Policy FA5: Strategic Policy for Eastern Area

The Hillcrest and Ore valley (Focus Area 11 or FA11)identifies a range of 440-540 dwellings. Potential allocations for FA11 in the Development Management Plan (DMP) consultation document includes 10 sites comprising 358 dwellings to be allocated (comprising allocated Local Plan sites, extant permissions and 2 sites have no planning status). In addition, the DMP identifies a further 3 sites comprising a total of 102 dwellings as under construction. This figure of 460 is within the range stated in Policy FA5.

It is essential that the policy is flexible to ensure sufficient sites are identified over the plan period to provide adequate housing supply, particularly as some of the proposed allocation sites may not be delivered. The land at Rock Lane is capable of being delivered within five years, has a willing landowner, and the site is relatively unconstrained with the exception of its designation within the AONB for which the impacts of development can be mitigated through enhancement of the AONB. The potential allocation of a nearby site at Winchelsea Lane in the AONB through the focused consultation of the DMP is indicative that the settlement boundary is capable of being amended through appropriate development. The inclusion of the site at Rock Lane for development (approx. 30 dwellings) would be consistent with the range specified at Table 5 of Policy FA5.

Policy FA5(a) and paragraph 5.56 specifically refer to our client's land at Rock Lane (consistent with Objective 5h), which states HBC has adopted a joined up approach with Rother District Council (RDC) for development of the land in association with securing environmental and access improvements to the AONB. This policy confirms HBC accepts the principle for development of land west of Rock Lane, albeit only within the adminstrative area of Rother. This land is currently under the private ownership of our client and therefore, to achieve environmental and access improvements to the AONB will require development to unlock the site, subject to development viability. Without development being permitted on part of the site there is no incentive for the landowner to provide the desired improvements on his land.

HBC's current approach fails the tests of soundness because the achievement of Policy FA5(a) is reliant on Rother securing development on land within their administrative area and the associated improvements from our client's land. There can be no obligation on the landowner to deliver improvements on land within Hastings where no development is proposed. The current approach by HBC misses the opportunity to apply a joined up approach to facilitate development within both Rother and Hastings administrative areas and associated improvements. HBC should adopt a positive approach to facilitate development and improvements on land within their boundary to apply a genuine joined up approach with Rother and comply with the duty to co-operate.

Securing an appropriate amount of development along the frontage of Rock Lane would be consistent with the potential development on my client's land to the north within the administrative boundary of Rother and the existing ribbon of development further to the north beyond. Achieving an appropriate and modest extension to the settlement boundary would provide the opportunity to enhance and access the remaining 2+ha of undeveloped land to the west for public benefit. Achievement of this policy will require positive discussions with both Authorities, the landowner and/or a developer subject to development viability.

There are currently no rights of way into the AONB in the immediate locality. The release of some land for residential development could potentially deliver wider benefits to the public to make the AONB accessible in this location and meet HBC's Objectives and Policies. Furthermore, it would also address National Planning Policy Framework paras 115 and 116, as development would be in the public interest due to the potential improvements to the AONB, there is a need for housing development in the Borough and this site is a suitable location for development given its adjacency to the settlement boundary and it is possible to moderate the impacts of development with the potential for improvements.

Policies SC1 and EN4 are relevant in respect of this representation.

Rother District Council (RDC) support the inclusion of adopting a joined up approach with RDC to the use and management of land between Ivyhouse Lane and Rock Lane, to secure improvements in association with development in the locality. This approach is in line with Policy HF1: The Hastings Fringes, in the Rother District Council Proposed Submission Core Strategy (incorporating focused amendments).

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