Hastings Local Plan Draft Local Plan Preferred Options (Regulation 18)

4. Strategic Policies Comment

Introduction Comment

4.1One of the principal functions of the Local Plan is to set out the amount of future development being planned for, where it is to be located, and what form it will take. This section presents both the overall development strategy, set out in Policy SP1, which identifies the spatial approach and broad distribution of development across the borough, and complementary 'strategic policies', which set out the overall approach in relation to key themes including the scale of housing and employment growth.

4.2These borough-wide strategic policies form the basis of this Local Plan’s policy framework and are the starting point for the more detailed policies and proposals in subsequent sections. It is these key strategic policies to which neighbourhood plans should generally conform. The strategic policies should be read alongside specific development potential and regeneration area policies, site allocation policies and detailed development management policies contained within Parts 5, 6 and 7 respectively, as well as any locally specific policies set out within future neighbourhood plans.

Strategic Policy 1 (SP1): Directing Growth – a Spatial Strategy Comment

4.3At the heart of our spatial strategy is the need to promote sustainable development as the framework for growth and change in Hastings. The Local Plan provides an ambitious and positive framework for addressing local housing and economic needs and other social and environmental priorities to better enable the council and other stakeholders to invest in housing, jobs communities and places, making the most of investment opportunities as they arise to effectively address spatial planning challenges over the plan period.

4.4Growth in the first instance is directed to locations which are well supported by existing or planned sustainable transport infrastructure and other services. This approach will help minimise carbon emissions from travel and allow significantly increased development densities in appropriate locations. This in turn can also help to deliver much needed housing, alongside spaces for businesses to grow. This increased demand from new occupants can help bolster local shops and services and may help justify greater investment in infrastructure such as increased bus services and other sustainable transport initiatives.

4.5The council has set an ambitious target for the town to work towards becoming carbon neutral ahead of the UK target of 2050. This target is consistent with and informs our development strategy for accommodating growth and change. Managing the pattern of development in this way, ensures it is sustainable, will lessen encroachment on the natural environment - including protecting soil, water, and vegetation that have an important role in carbon mitigation.

4.6Hastings also has significant levels of flood risk in different parts of the borough, and this risk will grow with climate change. We have sought to avoid allocating sites in areas with elevated flood risk where this cannot be mitigated. New Windfall development is not expected within these locations or in areas strictly protected for their natural environmental benefits, unless it can be evidenced that the use is compatible, risk can be mitigated and is aligned with other policies in the Local Plan.

4.7Hastings is tightly constrained. To the north, east and west is largely bounded by the borough boundary, and nationally or sub-regionally important environmental designations with the English Channel to the south. There is therefore limited opportunity for outward growth and expansion of the Town as a whole.

4.8As a result, our growth strategy must focus on prioritising development on Previously Developed Land (brownfield sites) within the urban area, through renewal, regeneration and densification and lastly through suitable greenfield site development in order to maximise the number of new homes which can be delivered.

4.9To maximise housing delivery over the life of the plan, the Hastings Densification and Capacity Study puts forward suggested minimum densities at which new housing development sites should be built, with no identified maximum density. Whilst these minimum densities are a guide, they are put forward with the intention of ensuring that the very best use of land is made in redevelopment. The Study divides the Borough into Density Zones according to their appropriateness for increased density. A map showing these Density Zones within Hastings Borough is included in Section 6 of the Plan.

4.10The Density Zones are a starting point based on analysis of suitability only with no account taken of potential individual site sensitivity arising from the natural and built environment. Seven criteria have been combined and analysed to provide an overview of the relative suitability of densification for different parts of the Borough. Conclusions on the potential for increasing densities can be drawn from where and how these criteria overlap, building a case for how some areas are more suitable than others for significant densification.

4.11As well as using the Density Strategy to inform indicative capacity numbers at individual site level, in some circumstances we have relied on other information. This includes, for example, where a site has an existing planning approval, or the capacity has been informed by design work from another study, or the site is located in a highly sensitive location such as the High Weald National Landscape. In addition, across all Density Zones, small sites which might only involve one single building on a plot, might deliver densities well in excess of the Density Zone within which they are located. This is particularly so for small sites in the most sustainable and central locations.

4.12As the sites allocated through the plan will not meet the Government’s Housing Target for Hastings, it is accepted that Windfall development will need to play a role in augmenting housing delivery. A Small Site Windfall housing projection is therefore included in the housing land supply figure.

4.13In addition, over the lifetime of the Plan, the following have the potential to increase housing delivery. These are:

• Housing renewal areas, of which three locations are identified in the Plan (see Policy H6);
• The greenfield development potential area on land known as Breadsell. Working with Rother District Council, this would be a cross-boundary site, which subject to ascertaining the suitability of the site would form an urban extension to Hastings (see Policy D1);
• Redevelopment of the former Convent of Holy Child Jesus, which secures the repair, restoration and long-term sustainable future of the Convent buildings. A Development Brief and Masterplan is in preparation (see Policy R2); and,
• The regeneration potential offered by the ‘Hastings Central Regeneration Area’, which includes Hastings Town Centre (see Policy R1). Also, a smaller regeneration area around Warrior Square Station in St. Leonards (See Policy R3).

4.14The Spatial Strategy seeks to achieve the right balance between planning positively to meet the town’s development needs for homes, jobs, shops and services whilst continuing to protect and enhance the Town’s environment recreational spaces and heritage assets. The core principles that will help to direct this are set out in strategic Policy SP1.

Strategic Policy 1 (SP1): Directing Growth Comment

Strategic Policy 2 (SP2): New and Affordable Housing Comment

4.15National planning policy, as set out in the NPPF (or the Framework), expects local plans to promote sustainable patterns of development. This includes meeting, as a minimum, the identified level of housing needs for their areas in full. National policy requires us to use a government-set methodology to calculate the housing needed in our area, and through the Local Plan meet or exceed this number. For Hastings, this requirement is currently (May 2025) 697 homes a year^[1]. This equates to a requirement for 12,546 net new homes over the lifetime of the Plan.

^[1]The annual housing need figure is subject to change on a yearly basis, and the Council will therefore monitor any updates to the standard method and its outputs as work on the plan progresses.

4.16The Framework provides two exceptions to meeting development needs in full. First, where protecting areas or assets of particular importance provides a strong reason for restricting the scale, type or distribution of housing development within an area. Second, where the adverse impacts of meeting needs in full would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework as a whole.

