Preferred Approach 1: Location of New Housing

Object

Representation ID: 1272

Received: 08/07/2008

SMPCT consider that while the principle of directing the majority (80%) of new housing within the built up area, thus meeting objective 4, is sound the fact that the Strategic Housing Land Availability Assessment (SHLAA) has yet to be completed means that it is not clear where and how this housing will be delivered.

The issue of delivery is further questioned given the low completion rates of previous years (85% of the target over the last 7 years (2000-07) chart 10, 2006-07 AMR) and timescales of the major release of the major greenfield site at Breadsell Lane (expected 2021-26). The fact that significant infrastructure and cooperation of a neighbouring authority will be required in order to be bring forward this site means that there are significant obstacles that are likely to prevent this site coming forward for redevelopment earlier should delivery fall more than 15% below the annual target.
SMPCT consider that in the light of the above the Council should, through the SHLAA, identify the maximum number of residential units, taking account design considerations, that can be accommodated within the existing built up area especially as the Council recognises that the re-use of previously developed land is vital to the physical regeneration of the town.

SMPCT reserve the right to comment further on the preferred approach of the Core Strategy process once the SHLAA has been published.

Object

Representation ID: 1303

Received: 08/07/2008

An annual dwelling increase of 210 dwellings is inadequate to meet anticipated housing requirements, to achieve the intended transformation of Hastings & to provide satisfactory housing choice. Annual completions should increase to 400 dwellings for the whole 20 year period

Object

Representation ID: 1304

Received: 08/07/2008

Of the 4 options presented (para 7.7) option 4 should be pursued on the basis that this will provide the greatest opportunity to achive housing delivery in the short & medium term. the final housing numbers in the SE Plan (para 7.11) are likely to require a higher requirement than the option selected at Preferred Approach 1.

Object

Representation ID: 1305

Received: 08/07/2008

The potential timescale for the greenfield development site at Breadsell Lane needs to be flexible & not restricted to the period 2021-2026 (para 7.15), particularly as it is likely to be phased over a number of years.
Not withstanding the above, the trigger for release of site should be if housing delivery fails to meet the annual target on any 3 occasions after 2006 (para 7.16)

Support

Representation ID: 1310

Received: 08/07/2008

Support for the location of new housing at Breadsell Lane

Object

Representation ID: 1313

Received: 14/07/2008

Most of PA1 seems to refer to 'greenfield development'. We think that 'brownfield' development should be prioritised ahead of 'greenfield' development largely in line with PA 2/3/10/11/12/13. This would most likely generate less traffic because of the presence of alternatives to the car, actual and potential.

Object

Representation ID: 1316

Received: 14/07/2008

The Breadsell Lane site should be at the very least be 'placed on hold' and reviewed. (See comments on PA27 - Skills and Training).

Support

Representation ID: 1354

Received: 08/07/2008

Hastings cannot accommodate its housing requirements entirely on brownfield sites, as such it is prudent to utilise some Greenfield sites. It seems advantageous to concentrate Greenfield development within one area. The Preferred Option 3 & allocation of Land at Breadsell Lane is strongly supported as release of land for housing here would ensure other areas of the Borough situated within the High Weald AONB (where much land in the South East of Hastings lies) remains protected. It would also enable the delivery of the shared vision for Hastings & Bexhill due to its location. Concentrating Greenfield development in the one area may also allow greater levels of energy efficiency to be achieved & will enable a more harmonious form of deevelopment as well as delivering other key objectives such as sustainable transport, provision of a network of green spaces & community facilities. Out client's land within Rother District Council could help deliver this shared vision & enable such benefits to be brought to the area.

Comment

Representation ID: 1373

Received: 08/07/2008

The council does not build houses so it is not within its gift to say to ESCC or central government that 4200 homes will be built. It is within HBC gift to say they will build to an excellent standard regardless of the size of development to a holistic plan for the town & not to the poor get rich standard of some developers. If there is a minimum standard this must apply across the piece & not be dropped due to perseverance of applications. Standards are standards eg. ten metres is still ten metres be that measured in millimetres of centimetres.
Little or none of this is within your gift as you are at the mercy of developers & business; therefore the triggers that are put in place have to work in our favour & not theirs.

Comment

Representation ID: 1388

Received: 08/07/2008

When was the consultation on the location of sites for the next 15 years done or was it a quiet exercise carried out in April 2008 without is appears widespread public consultation. Will there be consultation on 'location of individual housing sites (will be the) subject of a site allocations development plan document'

Comment

Representation ID: 1392

Received: 08/07/2008

I expect the HOME BUILDERS FEDERATION did support the release of a greenfield site as it means they would more profit from a site like this than redeveloping urban sites.
Just because they are not allowed to count the re-use of empty buildings for housing in the housing provision does not mean they should be ignored or pulled down. Rather this rule should be challenged & changed to insure the protection of the townscape.

