Hastings Borough Council Cc Cllr Dawn Poole – Lead Member Regeneration, Communities & Culture Appendix B

Matter 3 – HBC, SR8

APPENDICES INDEX

Appendix A HBC letter to ESCC 25 February 2016

Appendix B ESCC Cabinet Report 8 March 2016

Appendix C HBC comments on the draft Waste & Minerals Sites Plan 19 August 2014

Appendix D HBC comments on the draft Waste & Minerals Plan 09 December 2015

Appendix E Queensway Gateway Road Letter of Support from Rupert Clubb, Director of Communities, Economy & Transport 5 August 2015

Appendix F Statement from John Shaw, Chief Executive, SeaChange Sussex

Appendix G Statement from Kerry Culbert, Planning Policy Manager, HBC

Appendix H Hastings Local Plan, Hastings Planning Strategy 2011-2028 (adopted 19.02.14); Hastings Local Plan, Development Management Plan (adopted 23.09.15); Hastings Local Plan, Policies Map, Development Management Plan (adopted 23.09.15) (incorporating Planning Strategy Policies adopted 19.02.14) Appendix A Please quote: Your reference: Date: 25th February 2016 Please ask for: Kerry Culbert Telephone direct: 01424 783304 E-mail: [email protected] Web: www.hastings.gov.uk/planning Regeneration and Culture Aquila House, Breeds Place Hastings, East Sussex TN34 3UY Mr Tony Cook Planning Policy and Development Management Planning Services Communities, Economy and Transport County Hall St Anne’s Crescent Lewes East Sussex BN7 1UE

By email and by post

Dear Mr Cook

Thank you for the opportunity to meet with yourself and Sarah Iles on the 9th February to discuss your potential proposed Main Modifications to the Waste & Minerals Sites Submission Plan (W&MSP). We also welcomed your invitation to Rother District to attend in light also of that Council’s concerns with the Plan.

We were encouraged by the fact that you are now proposing some “Main Modifications” to the Plan prior to submission but I felt extreme disappointment that at the meeting it appeared that your proposals were a “final offer” rather than any realistic opportunity to further consider Hastings outstanding concerns.

Since the meeting I have had the opportunity to discuss matters with our Lead Member for Regeneration, Communities & Culture. As I emphasised at our meeting you will be aware of the strength of our Cabinet’s response regarding your proposed submission plan. I am accordingly now charged to write formally to you to express our disappointment that following our meeting we remain concerned that despite our previous initial comment of support in principle for the draft W&MSP providing it was not in conflict with our emerging Development Management Plan (DMP) that there has been no direct or indeed any further liaison since that original comment when clearly we consider that there is now significant conflict with our now adopted DMP. We do not feel this approach meets the spirit of the Duty to Co-operate – and that this situation we are now in might otherwise easily have been avoided.

1. Firstly – just to reaffirm that my Council’s Cabinet resolution is very strong and that, whilst welcoming what we see as being clearly a move in the right direction, what is on the table at present (via your proposed “ Main Modifications”) simply does not meet this Council’s concerns. Whilst points 3 and, to some extent 4, of the Cabinet resolution have been addressed, points 1 and 2 have not really been touched upon.

2. We do welcome the deletion of the land at Whitworth Road which we have previously expressed concerns about – this addresses our Cabinet resolution at point 3.

3. However we remain particularly concerned at the inclusion of almost all of the DMP employment land allocations as areas of search or opportunity for waste purposes (the exceptions being Hastings town centre and your own land east of Queensway) and the apparently blanket ‘acceptable in principle’ approach to existing industrial estates. Appendix A 4. With regard particularly to the DMP’s employment allocations on land West of Queensway – this approach, as promulgated in your Plan will significantly undermine one of the principal planks of our economic strategy – of delivering a high quality, easily accessible employment corridor – capable of significantly raising the quality, number and prospects of job opportunities within the Borough. This remains the main strategic thrust of our DMP and Planning Strategy for employment land and growth and underlines our concerns regarding the W&MSP as currently drafted and its adverse impact upon this strategic objective.

5. The inclusion of the Queensway land also seems to be at odds with what your Council has supported, from an economic development perspective, at our EIP in respect of what our DMP is trying to achieve. And also in terms of the support given by your Council for the proposed Queensway Gateway Road, a strategic piece of highways infrastructure that has recently been approved and which greatly enhances this employment corridor and its ability to deliver that strategic employment corridor.

6. The use of this land west of Queensway for waste management purposes might well also impact adversely upon Marline Valley SSSI in terms of air quality, disturbance and risk of pollution for example.

7. Whilst we welcome the proposed additional wording and references that are now within the proposed “Main Modifications” to the W&MSP, to our own DMP and Planning Strategy (Local Plan) we fear these could all too easily be overridden in the event of an application being considered.

