2.1

Showing comments and forms 1 to 4 of 4

Object

Development Management Plan Focused Consultation 6th July - 17th Aug 2012

Representation ID: 3845

Received: 17/08/2012

Representation Summary:

There was no consultation and no credible evidence base - choices are not supported by facts, only subjective assessments based on a wide variety of criteria.
They diverge from SOA boundaries in at least 10 locations rendering them statistically unreliable, and cut across Conservation Areas.
They are too large to be effective in their aim of providing 'a more local perspective and sense of place'. The portraits are superficial and inaccurate and do not display 'an understanding and evaluation of [ ] defining characteristics.'[NPPF 58] and pre-empt local involvement in neighbourhood plans, contrary to the intention of the Localism Act.

Full text:

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 was 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 responses. 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 the Planning Strategy Proposed Submission Version 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.

Object

Development Management Plan Focused Consultation 6th July - 17th Aug 2012

Representation ID: 4576

Received: 13/08/2012

Representation Summary:

For a town the size of Hastings it is difficult to see the justification and rationale of sub-dividing the area into 13 sub-areas for the purpose of providing housing land alllocations, the requirement for which applies to the Borough as a whole.

Full text:

See attached

Object

Development Management Plan Focused Consultation 6th July - 17th Aug 2012

Representation ID: 4577

Received: 13/08/2012

Representation Summary:

It is pointed out that the Marline Valley SSSI and surrounding area subject of our representations has only limited footpath access. The site is not otherwise open space and footpath access is limited though it has been observed that 'informal' paths have been created. However, the allocation of the land at Breadsell Lane will create an important opportunity to plan appropriate improvements to the present footpath network as well as providing pedestrian and cycling links between existing communities and the site in the manner shown on the submitted masterplan.

Full text:

See attached

Comment

Development Management Plan Focused Consultation 6th July - 17th Aug 2012

Representation ID: 4585

Received: 13/08/2012

Representation Summary:

The County Council can provide HBC with short paragraph statements on key historic and archaeological background to each area to help set the scene for the present dayt and future vision. This information may be more appropriately presented elsewhere in the Local Plan but it would perhaps be helpful if this document incuded a link to historic and archaeological background information for each spatial portrait area to allow residents ot understand how each area has developed to its present state.

Full text:

See attached