4.17The scale and distribution of housing growth in the Borough aims to promote a sustainable pattern of housing development. A key aim has been to focus housing development in the most suitable and sustainable and least sensitive areas of the Borough in order to conserve and enhance the town’s rich natural and historic environment. In this regard, the Sustainability Appraisal (SA) (ref), a process which provides an assessment of how different development options perform in environmental, social and economic terms, has informed the housing growth and spatial strategy set out in the Plan.

4.18The Strategic Housing and Employment Land Availability Assessment (SHELAA) is an up-to-date and on-going data source in relation to housing land supply potential. All suitable, available and deliverable sites are included within the Plan’s housing target in accordance with sustainable development objectives of the NPPF, between 2023 and 2041, the new housing target is 3,141 – 3,373 net new homes. This is inclusive of small site Windfall. Annualised, this equates to 175 - 187 net new homes per annum. This represents the baseline position in relation to housing delivery.

4.19The SHELAA also identifies sites that do not yet meet all three tests (suitable, available, achievable) that would allow them to be included within the supply of deliverable sites in the Plan period. We recognise the potential for a number of these sites to deliver within the period in light of partnership working to promote housing delivery. We have therefore set out a policy framework to guide future proposals in the event that the status of these sites changes during the Plan period. These are:

• Regeneration Area Opportunity Sites. Areas that include these sites are identified by the prefix R in section 5
• Development Potential. These sites are identified by the prefix D in section 5
• Housing Renewal Sites. These sites are identified by the prefix H6 in section 7.

4.20Policy HA1 of the Plan sets out proposed site allocations for housing development in accordance with Policy SP2. Every effort has been made to make as much use of previously developed or brownfield land as possible in an effort to meet housing needs. However, due to issues with viability, deliverability and limited supply, it has also been necessary to identify greenfield sites to help promote housing delivery within the Borough.

4.21In addition, Windfall development has made a significant contribution to housing delivery in the past. Evidence shows that small site Windfalls (less than 5 dwellings) will continue to come forward in all years of the Plan up to 2041. An average of 45 Windfall dwellings per year has been assumed between 2023/24 and 2040/41.

4.22The new homes will be delivered primarily through private development, but there will be considerable partnership working with Registered Providers (RPs) in the delivery of affordable housing. Table 1 below sets out how the sources of housing supply and how the target will be achieved. The table summarises the council’s housing land supply position as at end of March 2025.

Table 1: sources of new homes to 2041 Comment

4.23In addition to developing a housing target for the Plan, the NPPF states that ‘the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies’.

4.24The council’s Housing and Economic Development Needs Assessment (HEDNA) Update is our key evidence source in relation to housing needs over the Plan period. The HEDNA provides an in-depth information in respect of overall housing need together with the size, type and tenure of housing required to meet the needs of different groups of current and future residents. Whilst Policy SP2 covers the tenure and size of affordable housing, we do expect all new homes to be well-designed, have reasonable space standards and be adaptable or accessible. Therefore, Policies SC1 and SC2 respectively will also be relevant when considering the provision of affordable homes. This also applies to specialist housing, such as homes targeted at specific age groups which include care or support, covered under Policy H1.

4.25The level of need for Gypsy and Traveller accommodation in the Borough is set out within the latest Gypsy and Traveller Accommodation Assessment (GTAA). The council acknowledges that there is insufficient land identified through site allocations to meet this need, and therefore a proactive approach to ensuring sites are able to come forward during the plan period is required. In order to maximise land supply to meet traveller needs throughout the plan period, the council will require developers to investigate the potential for residential sites of sufficient size to accommodate permanent traveller pitches. Where a proposal is for self-build or custom housebuilding, is within an incompatible flood zone, or involves a change of use of an existing building, this policy requirement will not apply. The strategy for meeting the housing needs of Gypsies and Travellers is based on Windfall delivery. Policy H5 enables the council to determine planning applications for Gypsy and Traveller Windfall sites on a site-by-site basis, subject to individual circumstances and need.

Affordable Housing Comment

4.26Affordable housing is a national term defined in the Framework meaning housing available to those who are unable to access accommodation suitable for their families’ needs, at a price that they can reasonably afford on the open market, whether for rent or home ownership. It should be available at a cost low enough to be afforded by eligible households and is determined with regard to local incomes and house prices. In Hastings, affordable housing is essential because:

• Local house prices and rents are much higher than local incomes.
• Many households rely on benefits or low-paid work.
• The private rented sector is large but often expensive and insecure.
• There is strong demand for genuinely affordable homes.

4.27Affordable housing is delivered by the planning system through open market schemes working in tandem with affordable housing providers (registered providers (RPs)). In these circumstances affordable homes are secured either by a planning condition or a planning obligation. However, increasingly specialist affordable housing providers are delivering development sites entirely as affordable homes.

4.28There are a number of different types of affordable housing, including social and affordable rented housing, and affordable home ownership. In Hastings, social and affordable rented homes are typically provided by housing associations. Social Rents are set using a national formula and are typically around 50–60% of local market rents. These are the lowest cost rented homes. Affordable rented homes can be up to 80% of local market rents. However, in Hastings we have worked with key partners to cap rents at the Local Housing Allowance (LHA) rates— the maximum rent level that can be covered by Housing Benefit or Universal Credit. This ensures that people on lower incomes can realistically afford them. Affordable home ownership includes shared ownership, rent-to-buy and discounted market homes for example. These tenure options provide different routes into affordable housing, helping meet a range of needs from those requiring long-term rented homes to households looking to move towards ownership.

4.29The council’s Housing Strategy recognises that Affordable rent homes are not always affordable to everyone locally, which is why the council works with providers to cap rents at LHA rates. We will seek to prioritise social rented homes where we can, however if agreeing to affordable rent homes (capped at LHA) results in more affordable homes being developed on a site we will support this.

4.30The HEDNA Assessment follows the approach outlined in the Planning Practice Guidance (NPPG) to model net affordable housing needs, based on relative costs and incomes. It takes account of current unmet needs, newly arising needs and the current annual supply of affordable housing. As of February 2024, this translates into a net requirement for 432 affordable homes per annum over the Plan period.