8. In determining the appropriate level of new employment needed over the lifetime of the Local Plan, the Council has had due regard to the continuing need for regeneration. The Hastings Planning Strategy seeks to protect and enhance the Borough as a major centre of diversified employment, and to that end it proposes up to 70,000 sq m of employment floorspace during 2008-2028. The DMP employment allocations are clearly needed to meet this target which is now enshrined within the adopted Planning Strategy. We are greatly concerned as outlined at (3) above, that since the scale of what might be needed or proposed for waste management purposes is not clear at this stage the impact on allocated sites and existing IEs and ultimately the Council’s ability to meet its own Local Plan employment targets will be seriously undermined.

9. In fully accepting the need for waste and recycling facilities to be located close to the point of waste generation, in order to serve a growing Hastings and Rother population, we consider that there are clear and much more preferable alternatives that will not cause such damaging impacts upon the successful delivery of jobs within Hastings. There is considerable merit in looking at the Burgess Road area (land within Hastings and Rother) to provide for the future waste needs of both Authorities. That said, the current planning application at Burgess Road both vindicates our DMP allocation and emphasises our concerns as expressed to yourself at our recent meeting as to the apparent lack of rigour your Council has shown in the drafting of its Plan in terms of approaching landowners.

We will of course be pleased to continue to be available to discuss this matter further and would again urge you to reconsider our concerns and point 4 of my Cabinet’s resolution to submit a revised proposed Submission version to more appropriately address these concerns. As matters stand we feel that we will have no option but to maintain our formal objection to the Submission Plan.

May I finally take the opportunity to clarify our understanding of what you advised us at the meeting of 9th February, namely that you do not intend to separately publish your proposed Main Modifications for public consultation but instead expect that these will be consulted upon at the same time as any Main Modifications that may be recommended by the Inspector appointed to examine the Plan. I further understand that you are intending to report upon the matter of the Plan to your forthcoming Cabinet on the 7th March.

Yours sincerely, Kerry Culbert Planning Policy Manager Cc Cllr P Chowney – Leader, Hastings Borough Council Cc Cllr Dawn Poole – Lead Member Regeneration, Communities & Culture Appendix B

Report to: Cabinet

Date of meeting: 8 March 2016

By: Director of Communities, Economy and Transport

Title: East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan – Regulation 19 Consultation – Response to Objections

Purpose: To agree an initial response to Objections received during the Regulation 19 Consultation on the Waste and Minerals Sites Plan to be submitted to the Inspector as part of the Public Examination, and, seek delegation to officers to agree and consult on draft Main Modifications to the Plan.

RECOMMENDATIONS: Cabinet is recommended to:

(1) Agree, subject to the endorsement of Brighton & Hove City Council and the South Downs National Park Authority, to the proposed approach to the Objections to the Pre- Submission Waste and Minerals Sites Plan and, to the submission of draft Main Modifications to the Inspector as included in Appendix 3, and thereby, alter the Minerals and Waste Development Scheme to reflect the revised programme; (2) Authorise the Director of Communities, Economy and Transport to agree, in consultation with Brighton & Hove City Council and South Downs National Park Authority, for subsequent public consultation, the draft Main Modifications and any further Main Modifications arising from the Public Examination necessary to make the Waste and Minerals Sites Plan sound, except where any subsequent change would involve a significant shift in the policy approach whereby this would be referred to Cabinet for approval prior to public consultation; (3) Authorise the Director of Communities, Economy and Transport to make, if necessary, minor changes to the document arising from any views of the City Council and National Park Authority, or, arising from the Public Examination; and (4) Note that all Main and Minor Modifications to the Plan will ultimately be presented to Cabinet and Full Council in due course as part of the Adoption of the Waste and Minerals Sites Plan

1. Background Information

1.1 The Waste and Minerals Plan (WMP) was adopted by the County Council, Brighton & Hove City Council (BHCC) and the South Downs National Park Authority (SDNPA) in February 2013. The Plan set out the 3 Authorities’ planning policy for waste and minerals development in the Plan Area. It included ambitious targets for diverting 98% of all waste from landfill by 2020/21 and proposed that the Plan be net self-sufficient in waste management capacity. In order to achieve this, additional recycling and recovery facilities are required for the Plan period up to 2026. The WMP did not identify any specific sites but saved certain previous site allocations.