Comment

Representation ID: 1423

Received: 08/07/2008

Maps need to be provided showing details of employment & housing land with respect to designated sites & landscapes. this should include international, national & locally important sites.

Object

Representation ID: 1426

Received: 08/07/2008

The proposed site for contingency housing appears to be north of land adjacent to Marline Valley Woods SSSI. Natural England is minded to object to this site as an allocation for development. This is due to potential adverse impacts on the SSSI as detailed in comments on Preferred Approach 1: Location of New Housing.
The map provided within the document appears to include part of the SSSI within the development area & is not consistent with the identification of the area shown within the summary leaflet.
Assessing impacts on a SSSI is a fundamental requirement when assessing such allocations & Natural England advises that boundaries of statutory protected sites are incorporated into such maps. PPS9 is clear that SSSIs should be given a high degree of protection under the planning system & planning authorities should seek to ensure that policies are in place to protect & enhance nationally important habitats into the future.
The site as illustrated on the map, also appears to include areas of ancient woodland.

Object

Representation ID: 1433

Received: 08/07/2008

The possible allocation of a greenfield site at Breadsell Lane to accommodate 1000 new homes raises concern. The site is adjacent to Marline Valley SSSI & on the boundary of the High Weald AONB.
Full consideration should be given when assessing the site suitablity to the impacts of these highly valued designated sites taking into consideration other potentially damaging plans or projects. (In this case, this should include the proposals for the Hastings to Bexhill link road, the enviro-enterprise corridor along Queensway & the proposal for development at Wilting.
Paragraph 8 of PPS9 is clear, planning permission should not normally be granted on land within or outside of an SSSI if it is likely to have an adverse effect (either alone or in combination with other developments)
Natural england is highly concerned about the nature & location of this option & we would be minded to object to any future application to develop this area. Any application for housing has the potential to adversely effect the SSSI -
*Hydrological impact - impacts of the quality & quantity of water feeding into gill streams within the woodland. These support nationally important bryophyte assemblages within the SSSI.
*increased visitor disturbance
*Fragmentation of the SSSI - severing biodiversity links to the wider environment, isolating genetic reserves of flora & fauna.

Comment

Representation ID: 1460

Received: 08/07/2008

It should be noted that all the preferred approaches could involve locations that may require waste treatment provision which could impinge on the capacity of the sites to deliver the scale of provision indicated in the Preferred Options document. The County Council as Waste Planning Authority is happy to discuss this issue as the Core Strategy is developed.

Support

Representation ID: 1461

Received: 08/07/2008

The intention to provide sufficient housing to meet at least the SE Plan requirement is strongly supported.

Comment

Representation ID: 1462

Received: 08/07/2008

It is recognised that Hastings has little choice of greenfield development opportunities & is heavily reliant upon urban intensification. However, it is unclear how different, if at all, the estimated yield from urban sites is between the options. For example, if the yield from urban sites could be increased a litte, might the rejected option 2 provide sufficient housing to meet comfortably the SE Plan requirement without having to resort to releasing to Breadsell? Thus, it is not clear whether or how far the Core Strategy needs to rely on Breadsell.

Support

Representation ID: 1463

Received: 08/07/2008

If Breadsell has to be developed, the County Council would support, in principle, its comprehensive development as a multi-use scheme together with the necessary infrastructure.

Object

Representation ID: 1464

Received: 08/07/2008

There appears to be no evidence that it has been subject to a landscape appraisal alongside other greenfield options in Hastings & it could have an adverse impact on the wider landscape in Rother District & the nearby SSSI.
Its delivery cannot be assured until key transport links & access from Rother are provided, none of which is in the control of the Core Strategy. There is, therefore, an element of risk that may require a contingency proposal, should any of those transport schemes fail.
It is not clear how far at this stage the strategy really needs Breadsell. If monitoring indicates that windfall completions are coming forward in significant numbers & the potential yield form other urban sites is maintained, then Breadsell may not be needed to meet current SE PLan provisions by 2026.
There are judgements to be made about the balance of risks & deliverability of the strategy.

Comment

Representation ID: 1465

Received: 08/07/2008

If Breadsell is pursued & needs to be brought forward before 2021, then a new primary school maybe required earlier than PA1 suggests. If Breadsell is included in the final version of the Core Strategy, then the County Council would wish to play its part in the preparation of the Supplementary Planning Document that the Borough Council intends to produce.