Comment point Comment

4.31National guidance does not require planning authorities to meet the full extent of this need. For Hastings, meeting this need in full is not a realistic prospect in view of the constraints and difficulties in meeting housing requirements in general. The circumstances do, however, demonstrate the pressing need to secure as much affordable housing through the planning system as development viability will allow. The policy approach set out here supports and complements the council’s Housing Strategy which also includes council-led projects relating to the acquisition and return of empty homes back into residential use, or the conversion of other premises for residential use. All of these initiatives are part of the drive to increase the supply of affordable homes.

4.32The council must have regard to national planning policy which makes clear that the viability considerations of the policy requirement for affordable housing should be considered as a whole, with other policy requirements, such as infrastructure contributions. This is the job of the council’s Whole Plan Viability Assessment which has informed both the threshold and percentage requirement for affordable housing contained within our Policy. This work will be subject to further updating for the next iteration of the draft Plan. This will include the identification of a percentage requirement on sites yielding fewer than 10 homes.

4.33Homes England provides funding to help build new affordable homes. Current funding processes mean that it is often more viable for housing associations to deliver developments for 100% affordable housing rather than secure homes on a private development through the use of planning conditions or a planning obligation. Increasingly specialist affordable housing providers are delivering housing schemes which are entirely made up of a mix of affordable tenures. The council’s affordable housing policy supports this potential.

4.34Whilst the policy thresholds have also been designed to support the economic viability of development, a five-year review of the Plan, from the date of adoption, will reassess the affordable housing policy thresholds in the light of their effectiveness and taking account of market circumstances at that time.

4.35The Policy includes other measures intended to ensure affordable housing delivery is maximised. Regard will be had to a proposal site as a whole, to avoid it being subdivided or artificially developed in phases as a way of reducing the policy requirement for affordable housing. For Windfall sites, it will be assumed as a starting point that sites are capable of providing at least 45 dwellings per hectare. Developments of apartments are likely to be capable of providing significantly higher levels of dwellings per hectare.

4.36Where applicants seek to reduce affordable housing provision for viability reasons, they will be expected to submit a viability report as a basis for negotiation. The council will require independent verification of viability reports, and the costs associated with this will be recouped from the applicant. Where agreement has been reached during the planning application stage on providing less than the full on-site affordable requirement, any reduced affordable housing contributions will be subject to a review mechanism. Property markets do experience change at both the local and national level. The viability of a scheme may therefore be notably different by the time of implementation due to changes in market conditions; and uncertainties in relation to aspects of a viability assessment at the application stage. In considering viability matters, regard will be had to best practice, particularly as set out in NPPG.

4.37In order therefore, to ensure that the maximum reasonable level of affordable housing is provided in line with Policy SP2, and that other plan requirements are met, the council will require a viability review through planning condition/obligations on all residential / mixed use schemes which do not meet the affordable housing requirement and / or policy requirements in full at the time permission is granted. A viability review will determine whether a development is capable of providing additional affordable housing or meeting other unmet policy requirements.

Comment point Comment

4.38A key pillar of increasing housing affordability, supporting development viability, and supporting sustainable development is to ensure developers maximise opportunities to procure labour, skills and materials locally, either within Hastings or within the Functional Economic Market Area through Local labour and procurement agreements. Seeking local procurement opportunities for goods and services contributes to Sustainable Development Goal 12 ‘Ensure sustainable consumption and production patterns’.

4.39Development also provides an opportunity to resolve critical barriers to upskilling experienced by local working age people that serve to widen the affordability gap by limiting employment potential, including cost and access to opportunities. Through provision of a local skills development plan, developers or employers where the occupier is the developer can engage with existing initiatives or highlight the benefits of their own skills development programming. A completion statement outlining the key outcomes should be provided upon completion of the local skills development plan commitments.

4.40Where land in the council’s ownership is suitable for housing development, the council’s priority is to secure the building of 100% affordable housing. The council has an ambition to see 100% affordable housing delivered on greenfield housing sites. Our evidence to-date supports a minimum viable delivery of 40%. The Plan provides explicit encouragement to the provision of greater levels of affordable housing on sites. We will continue to monitor development viability and seek to increase this percentage requirement over the lifetime of the Plan. Any such changes will be made through a Local Plan review process.

Strategic Policy 2 (SP2): New and Affordable Housing  Comment

Strategic Policy 3 (SP3): Business Development – Office and Industrial Comment SIEA1 - Queensway Corridor (1) SIEA2 - Ivyhouse Lane (2) SIEA3 - Ponswood (3) SIEA4 - Bulverhythe Estate (4) SIEA5 - York Road (5)

4.41Hastings is the largest urban economic area within the Hastings and Rother Functional Economic Market Area and is home to a number of organisations that are of national and international renown including Kurt J Lesker, AKK BD Foods, Focus SB and Medica Group. It is part of a wider regional cluster of advanced manufacturing that is well positioned for accelerated growth during the plan period. By successfully supporting our growth industries, we will create a more vibrant economy, benefitting other sectors including the construction industry and service industries in turn.

4.42Access to well-paid and skilled employment opportunities is key to improving housing affordability, and ensuring that local people can access the jobs and training they need reduces the need for out-commuting and improves the sufficiency and sustainability of the town as a whole. A skilled workforce, employment land allocations and clear economic policies all contribute to making Hastings a desirable location for investment.

4.43The Hastings economy differs to the wider South East in that there is lower representation in professional services and office-based activities and more manufacturing, construction, tourism and healthcare. There is also a healthy logistics and freight sector that has grown in strength with a relatively short period. Across the Hastings and Rother Functional Economic Market Area (FEMA) the manufacturing sector is locally resilient and contains some long-standing and high performing companies in electronics and the creative industries sector (including design, web, gaming, arts, visual arts, performing arts). Vacancy rates in our industrial estates are low.

4.44Over the last few years there has been very limited ‘churn’ in the industrial premises market – while that means a degree of retention of existing business in the area, it also means there are limited opportunities for new or growing companies to locate in Hastings, without additional floorspace created. Recent analysis has indicated that there has been no significant new supply of industrial space in Hastings and requirements for larger industrial units are reportedly almost impossible to fulfil. Analysis has also indicated a backlog of need for smaller premises. The consequence of this undersupply of industrial space is that no units are available to provide ‘grown-on’ space in Borough for local companies looking to grow, and it resulting in missed opportunities to attract inward investment. This together with an existing ageing stock and essentially no vacancies are constraining the economic potential of Hastings.

