Local Plan Supporting Evidence Base Documents

Comment

Representation ID: 28293

Received: 23/07/2024

Respondent: Wards of London

Agent: Paul Dickinson & Associates

Comments in support of BEX0032

I am writing on behalf of Wards of London, the landowners of former Sidley Sports
Ground, Glovers Lane, Bexhill-on-Sea TN39 5ER. The extent of their land is shown on
the attached plan.
The Regulation 18 Draft Version advises that it sets out a clear and evidenced policy
direction that the Council wishes to take in respect of key planning objectives.
Paragraph 1.40 explains that individual site allocation policies will form Chapter 13 in
due course, but this is not part of the Regulation 18 consultation because the Council
wants to consult on the development strategy and draft housing and economic land
availability assessment (HELAA) before final site selection and specific site allocation
policies are prepared. My comments are therefore made in that context.
You will be aware that the former Sidley Sports Ground site is allocated under Policy
BEX11 of the adopted DaSA (December 2019) for a full size 3G artificial grass pitch
(AGP) including floodlighting, ancillary changing facilities, a community hub and
associated open space.
However, the Council has recently reassessed the site (BEX0032) as part of its
consideration of the Draft HELAA April 2024 which forms an important part of the
evidence base to the emerging local plan. It notes that the site was previously the
sports ground of Sidley United Football Club but has been disused since around 2013,
so more than 10 years. It also notes that the landowner has indicated the site is
available for residential development, however, its current planning use remains as
open space as a sports field and an alternative use would be contrary to policy BEX11
and the NPPF which seeks to retain valued community facilities and services and guards against the loss of sports and recreational buildings and land unless they are
surplus to requirements or the loss would be replaced by equivalent or better provision
in terms of quantity and/or quality in a suitable location.
The Council’s assessment concludes that current evidence suggests the existing
allocation is unlikely to come forward but in principle the site is in a sustainable location
for housing. The assessment states that if the landowner were to provide a 3G pitch
and associated facilities in a suitable alternative location, then the site could potentially
be suitable for a mixed-use, to include residential development, a community use and
open space, subject to a change to adopted local plan policy.
The emerging local plan review provides such an opportunity to change the policy so
that the overall objectives relating to the provision of appropriate sport and recreation
facilities are still met but a positive and viable use for the site can be encouraged to
come forward rather than it remaining vacant and disused.
The landowners and their professional team, including myself, are in discussions with
Council officers and other stakeholders to seek agreement on a package which would
meet all the relevant policy objectives. This package is based on the provision of a fullsized 3G pitch with floodlighting and associated facilities at Bexhill Academy to the
west of the site. This would provide a significant enhancement and improvement to the
current sports pitch offer at the Academy both for its pupils and for the wider
community. This provision would then free up the site for residential-led development.
These discussions are at an advanced stage and we shortly intend to engage directly
with the Planning Policy team.
The HELAA indicates that the site would be suitable for a mixed-use including
residential development, a community use and open space. Clearly there are
questions around financial viability that need to be assessed in order to ensure that any
allocation is viable and there are realistic expectations of what can be funded by the
residential development. Discussions with Graeme Quinnell, the Council’s Housing
Enabling and Development Officer, have been on the basis of a 100% affordable
scheme. A feasibility exercise is being undertaken to determine the costs of the 3G
pitch and associated facilities. The development will also need to fund other
requirements such as biodiversity net gain and CIL where applicable whilst still provide
a commercial incentive for the landowner to bring forward proposals.
We would therefore welcome the opportunity to discuss a site allocation to be included
in the Regulation 19 plan for residential-led development on a viable scale together
with a requirement that the loss of the former playing field would be replaced by
equivalent or better provision in terms of quantity and/or quality in a suitable location.