4.3

In accordance with Paragraph 4.3 we would like this opportunity to propose an alternative site for consideration within the site allocations - land west of Rock Lane (north of Spindlewood Caravan Park). The reason for writing to you at this stage is because Hastings Borough Council (HBC) has now extended its proposed site allocations to include potential sites that are greenfield sites. Previously, Savills made representations to the Core Strategy Informal Consultation. Savills also wrote to you in October 2010 requesting an assessment of the site for its potential for residential development, and more recently (November/December 2011) Savills requested a meeting with HBC to discuss the potential for this site but no correspondence or meeting was set up by HBC.

Despite our request for our site to be assessed through the SHLAA, the site was excluded. Savills was advised by HBC that the site represented a 'major incursion' into the AONB and the Council was only seeking to identify previously developed sites within the Borough. The adjacent site B39 (Spindlewood Caravan Park) was similarly excluded from the SHLAA and for the following justification:- "Site lies within AONB with sensitive landscape issues though the caravan site has significant mitigation measures in place. Given the over riding importance of the AONB, the capacity to accept development in landscape terms is likely to be moderate. Development options elsewhere must be explored thoroughly before any incursion into the AONB is considered."

It is now evident from HBC's housing requirement in the Local Plan and this focused consultation document, that HBC must identify greenfield sites. The land west of Rock Lane as identified on the attached plans (Plan 1. Land ownership Plan)in accordance with Paragraph 4.3 should be considered for potential residential development.

You will be aware that Rother District Council (RDC) has identified our client's land in their SHLAA as a potential residential development site (Site Reference HF6) with the potential for approximately 35 dwellings. Furthermore, RDC has proposed Policy HF1 Hastings Fringe in their Submission Core Strategy, which includes:

"(ii) Take a holistic approach to the use and management of land between Ivyhouse Lane and Rock Lane to secure environmental and access improvements in association with any development in the locality; ...
(vi) Provide 45-80 net additional dwellings between 2011 - 2028."

Our client's site is situated between Ivyhouse Lane and Rock Lane, which is the site referred to at HF1(ii) above. Within the Hastings Fringe, a site at Woodlands Way benefits from planning permission for 43 dwellings, and apart from our client's site there are no other sites identified in RDC's SHLAA within the Hastings Fringe. HF1(ii) endorses the potential for development on our client's site up to 37 dwellings. RDC's 'Hastings Fringe Background Paper, August 2011' acknowledges at paragraph 10.2 the potential for development of the site "subject to consideration of the impact of the High Weald AONB and wider landscape impacts in the area. Any development in the area should be considered as part of a comprehensive approach to the area in order to facilitate improvements to areas of degradation which exist within the AONB along the Fringe. These considerations will be explored further within the Development and Site Allocations DPD."

The approach set out by RDC in their Submission Core Strategy and supporting documents is reflected in HBC's Proposed Submission Local Plan, whereby paragraphs 2.44 and 2.49 set out HBC's and RDC's shared approach, along with paragraph 5.56 and Policy EN4. Furthermore, Local Plan Policy FA5(a) states:

a) Adopt a joined up approach with Rother District Council to the use and management of land between Ivyhouse Lane and Rock Lane, to secure environmental and access improvements in association with development in the locality.

RDC and HBC have adopted a joined up approach to promote development on our client's land to facilitate environmental and access improvements in the locality which is in our client's private land ownership. However, whilst HBC endorses residential development should take place on our client's land within Rother District, it does not consider development should occur on land within their administrative boundary. This approach is inconsistent. The allocation of our client's land for residential development within Rother and Hastings' administrative area would achieve a comprehensive form of development, presenting minimal encroachment beyond the current settlement boundary and into the AONB which is not currently publicly accessible. Residential development would provide the potential to facilitate environmental and access improvements into the AONB. Long term management and maintenance to protect and enhance the AONB would be discussed as part of a planning application, and subject to development viability.

HBC is considering a significant urban extension to Hastings on greenfield land at Breadsell Lane (B16), previously discounted in the Submission Local Plan and SHLAA. Furthermore, land to the north west of Winchelsea Lane (N05) is outside the settlement boundary and within the AONB, presenting similar constraints to our client's site. The site at Battle Road (N08) is adjacent the AONB and which reportedly has similar nature conservation/SSSI issues as B16.

The development of our client's site represents an opportunity for a logical and small scale extension to the settlement boundary, that would cross boundaries with RDC to contribute towards the delivery of much needed new housing whilst having the potential to deliver wider benefits with environmental and access improvements to the AONB.

5 of the 6 potential sites identified in this focused consultation document have constraints to development, and which in some instances present similar constraints to those on our client's land. Those constraints are capable of being overcome with respec to our client's land whilst providing the opportunity for significant public benefits to access and improve the AONB. The site is capable of being delivered within the next five years.