4.45A local need for an additional 51,297sqm of employment floorspace and 4,150 new job opportunities to 2041 has been identified. New floorspace will support job creation and retention and provide start-up, grow-on and investment space for both existing and incoming employers, as well as mitigating market paralysis. New, modern premises may also have a role in attracting cleaner, greener industry. We need to support this with new investment in workforce skills training and ensuring we have the digital infrastructure in place to support demand.

4.46Meeting identified needs will be achieved in part through the development of existing allocations but also through the retention and redevelopment of our existing industrial stock. Our Strategic Industrial Employment Areas (SIEA), as illustrated in the key diagram (Figure 1), include the Queensway Corridor, comprising sites across Queensway, Castleham, Churchfields and Ridge West, and the established Ponswood and Ivyhouse Estates, which offer the most potential for new development and densification. This will benefit both Hastings and the wider FEMA. Local Development Orders, which can give permission for certain types of use without the need for planning permission, may be used to facilitate intensification in these areas.

4.47Sites at Bulverhythe and York Road also have an important economic role delivering waste management infrastructure, transport, distribution and warehousing. Roebuck industrial estate and a number of other dispersed business premises across the Borough also have an important role in terms of the space they provide for existing and potential new businesses. These areas are protected as Local Industrial Employment Areas (LIEA) where the potential for intensification is more limited, but their role in providing the workspaces Hastings needs moving forward into the plan period is acknowledged.

4.48With changing work and lifestyle patterns, home-based working will continue, and employees are seeking shorter commutes to the workplace and greater diversity and vibrancy of services in their immediate locality to capitalise on quality-of-life improvements and health and wellbeing benefits that reducing commute time can deliver- such as more access to leisure time or the ability to utilise active travel solutions. Ensuring that there is adequate workspace in the local area can help to facilitate this.

4.49The demand for office floorspace across East Sussex, in contrast to industrial space, is lower. However, the type of office most suitable for the needs of businesses moving forward has changed considerably. There is a growing demand in the local market for managed workspace/small office units for micro-businesses (fewer than 10 people). Space that can be used flexibly to accommodate small business or provide larger spaces for existing business to consolidate their offices would support business stability. Hastings Town Centre, with its existing role as an important sub-regional economic centre, continues to be the primary location for future office development. Smaller and more local scale office uses could perform a similar role in our smaller centres, such as St Leonards and other District Centres.

4.50In 2020 significant changes were made to planning law. This included extensions to ‘permitted development rights’ which allow conversions and change of use of certain employment premises without the need for full planning permission. A new ‘Commercial Business and Service’ planning use class has also been introduced. This allows changes of use, without any need for planning permission, within a wide range of uses including shops, restaurants and cafes, offices, gyms and childcare provision. Whilst the objectives here to enable a more flexible approach to support town centre recovery and to help promote the delivery of more housing are supported, we will continue to monitor the supply and demand for employment floorspace. We may revise our approach to managing change to office premises in central Hastings and the established industrial areas. This might extend to adopting tools that will require full planning permission for changes of use of office floorspace to residential development currently allowed under permitted development rights (through ‘Article 4 Directions’).

Strategic Policy 3 (SP3): Business Development – Office and Industrial  Comment SIEA1 - Queensway Corridor (1) SIEA2 - Ivyhouse Lane (2) SIEA3 - Ponswood (3) SIEA4 - Bulverhythe Estate (4) SIEA5 - York Road (5)

Strategic Policy 4 (SP4): Business Development – Town Centres Comment Hastings Town Centre (1) St Leonards District Centre (2) The Old Town District Centre (3) Silverhill District Centre (4) Bohemia and Tower Local Centre (5) Ore Village Local Centre (6) Battle Road Local Centre (7) Marine Court Local Centre (8) Bexhill Road Local Centre (9)

4.51The NPPF^[ii] and PPG^[iii] both place weight on the development of positive plan-led visions and strategies for town centres, and the promotion of new investment and development in town centres first, ahead of edge and out-of-centre locations. Policies need to define a network and hierarchy of town centres and promote their long-term vitality and viability^[iv]. Policies also need to define the extent of a centre’s Primary Shopping Areas (PSA) and the range of use that will be permitted within them^[v].

4.52The Borough’s network of town, district and local centres are a core part of the local economy. Some of the larger shopping areas provide a range of facilities, including shops and services which appeal to residents and visitors alike; educational, medical and lifestyle support; as well as cafes, bars and restaurants which contribute positively to the evening economy. Different uses during the day and in the evening can reinforce each other, increasing the attraction of our larger centres to local residents, shoppers, workers and visitors^[vi].

4.53Our network of centres also acts as focal points for communities and have an important role in meeting the needs of less mobile members of the community, assisting social inclusion. The ‘town centre first’ approach is important in helping to reduce the need for people to travel by car and helps promote a low carbon economy. This is recognised by the council’s ongoing commitment to regeneration and investment projects in Hastings Town Centre through Town’s Fund Programming^[vii]. Our shopping areas also have a key role in the provision of employment opportunities across a variety of sectors^[viii].

4.54The council’s strategy is therefore to continue to protect and enhance the retail and commercial role of the Borough’s Town, District and Local Centres and to support proposals which will add to their vibrancy, providing a range of compatible uses consistent with their role within the town centre hierarchy.

The Hierarchy – Hastings Town Centre Comment

4.55Hastings Town Centre is clearly at the top of the town centre hierarchy by virtue of its scale. It has an important role within the local economy and wider wellbeing of the Town. It is also the most accessible being served by all rail services and virtually all bus routes. Hastings Town Centre is a sub-regional centre, which means its catchment extends beyond the Borough boundary. The retail offer in the Town Centre is characterised by a mix of larger national and franchise retailers and smaller independent and specialist retailers.

4.56The Town Centre boundary and Primary Shopping Area (PSA) are both identified on the Policies Map. The PSA is focused on Priory Meadow Shopping Centre and the adjoining pedestrianised streets of Queens Road, Robertson Street, Wellington Place and further to the north along Queens Road as far as the Morrisons supermarket. This area contains national retailers, other shops and services, food and beverage, leisure and civic activities.

