. Criteria iv) relates to situations where redevelopment of existing employment sites would occur and it is wholly inappropriate for inclusion in this policy.

This criteria should therefore be deleted.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy RHA2: Harbour Road Employment Area

Representation ID: 24352

Received: 07/12/2018

Respondent: John Jempson & Son Ltd

Agent: MDA Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

John Jempson & Son Ltd are bringing forward redevelopment proposals for all three of their major sites in Rye. To allow the consolidation of their business onto one site at Harbour Road all three sites MUST come forward together and be economically viable if all the existing employment is to be maintained. In order to accommodate this relocation, their site on Harbour Road, needs to be expanded as shown on the attached plan. This can happen without having a significant impact on the surrounding environmental designations.

There needs to be an element of flexibility in the definition of the Employment Area boundary to accommodate development proposals in the future.

Therefore, we propose an amendment to the boundary defined on Figure 56 as shown on the attached plan (plan attached: www.rother.gov.uk/CHttpHandler.ashx?id=31160). This is a significantly reduced area from that which was originally put forward as Site RH6. The site is reduced to create an area where the environmental impacts arising can be mitigated through an ecological management plan but still allow expansion of the site to provide for the relocation of Jempson from Rye town centre and new accommodation for their tenants.

Full text:

Chapter 11, Policy RHA2

Harbour Road Employment Area, Rye

The Proposed Amendment to Figure 56

John Jempson & Son Ltd are bringing forward re-development proposals for all three of their major sites in Rye that together will provide much needed new housing and modern employment facilities. However to allow the consolidation of their business onto one site at Harbour Road it is necessary that all three sites MUST come forward together and be economically viable if all the existing employment is to be maintained. In order to accommodate this relocation of their business and tenants from Rye town centre, their site on Harbour Road, as
shown on Figure 56, needs to be expanded as shown on the attached plan. This can happen without having a significant impact on the surrounding environmental designations.

Background Information

The Employment Sites Review noted that the Harbour Road Employment Area has an important strategic role to play being the main economic hub for the eastern half of the District. This strategic role has to be balanced against the need to not adversely impact on the surrounding environmental constraints.

However this area also has the most intensification potential to deliver more jobs locally (para 5.37e), therefore there needs to be an element of flexibility in the definition of the Employment Area boundary to accommodate development proposals in the future.

An example of where this has already occurred in the Harbour Road EA is the amendment made to take account of the development at Site RH2, The Saltings. Here it was recognised that given the significant contribution to local jobs the environmental impacts arising could be mitigated.

Therefore, we propose an amendment to the boundary defined on Figure 56 as shown on the attached plan. (plan attached: www.rother.gov.uk/CHttpHandler.ashx?id=31160) This is a significantly reduced area from that which was originally put forward as Site RH6 (land south of the former Spun Concrete site) and assessed in the Sustainability Appraisal (Volume 3, Appendix 4, Page 133, Site RH6). In response to the comments made the site is reduced to create an area where the environmental impacts arising can be mitigated through an ecological management plan but will still allow an expansion of the site to provide for the relocation requirements for Jempson from Rye town centre, as well as providing new accommodation for their tenants.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

1.31

Representation ID: 24353

Received: 07/12/2018

Respondent: John Jempson & Son Ltd

Agent: MDA Associates

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

John Jempson & Son Ltd are bringing forward redevelopment proposals for all three of their major sites in Rye. To allow the consolidation of their business onto one site at Harbour Road all three sites MUST come forward together and be economically viable if all the existing employment is to be maintained. In order to accommodate this relocation, their site on Harbour Road needs to be expanded as shown on the attached plan. This will not have a significant impact on the surrounding environmental designations.

The Sustainability Appraisal of Site RH6 assumes that the whole site is "greenfield". This is not the case and therefore the poor scores shown does not accurately reflect the position.

A reassessment should be made of Site RH6 based on the attached plan which shows the existing employment site and some expansion land. This is needed for the relocation and consolidation of Jempson business from Rye town centre, thereby facilitating the much needed re-development of their existing employment sites for housing and maintaining the existing local jobs.

Amendment

Review the SA for Site RH6 based upon the revised site area as shown attached. (map attached: www.rother.gov.uk/CHttpHandler.ashx?id=31160)

Full text:

John Jempson & Son Ltd are bringing forward re-development proposals for all three of their major sites in Rye that together will provide much needed new housing and modern employment facilities. However to allow the consolidation of their business onto one site at Harbour Road it is necessary that all three sites MUST come forward together and be economically viable if all the existing employment is to be maintained. In order to accommodate this relocation of their business and tenants from Rye town centre, their site on Harbour Road,
as shown on Figure 56, needs to be expanded as shown on the attached plan. This can happen without having a significant impact on the surrounding environmental designations.

The Sustainability Appraisal of Site RH6 (p133) assumes that all of the site is a "greenfield" site. This is not the case and therefore the poor scores shown in the assessment for employment uses does not accurately reflect the position.

A reassessment should be made of Site RH6 based on the attached site plan which shows the existing employment site and some expansion land. This is needed for the relocation and consolidation of Jempson business from Rye town centre to this site, thereby facilitating the much needed re-development of their existing employment sites for housing and maintaining the existing local jobs.

Amendment

Review the SA for Site RH6 based upon the revised site area as shown attached. (map attached: www.rother.gov.uk/CHttpHandler.ashx?id=31160)

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