Comment

Representation ID: 1466

Received: 08/07/2008

The needs for waste reduction & waste recycling & treatment facilities should be recognised in any major greenfield site releases, such as the Breadsell proposal.

Object

Representation ID: 1522

Received: 08/07/2008

7.2 There is no need to accommodate 20% more than housing indicated in the South East Plan. This is contrary to ESCC predictions etc.for population.
7.5 The figures of 4200 dwellings should include the 1520 windfall figures. The Government shoud be pressed to include windfall housing in the overall figures & also to include Empty Homes brought back into uses. I am against the development of the major Greenfield site at Breadsell Lane

Object

Representation ID: 1578

Received: 07/07/2008

We are particularly disappointed to see such a lack of vision & imagination in the proposals for housing growth. The reference in para 7.10 is incorrect as options 3 & 4 adopt only part of one aspect of the Country Avenue concept. The Country Avenue aimed to provide compact integrated mixed live/work communities linked to existing infrastructure, primarily along the Ridge. This is to be applauded & should be included in the core strategy. The Country Avenue also included a new sustainable live/work community at Wilting Farm - linked to existing road infrastructure & a new station that would also serve existing isolated communities. The Breadsell Lane proposal is nothing like this & lacks fundamental elements of sustainability. Like former GLC expansion in 1970/80s, it could well lead to creation of isolated dysfunctional suburban sprawl.

Comment

Representation ID: 1608

Received: 07/07/2008

PPS12 para 4.1 & 4.5 identify that a key role of Core Strategies is to set out when elements of the strategy will be delivered. Some elements of the strategy are clear about when change will take place (for example educational developments), however this should be strengthened at submission to ensure that it is clear when different elements of other types of development will take place. We would expect to see a housing trajectory included in order to demonstrate the phased delivery of the housing allocation against which monitoring can take place & in particular that there is a 5 yr, 10 yr & 15 yr supply of land.

Object

Representation ID: 1643

Received: 08/07/2008

Option one should be accepted and ESCC quote rejected as unsustainable. The population projection states that the population will decrease therefore fewer homes will be required. "if sites do not come forward at the expected rate" the green field site will be released to wrong. Developers will hold onto harder to develop brownfield sites to add the release of the green field sites which yield greater profit hem. All brownfield sites need to have been used before green field is released. The council have no control over the rate of development. This is dependant on he developers profit margin which is dependant on house prices, land prices, inflation etc. 7.16 this strategy gives all the power to the developers and none to HBC, who would be at their mercy. Change to option one and inform ESCC Hastings does not have any further space to expand.

Comment

Representation ID: 1673

Received: 03/07/2008

Para 6.29 - whilst it is recognised that in practice the Borough's 5 and 25 year housing land supply will comprise a mix of urban and greenfield sites, it is felt that the NW Hastings major allocation should be central to this, given its key role in the LDF strategy. There are strong benefits to be gained by taking a comprehensive approach to new development.

Object

Representation ID: 1687

Received: 07/07/2008

We are concerned at the failure to support any of the visionary planning ideas contained in the excellent MBM Masterplan produced at vast public expense by one of Europe's greatest masterplanners. We feel that, at least, the Sea Avenue and the Country Avenue should be included in the core strategy as a option for developing sustainable integrated small scale mixed-use communities linked to existing transport and community infrastructure. So much innovative thinking should not go to waste.

Object

Representation ID: 1688

Received: 07/07/2008

By contrast, the Breadsell Lane proposal repeats the mistakes of GLC expansion in late 1970's by creating an isolated edge of town unsustainable community wholly at odds with current planning policy. It places many families at risk of a dysfunctional future. The proposed development here will also destroy beautiful countryside within easy access of Hastings as well as the green corridor which provides a buffer between Town and Village

Object

Representation ID: 1710

Received: 08/07/2008

Presently, it is not acceptable that failing to meet house build targets is the sole critical factor to release green belt land. It is conceivable that there are vested interests which would prefer early release & that these interests may have too much direct influence on trigger. This risks unserviced dwelling expansion which could be a repeat of the built environment influences which created concentrated deprivation in the past.

Object

Representation ID: 1728

Received: 07/07/2008

Presently, it is not acceptable that failing to meet house build targets is the sole critical factor to release green belt land. It is conceivable that there are vested interests which would prefer early release and that these interests may have too much direct influence on the trigger. This risks unserviced dwelling expansion which could be a repeat of the built environment influences which created concentrated deprivation in the past.