4.57Businesses in Queens Road have worked together to create a distinct brand for the area. The Queens Road Quarter reflects the numerous creative businesses that operate in the area, independent bars, cafes and shops work together to draw people up from the town’s main shopping area by promoting their unique offer.

4.58There are also important areas of specialist and independent businesses on Trinity Street, Claremont and the non-pedestrianised section of Robertson Street extending into White Rock. This is the Hastings Commons ‘Town to Sea’ quarter. The area including the Observer Building, has seen significant improvement and a Heritage Action Zone has seen increased investment in the area’s heritage assets. The area is also part of the America Ground, giving the area a unique identity that businesses and residents celebrate.

4.59There are a number of important pedestrian linkages to the seafront, and whilst the character of the town centre uses changes here, the seafront area from Hastings Pier to Pelham Crescent falls within the town centre boundary. The seafront itself and the promenade is a vital part of the Town’s visitor economy, as well as providing services to local residents. It will be important to ensure that where possible, future town centre development ensures the seafront and Town Centre are integrated and linked destinations, where new development is used to promote the ‘Healthy Streets’ approach to street and place design with the overarching aim of making streets healthy places for everyone.

4.60Within suitable locations in Hastings Town Centre, the continued encouragement of appropriate residential development at first floor level and above helps to maintain and enhance the vibrancy and vitality of the Centre.

4.61In recognition of the changing nature of retailing and new ways of working, Regeneration Area Policy (R1) Hastings Central, sets out a vision and strategy for targeted regeneration and development of Hastings Town Centre.

District Centres – St Leonards, The Old Town and Silverhill Comment St Leonards District Centre (1) The Old Town District Centre (2) Silverhill District Centre (3)

4.62District centres will usually comprise groups of shops often containing at least one supermarket or superstore, a range of non-retail services and food and beverage establishments, as well as local public facilities.

4.63St Leonards is the second largest centre in the hierarchy and is of a scale to warrant the need for both a town centre boundary and a primary shopping area. Both are defined on the Policies Map. It has its own distinctive character and includes a broad range of retailers both national and independent, other services, restaurants and cafes. Across the year there are street markets and festivals, utilising the nearby Warrior Square gardens. The PSA includes the whole of Kings Road, the lower part of London Road, and the eastern part of Norman Road. It is important that a vibrant and varied mix of town centre retail uses remain predominant in this area.

4.64The Old Town is a mix of retail and residential properties, with an eclectic mix of independent shops, cafes, bars, restaurants and leisure amenities that give the area its unique identity. The area is a focal point for some of the town’s cultural festivals such as ‘Jack in the Green’ and has a thriving nighttime economy all year round. Again, defined on the Policies map, the town centre boundary for The Old Town covers George Street and High Street, East Parade and Rock-a-Nore Road. George Street and High Street form the PSA.

4.65Though smaller in scale to St Leonards and The Old Town, Silverhill has a large-scale supermarket justifying its inclusion as district centre. In the case of Silverhill, the primary shopping area and the town centre boundary match.

4.66All three district centres are underpinned by an important retail function, and whilst some degree of flexibility can be applied to the range of uses which can be supported within these centres, it is vital to ensure that they continue to meet local residents’ essential day to day shopping needs and assist in promoting sustainable patterns of shopping in the borough.

Local Centres - Bohemia and Tower, Ore, Battle Road, Marine Court and Bexhill Road Comment Bohemia and Tower Local Centre (1) Ore Village Local Centre (2) Battle Road Local Centre (3) Marine Court Local Centre (4) Bexhill Road Local Centre (5)

4.67Local centres include a range of small shops of a local nature, serving a small catchment. Typically, local centres might include, amongst other shops, a small supermarket, a newsagent and a pharmacy. Other facilities could include a hot-food takeaway and launderette.

4.68These smaller centres are defined on the Policies Map. Owing to their size, these centres have a single boundary where the town centre boundary and the primary shopping centre are the same. Local centres can help to meet the needs of the local residents, particularly the less mobile and elderly as well as encouraging active or low carbon travel options for immediate local residents. Therefore, the Policy’s focus in these centres is to encourage convenient and accessible local shopping facilities to meet the day-to-day needs of residents and contribute to social inclusion.

Street trading and Markets Comment

4.69Other activities that take place in and around the identified shopping areas can help to add to the vitality and vibrancy of them. Markets can be a good way for businesses to develop or for customers to discover new things. They can also help foster community spirit and create an identity for an area. A licence for street trading is required for anyone wishing to run a market stall and this can be obtained, provided that information about the times of sale, the types of things for sale and proof of insurance are submitted to the council.

4.70The council will continue to encourage and support well managed covered and street markets such as those that have proved successful in Hastings Town Centre including St Andrews Mews and Queens Arcade, and also The Stade open space and hall, and Kings Road in St Leonards.

Sequential and Impact Tests Comment

4.71Maintaining and enhancing the vitality and viability of our Town Centres is dependent on ensuring that new investment is focussed within these centres in line with the ‘town centre first’ principle. This both aids their economic prosperity and ensures that new development takes place in the most sustainable locations, easily accessible by modes of travel other than the private car and convenient for visitors and residents alike.

4.72When considering proposals for main town centre developments, the council will apply the sequential and impact tests in accordance with national policy. This means that applicants will be expected to have demonstrably followed a sequential approach when selecting development sites for main town centre uses, including fully exploring how the scheme could be adapted so that it could be accommodated on a more central site. The NPPF defines main town centre uses as retail development (including warehouse clubs and factory outlet centres); leisure, entertainment and more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, nightclubs, casinos, health and fitness centres, indoor bowling centres and bingo halls); offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities) as retail, leisure and entertainment, intensive sport and recreation uses, offices, arts, culture, and tourism^[ix]. The NPPF further identifies town centres as the first choice of location for these uses^[x].

4.73The NPPF states that local planning authorities should request an impact assessment for main town centre uses outside of the town centre hierarchy if the scale of development is over a proportionate, locally set threshold. The NPPG provides guidance on the indicators which should be taken into account by local planning authorities seeking to identify local impact assessments. In relation to Hastings, we consider the following factors to be relevant:

• The scale of the existing centres in the retail hierarchy;
• The uses which are important to different centres in the hierarchy; and
• The health of the centres over time.

