4.3

4.30 Hastings Local Plan The Hastings Planning Strategy Proposed Submission Version 25th May - 17th August 2012, does not 'set out a clear economic vision and strategy for the area which positively and proactivey encourages sustainable economic growth.

There was no consultation - they were introduced in Core Strategy Informal Consultation June -August 2011 with the note 'the boundaries are not part of the consultation' [Spatial Strategy, p20]. This attitude is reflected in the current DMP focused consultation, para 1.8 'These aim to give a vision and context to how we want neighbourhoods to develop'.

The published DMP Consultation in Feb- April 2012 merely asked for comments on site allocations within the Planning Focus Areas. I am informed by the Planning Department that at two meetings relating to that consultation residents were invited to make comments about the actual focus areas, but since this invitation was never published in any way, no response button was available on the on-line consultation document, and this information travelled no further than the three dozen or so attendees across the two meetings, it remains the case that the level of consultation on this issue falls below that required by the HBC Statement of Community Involvement [Update September 2011]:

Information-giving:
3.3 This means that we will provide our communities and interested parties with balanced and objective information to assist them in understanding the problem, alternatives or solutions. This will also include giving feedback on progress and outcomes. Information will be available, upon request, in a variety of accessible formats including electronically, large print, in Braille, on tape and in languages other than English.
Seeking views:
3.4 We will get public feedback on analysis, alternatives and decisions. We will consult with communities, interested parties and service providers and they will be given the opportunity to make representations on formal proposals.
Participation:
3.5 We will work directly with people throughout the process to ensure that public and private concerns are consistently understood, that they contribute to and influence the range of options which are to be considered. This will include contributing ideas and actively engaging in developing options and proposals.
3.6 We confirm that community involvement will be central to the production, use and
review of the full range of Local Development Documents included in the Local
Development Framework.

When I objected to both the lack of consultation and the boundaries in 2011, this was the answer:-
The planning focus area boundaries are not arbitrary - they are based on the nationally set boundaries of Super Output Areas (SOA) along with a recognition of local geography and communities. The boundaries have been carefully drawn so that comparisons can be made with previous figures and SOA statistics can be used for these areas to give consistency.

In fact, they diverge from SOA boundaries in at least 10 locations rendering them statistically unreliable, and cut across Conservation Areas. Conversely, in places they follow SOA boundaries slavishly although as computer-generated statistical tools these split established neighbourhoods.

There is no credible evidence base - no facts are offered to support choices, only subjective assessments based on a wide variety of criteria, They were so 'carefully drawn' that between August 2011 and February 2012, a large part of Focus Area 7 was relocated to Area 5.

Their function is unclear. It would seem that they may have been created to meet with NPPF 58:

'Local and neighbourhood plans should develop robust and comprehensive policies that set out the quality of development that will be expected for the area. Such policies should be based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics.'

At first glance, they appear to summarize area characteristics adequately, but a closer reading shows up a lack of understanding, inaccuracies and superficialities. I have detailed these for my areas [6 and 7] in my response to the current DMP focused consultation. Whether or not they have chosen to make representations, residents of other areas in the town have expressed similar reservations about the accuracy and usefulness of the portraits, and do not consider that the areas constitute neighbourhoods.

The artificial nature of the conflations is exemplified in para 5.25 [Spatial Areas: Central Area]:

5.25 Each area has its own unique identity, ranging from the active Town Centre with over 500 retail units and predominantly privately owned or private rented housing, to the expansive Alexandra Park, surrounded by large Victorian properties. Silverhill provides local shops and small businesses that are popular with local residents, as well as an Asda supermarket, whilst St Helens is predominantly residential, with a high proportion of privately owned properties.'

This paragraph, apparently discussing four of the six component Focus Areas, is in fact mentioning only three - it ascribes a 'unique identity' to both Alexandra Park, and to Silverhill - which are the titular components of Focus Area 5.

This shows that even the planners have found the areas are far too large to be effective in their stated aim of providing 'a more local perspective and sense of place' [Planning Strategy Proposed Submission Version para 4.3]. What relationship does Farley Bank have with the north east edge of Ore, over the hill and on the way out to Rye? Or Silverhill have with Laton Road and the Blacklands Conservation Area on the other side of the park? Or indeed with Horntye Park, which was moved into the same area, despite being integral to Bohemia? Where a Focus Area covers several Conservation areas, each designated for its distinctiveness, how can the Area provide a 'sense of place? What weight would these portraits and visions have against conservation area policies?

The DMP at para 2.1 says that their purpose is to inform the eventual policies of the DMP, which is very worrying. The definitive 'want' is used several times throughout the 'vision' pieces for the areas - this should be altered to reflect the nature of a vision - 'envisage' might be a better word.

In fact, in saying in the DMP para 1.8 'These aim to give a vision and context to how we want neighbourhoods to develop', the planners are being prescriptive and pre-empting local involvement in neighbourhood plans, contrary to the intention of the Localism Act.