We object to the exclusion of land at Breadsell Lane as a housing allocation.

The Core Strategy 'Preferred Approaches' Document (2008) identified Mr Simmons' land at Breadsell Lane as part of a major Greenfield site that had genuine prospects to provide new dwellings during the Local Plan period. Within this Preferred Approaches Consultation Document there was an unambiguous acknowledgement by the Council that a development of this land would provide the very best opportunities for providing essential infrastructure, such as improved transport, community and recreational facilities. It was also acknowledged that a large site would provide opportunities for higher standards of sustainable design and construction, which would assist in combating climate change during the plan period.

However, as a result of a Natural England objection, the Council abandoned its stance, deleted Breadsell Lane as a potential allocation and reduced the overall housing provision to compensate for the loss. We maintain our view that the removal of the site due to Natural England's objection has not been justified in evidence. Neither has a balancing exercise been undertaken to compare the undoubted benefits of a new residential development against the unknown risk facing the bryophyte population. This renders the emerging DPD 'unjustified' and therefore unsound.

It should also be noted that a significant number of the proposed allocation sites are subject to a caveat that Natural England's approval is required. It is therefore unclear why our client's site is being considered in an inconsistent manner and has been dismissed based solely on a need for future baseline hydrological information.

Land at Breadsell Lane is the only large greenfield opportunity that is not located within a protected Area of Outstanding Natural Beauty. In this respect, paragraph 110 of the NPPF is clear that in preparing to meet development needs, plans should allocate land with the least environmental or amenity value. The prudent use of land at Breadsell Lane will be consistent with this aspect of the NPPF and will reduce the pressure to develop smaller urban sites that offer more to the local community. This matter is not in dispute, as documented by the fact that the site was well supported by the Council prior to the objection from Natural England.

In conclusion, we consider that the Council's decision to exclude land at Breadsell Lane from the Site Allocations DPD without robust evidence has rendered the Plan unsound, as it no longer follows the most appropriate approach when compared with the reasonable alternative of a large Greenfield allocation.

This, along with further failures in respect of not addressing the objectively assessed housing need for the area, and a non robust housing land supply (see supporting representations), results in a strategy that is neither positively prepared or in accordance with National planning policy.

Notwithstanding the above, we consider that the plan could be made sound through the reintroduction of land at Breadsell Lane as a housing allocation, or at the very least as a future reserve site. The inclusion of such an allocation will provide flexibility and ensure that the DPD is effective.

An indicative masterplan has previously been produced to provide an indication of the broad level of development that could be accommodated Mr Simmons' land. A copy of this masterplan is included as an attachment. In order to provide a reasonable mix of dwelling types and tenures, we consider that the land could accommodate up to 450 units within Hastings Borough and provide access to further land immediately south over the longer term. Notwithstanding this capacity assessment, the number of dwellings could be phased over a much longer period, for instance with approximately 100 to 150 new units coming forward on the northern part of the site during this current plan period.