4.74In relation to the scale of proposals relative to ‘town centres’, the size of the centres in the Borough’s retail hierarchy varies quite considerably. Therefore, in ‘scale’ terms this would suggest that a very low threshold should be set reflecting the potential for stores proposed on the edge or outside of centres, (e.g. as part of petrol filling stations or the conversion of public house), to have a significant adverse impact on the trading performance, vitality and viability of district and local centres nearby. This will particularly be the case where these existing centres are dependent on smaller supermarkets and/or convenience stores to anchor their retail offer, and to generate footfall and linked trips and expenditure to the benefit of other shops, services and facilities.

4.75Other factors have also been considered, including cumulative impact issues. As a consequence, in the interests of seeking to protect the health of the smaller centres in the Borough, we consider that a low threshold for convenience retail proposals should be set at a gross figure of 300sq.m and for comparison retail, 200sq.m. These thresholds should apply to new stand-alone retail floorspace, proposed extensions to existing stores and applications to vary the range of goods to be sold from existing floorspace.

4.76Where a retail impact assessment is required, Appendix 3: Retail Impact Assessments sets out the information which should be submitted in support of planning proposals.

Strategic Policy 4 (SP4): Business Development – Town Centres. Comment Hastings Town Centre (1) St Leonards District Centre (2) The Old Town District Centre (3) Silverhill District Centre (4) Bohemia and Tower Local Centre (5) Ore Village Local Centre (6) Battle Road Local Centre (7) Marine Court Local Centre (8) Bexhill Road Local Centre (9)

Strategic Policy 5 (SP5): Meeting the Challenge of Climate Change Comment

4.77Addressing climate change is a statutory duty for local planning authorities under the Climate Change Act 2008^[xi] and Section 19(1A) of the Planning and Compulsory Purchase Act 2004^[xii]. It is also a central consideration within sustainable development.

4.78At the local level, the council has declared its recognition of global climate and biodiversity emergencies and its ambition to make work towards a carbon neutral borough ahead of the UK target of 2050. To this end, the council has adopted a Climate Change Strategy and Action Plan^[xiii]. The planning system has a key role to play in meeting the new challenge of reducing CO2 emissions to net zero.

4.79The Strategy and Action Plan acknowledge both the need to reduce carbon emissions, and also the need to mitigate and adapt to the effects of climate change we are already experiencing and will continue to experience in future, including hotter, drier summers, wetter winters, stronger winds, and the risks associated with flooding, drought, excessive heating and risk of loss of species and habitat.

4.80To support this goal, the council must set clear standards for how development proposals should be designed to deliver carbon neutral, well-designed places that are affordable to live, work and spend leisure time in. Policy SP5, together with the other policies of this plan, provides and overall framework for zero carbon development that fully mitigates and adapts to the effects of climate change both now and in the future.

Strategic Policy 5 (SP5): Meeting the Challenge of Climate Change Comment

Strategic Policy 6 (SP6): Renewable and Low Carbon Technologies Comment

4.81The council is committed through its Climate Change Strategy and Action Plan to work towards achieving a net zero borough ahead of the UK target of 2050 and has formally declared a climate emergency. Working towards providing a significant share of the town’s energy needs through decentralised, renewable energy has the potential to reduce the local use of energy derived from fossil fuels alongside national initiatives.

4.82Sites in Hastings have the potential to benefit from renewable energy generation due to the climate and topography. By maximising the potential for generating renewable energy onsite and storing it onsite, together with energy efficient design as set out in Strategic Policy SP5, the council considers that average annualised energy demands should be capable of being met within development sites.

4.83Policy SP6 provides a framework for the development of both current renewable energy generation measures and also provides for the possibility of suitable future innovations in energy generation when they become deliverable at the local level over the lifetime of the plan.

4.84The council is supportive of proposals that will deliver cleaner energy solutions at any scale, although consideration of any such proposals have to be considered alongside of any harmful impacts on the natural or built environment.

4.85In appropriate locations, the council will explore the use of Local Development Orders to simplify the planning process for Low and Zero Carbon technologies and set clear standards around size, scale and amenity.

4.86Low carbon heating solutions on a wider scale, such as neighbourhood or locality based, can provide an affordable, secure and green solution for occupants of serviced buildings. As this model removes market choice from occupants, such interventions must demonstrate that it represents energy affordability for occupiers and does not reduce the energy affordability benefits delivered through SP5.

Strategic Policy 6 (SP6): Renewable and Low Carbon Technologies Comment

Strategic Policy 7 (SP7): Protecting and Enhancing the Historic Environment Comment Archaeological Notification Areas (1) Conservation Areas (2) Historic Parks and Gardens (3) Scheduled Monuments (4)

4.87Hastings has a rich and varied historic environment. Architectural and historic interest exists in our buildings, townscapes, designed landscapes, and below ground. In all, there are 6 scheduled monuments, over 900 listed buildings, 18 conservation areas, 2 registered historic parks, numerous archaeological notification areas and other sites of archaeological and historic interest within the town. The many historic buildings and spaces combined with the town’s stunning topography delivers a uniquely attractive and high-quality historic townscape. The character of these historic areas contributes to a strong sense of place and contributes significantly to our distinctive and rich cultural heritage, which is highly valued.

4.88The town’s historic areas provide attractive living and working areas for the town’s residents and have the potential to draw in investors and new residents. The town’s rich history and built heritage contributes strongly to our tourism industry, which is an important sector of the local economy.

4.89The historic environment is vulnerable to loss and inappropriate change. It is critical that these special historic buildings and areas are protected, now and in the future. Active management of our historic environment will be required, as identified in the council’s Heritage Strategy and Action Plan, to ensure that its significance is protected, whilst not preventing sensitive change, to ensure that the historic environment remains an active and vibrant contributor to our town, enabling future generations the opportunity to experience and enjoy these special places. Over the lifetime of the plan, the council will work with partners to secure the long-term viability of historic buildings through their re-use, preservation, or sensitive restoration. This will include working with owners and forming partnerships with external funders to tackle historic buildings that have been identified as vulnerable on the national Heritage at Risk Register. Where resources allow, the council will also focus regeneration efforts on vulnerable high status heritage assets and those historic buildings that occupy prominent locations in the town.

4.90There is a presumption in favour of the conservation of heritage assets and their settings. The more important the asset, the greater the weight that will be given to the need to conserve it. As heritage assets are irreplaceable, any harm or loss will require clear and convincing justification. Keeping heritage assets in use is inherently sustainable as it reduces the consumption of building materials, energy and the generation of demolition and construction waste.

4.91Development which sustains and/or enhances the significance of heritage assets and/or their setting will be encouraged. Investment in the appropriate refurbishment or restoration of heritage assets, where works will preserve or enhance significance, will be encouraged and supported by the council.

4.92Not all locally important features of historic or architectural interest are listed buildings or part of a designated Conservation Area. However, they can still provide a valuable contribution to the local historic environment and can make an important contribution to creating a sense of place and local identity. This can include buildings, structures, and features, archaeological remains, and historic open spaces and the wider historic landscape or townscape, which are called non-designated heritage assets.

4.93In relation to archaeology, there are many areas of the Borough where there is high archaeological potential. Where the extent of the likely finds is unknown, great care needs to be taken to protect this archaeological resource through the planning process.

4.94The effect of a development on the significance of a non-designated heritage asset is a material consideration in the planning process. The weighting that can be given to the conservation of the heritage asset, within the assessment of the development proposals, will depend on the balance between the scale of harm or loss that will result from the development, and the significance of the asset.

Strategic Policy 7 (SP7): Protecting and Enhancing the Historic Environment Comment Archaeological Notification Areas (1) Conservation Areas (2) Historic Parks and Gardens (3) Scheduled Monuments (4)

Strategic Policy 8 (SP8): Conserving and Enhancing the Natural Environment Comment Ancient Woodland (1) Country Park (2) Countryside Park (3) Local Green Space (4) Local Nature Reserves (5) Local Wildlife Sites (6) National Landscape (7) Open Space (8) Private Open Space (9) Sites of Special Scientific Interest (SSSI) (10) Special Areas of Consideration (SAC) (11) Woodland (12)

4.95The borough of Hastings is rich in natural areas, diverse landscapes, and a magnificent coastline. The High Weald National Landscape (NL) follows the Borough's administrative boundary to the north and includes Hastings Country Park Nature Reserve at the east of the borough. At the western end of the borough is the Combe Valley Countryside Park^[xiv].

4.96Our designated wildlife sites include the internationally designated Hastings Cliffs Special Area of Conservation (SAC), 3 nationally designated Sites of Special Scientific Interest (SSSI) at Marline Valley, Combe Valley and Hastings Cliffs, 8 Local Nature Reserves (LNR), and 25 Local Wildlife Sites (LWS)^[xv].

4.97The world is witnessing a colossal decline in global biodiversity with one million animal and plant species threatened with extinction. Most terrestrial habitats are damaged, and the council’s Nature Emergency Action Plan (NEAP) demonstrates the council’s commitment to delivering a greener, more biodiverse future where nature recovery is seen as a priority.

4.98As well as statutory duties towards biodiversity, local authorities have a key role in developing a sense of place, enabling people to improve their health and wellbeing by using well managed natural green spaces to increase their physical activity and provide benefits to mental health.

4.99The Policy provides the strategic and high-level context for protecting the distinctive landscape and ecosystems of the borough. The Policy ensures the ecosystems and biodiversity of the borough are protected from harm, and where possible strengthened. The Policy aims to improve public access for all to nature and green and blue spaces to maximise health and wellbeing benefits.

4.100In line with national policy^[xvi] and legislation^[xvii], the council will improve our natural environment, reverse the decline in biodiversity, and leave our environment in a better state than we found it.

4.101In decision making, the council will have regard to the objectives of the Local Nature Recovery Strategy or its successor.

Strategic Policy 8 (SP8): Conserving and Enhancing the Natural Environment Comment Ancient Woodland (1) Country Park (2) Countryside Park (3) Local Green Space (4) Local Nature Reserves (5) Local Wildlife Sites (6) National Landscape (7) Open Space (8) Private Open Space (9) Sites of Special Scientific Interest (SSSI) (10) Special Areas of Consideration (SAC) (11) Woodland (12)

Strategic Policy 9 (SP9): Managing Coastal Erosion and Flood Risk Comment

4.102Hastings is vulnerable to various sources of flooding, with interaction of various mechanisms increasing the complexity of flood risk. The steep topography causes significant overland flow and risk of surface water flooding. This can occur in combination with high river flows, high tides and associated groundwater levels, restricting drainage. As the sewer system is largely combined, such issues can additionally contribute to sewer flood risk. Climate change is expected to further exacerbate flood risk in the Borough.

4.103In order to ensure that existing assets and dwellings are protected from increasing flood risk, appropriate flood defences and mitigations (both engineered and Natural Flood Management measures) will be supported. This includes measures to address surface water flooding, with areas particularly at-risk including Hastings Town Centre, Old Town, Hollington Stream and Warrior Square. For areas at risk from fluvial flooding, Natural Flood Management measures should be the preferred mitigation method unless it is not practical to do so.

4.104It is understood that due to this elevated overall vulnerability, a large portion of the borough will experience some flood risk from at least one source of flooding either now or within the lifetime of development proposals, including areas at risk of flooding as a result of coastal change. It is therefore understood that it may not be possible to avoid locations with some risk of flooding when identifying sites for development proposals. Policy SP7 seeks to direct development away from the highest risk areas (taking into account all sources of flooding and future projections of risk) and towards areas with the lowest possible flood risk for the development type.

4.105Where site allocations identified within this plan are at risk of flooding, the council will ensure that sites are sequentially tested in line with National Planning Policy and Practice Guidance, and that the exception test is applied where necessary. This will take place following the Regulation 18 consultation.

4.106Where an elevated flood risk from one or more sources is present, now or in the future, a sequential and exception test should be undertaken to ensure that all alternative locations with lower flood risk have been considered and demonstrate that the benefits of development in the proposed location will outweigh the risk. Appropriate mitigation and adaptation measures should also be proposed in order to manage risk and safeguard human health, both at the development location and downstream.

4.107As flood risk is dynamic, the risk levels may change during the lifetime of the plan and additional flood storage capacity may be required, the council together with the Lead Local Flood Authority (East Sussex County Council) will continue to review levels of risk on a regular basis and update guidance and technical advice accordingly. The flood storage capacity should be increased through extensions to existing and/or additional flood water storage ponds or other appropriate storage solutions, and these should be designed to provide enhancements to existing biodiversity and avoid impact on significant archaeological sites.

4.108As a coastal borough, Hastings has approximately 12km of coastline, 5km of which is a developed frontage protected by sea walls and groynes which help to retain the shingle beaches. The Hastings coastline is experiencing the effects of coastal change, which have been accelerated in recent years due to the wider impacts of climate change including sea level rise and extreme weather effects. A coastal change management area allows the council to better protect our existing and future economic and heritage assets from coastal change, protect human health and the marine environment.

Strategic Policy 9 (SP9): Managing Coastal Erosion and Flood Risk Comment

Strategic Policy 10 (SP10): Transport Infrastructure Comment

4.109A relatively low level of transport connectivity is a key issue for Hastings. Located on the periphery of the South East, Hastings has limited strategic transport infrastructure linking the Town to larger centres of population. This is combined with local accessibility issues which can hamper access to jobs, services and negatively impact on health and wellbeing. The transport strategy is to support capacity and safety improvements on strategic rail and road routes but with an increasing emphasis over the lifetime of the Plan to move Hastings towards a more sustainable transport future locally.

4.110To tackle these issues, the council will work proactively with transport providers including Network Rail, National Highways, East Sussex County Council and bus providers to bring forward a greater level of high-quality transport infrastructure forward.

4.111In addition, we know that places that provide opportunities for people to lead physically active lives can positively impact people’s physical and mental wellbeing. One of the simplest ways of exercising daily is getting around by active means. ‘Active travel’ such as walking, wheeling or cycling to or from work, school, a nearby bus stop or train station, or shopping area can go a huge way towards meeting daily physical activity needs as well as contributing to better air quality.

4.112The council is therefore supportive of those measures which aim to shift the focus from delivering highway improvement to providing the infrastructure which supports more walking, wheeling, cycling and passenger transport provision. This approach is referred to as ‘decide and provide’ and focusses on planning for ‘people and places’. This is in alignment with the County Council’s transport strategy Local Transport Plan (LTP4)^[xviii]’ and the East Sussex Local Cycling and Walking Infrastructure Plan (LCWIP)^[xix].

4.113In terms of the public rights of way network, in line with the NPPF, where possible, opportunities to provide better facilities for users, for example by providing links to existing rights of way networks, including national trails will be provided. In Hastings, this will also include the King Charles III England Coast Path National Trail^[xx], which is due to be in place during 2024/25.

4.114Car parks across the Town are used by visitors, shoppers, commuters and businesses. There is a mix of off-road car parks, on-street parking, restricted parking zones, and spaces for people with disabilities. Whilst efforts will be made to reduce demand for parking by promoting rail, bus and bicycle travel, coach parking and drop off points will be maintained in view of the more sustainable contribution they make to the visitor economy.

4.115With regard to the public availability of electric vehicle charging points, East Sussex County Council, as Highway Authority, is developing a strategic approach which will support the increased take-up of electric vehicles in East Sussex^[xxi].

4.116Contributions to improvements to transport infrastructure which may arise from new development are set out Policy ID1: Planning Obligations (Section 106), and site allocation policies.

Strategic Policy 10 (SP10): Transport Infrastructure Comment

Strategic Policy 11 (SP11): Healthy and Safe Communities Comment

4.117Health and wellbeing is a wide-ranging topic which cuts across many policy areas within this Local Plan. The World Health Organisation’s definition of health as ‘complete wellbeing’ may no longer be fit for purpose. Instead, health experts propose changing the emphasis towards ‘the ability to adapt and self-manage in the face of social, physical, and emotional challenges’.

4.118Health inequalities and deprived neighbourhoods are found across the country; however, coastal communities are often disproportionately affected, as is the case in Hastings. Hastings performs poorly against almost all indicators of health – both in terms of physical health and against the wider determinants.

4.119Just as health considerations are referenced throughout the NPPF, the Local Plan takes health and wellbeing to the heart of all policies. Applications for development in accordance with the Local Plan will be required to address physical, mental, social, community and economic health needs in order to deliver a policy compliant scheme.

4.120Policies in Parts 5 and 6 of the plan identify broad areas and individual sites that can contribute to the housing and employment needs of the borough, together with areas which should be protected and enhanced for sporting, recreational and cultural purposes, providing places to live, work, and learn and to facilitate the wellbeing and fulfilment of everyone in the borough. Policies in Part 7 of the plan set requirements for new development to provide:

• Decent, adaptable, energy efficient and affordable homes that are well connected to services and green spaces;

• High-quality, energy efficient and well-located modern workplaces that are likewise well connected;

• Improved play spaces, sports facilities, playing pitches and open spaces;

• Increased opportunities for active, green and multimodal travel;

• Safe communities free from crime, hazard and nuisance including the effects of flooding and landslide;

• Opportunities for community-led development, such as self-building and enhancements to community facilities;

• Enhancements to biodiversity, habitats and green and blue infrastructure;

• Maintains the network of walkable accessible shops and services in the community at town, district, local and neighbourhood levels.

4.121To support this approach, the council will require a Health Impact Assessment (HIA) screening for certain developments and an in-depth HIA to be undertaken where the screening process identifies potential for significant impacts on health and wellbeing.

4.122A Health Impact Assessment (HIA) assesses potential effects of a development proposal on the health of a population. The HIA recommends measures to maximise positive impacts, minimise negative impacts and reduce health inequalities. As a tool, it supports the planning system to address local health and wellbeing needs and tackle inequalities through influencing the wider determinants of health.

4.123Screening is a preliminary assessment to identify what health impacts may arise from a development proposal and whether the proposal would benefit from further assessment. To support this approach, the council will require a Health Impact Assessment (HIA) screening for certain developments and an HIA to be undertaken where the screening process identifies potential for significant impacts on health and wellbeing. If an HIA is required the scope and type of the HIA will vary depending on the size and type of the development, and its location.

4.124Further information on the application of HIA, together with template documents, is set out within the East Sussex HIA Guidance.

4.125In order to maximise the benefits of HIA, developers should undertake HIA screening at the earliest possible stage of the planning application preparation, before a design proposal is fully worked up. This ensures that applicants can seek to avoid any negative impacts of a development scheme whilst maximising positive effects on health and wellbeing and reduces the likelihood that additional work will be needed following submission of the application.

Strategic Policy 11 (SP11): Healthy and Safe Communities Comment

References Comment