1.2 The Waste and Minerals Sites Plan (WMSP) has been prepared to, among other aspects, provide spatial guidance on locations that would satisfy the requirements for waste facilities identified in the WMP. Detailed appraisal work was undertaken on the location possibilities for waste facilities and other matters. Public consultation on a draft WMSP was carried out over nine weeks in the summer of 2014. Following this, the proposed site allocations were reviewed and a Appendix B

Proposed Pre-Submission Draft Version prepared. The 3 Authorities agreed in October 2015 to public consultation on the Proposed Pre-Submission WMSP, as required by Regulation 19 of the Town & Country Planning (Local Planning) Regulations 2012. (This was reported to Cabinet on 22 September 2015). The waste site categories proposed in the Pre-Submission WMSP are detailed in Appendix 1.

1.3 According to the Regulations, public consultation under Regulation 19 is followed by formal submission of the Plan to Government and subsequent Public Examination held by a Planning Inspector. Any Main Modifications to the Plan are then consulted on, prior to adoption of the final Plan by the 3 Authorities. The County Council is also required by the Localism Act to keep the Minerals and Waste Development Scheme up to date.

1.4 A total of 47 representations were received on the Proposed Pre-Submission WMSP and one was received after the close of the consultation. A summary of the main representations is included in Appendix 2, and a copy of all the representations is available in the Members’ Room. To assist the Public Examination, it is proposed that the 3 Authorities indicate to the Inspector their initial response to the representations. As a consequence, Main Modifications are proposed to the Plan (see Section 2 below and as detailed in Appendix 3). Further Modifications may be suggested by the Inspector at the Public Examination, and it is proposed that public consultation on all the Main Modifications is carried out after the main Hearings of the Public Examination, with delegated authority being given to the Director of Communities, Economy and Transport to undertake this. The Minerals and Waste Development Scheme should be updated to reflect a potential submission in April 2016, Public Examination in the summer and Adoption in December 2016. It should be noted that all Main and Minor Modifications to the Plan including those proposed by the Inspector will ultimately be presented to Cabinet and Full Council in due course as part of the Adoption of the WMSP.

2. Supporting Information

2.1 The Sites Plan is designed to assist developers find sites suitable for waste development. The Plan puts forward a multi – faceted approach to deal with the shortfalls in capacity. There are waste site allocations which are considered suitable in principle for waste development and are safeguarded in the Plan (this includes Sackville Goods Yard, Brighton, and, Old Factory site, Lower Dicker). Extensions are proposed to some existing waste sites – these are also safeguarded. Two further types are not safeguarded – Areas of Opportunity on Previously Developed Land (which relate to specific sites including Queensway, Hastings, and, Former Gasworks site, Brighton), and, Areas of Search (which are less defined as they represent major expansion of urban areas where master-planning is still in process – including Land North of Bexhill, Land at Burgess Road on Hastings fringes, and, Whitworth Road, Hastings). Potential developers therefore have a plethora of options open to them but are most likely to pursue sites that are identified as being suitable in principle and are safeguarded. The sites assessed are outside the National Park and the High Weald Area of Outstanding Natural Beauty, save for two on the northern edge of Hastings. It was considered that sufficient allocations/guidance was included in the Pre-Submission WMSP to satisfy the capacity gap for recycling and recovery waste facilities.

2.2 Rother District Council (RDC) objects to North East Bexhill being identified as an Area of Search, and, to Beeching Road and Brett Drive Industrial Estates being identified as suitable industrial estates for waste development. The District Council also suggests extending the Area of Search adjoining Hastings fringes. The 3 Authorities’ Plan already incorporates some safeguards in relation to any new waste development in the Areas of Search recognising the need for compatibility with adjoining uses but the cross references should be strengthened whilst retaining North East Bexhill as an Area of Search. The existing industrial estates either have current waste uses in that location or are considered compatible for certain types of waste management. However, the wording of the Policies, via a Main Modification, should be Appendix B strengthened with regard to stressing the need to address constraints that might exist. The approach to Hastings fringes is considered in paragraph 2.3.

2.3 Hastings Borough Council specifically objects to all the main waste sites in Hastings referred to in the Plan, and wish to retain primacy for their local plan in the decision making process. The Borough Council objects to the identification of land at Burgess Road on the Hastings fringes as an Area of Search (this being the other part of the site that RDC suggests is suitable for extension – see above). In the light of these representations, it is proposed that the 3 Authorities approach should be that Land at Burgess Road should be retained as an Area of Search and extended as suggested by RDC, but, via a Main Modification, that the wording of the Policy be altered, similar to above, to strengthen the references to the need to address constraints that might exist and compatibility with adjoining uses. In addition specific reference should be included relating to a joint approach by the County Council, Borough Council and District Council to development on Hastings fringes. Land west of Queensway should be retained as an Area of Opportunity on Previously Developed or Allocated Land but, via a Main Modification, the Policy will be refined to specifically refer to other development plans, and stressing the need to address constraints and compatibility. The Borough Council as landowner has objected to the identification of Whitworth Road as an Area of Search. Whilst there is already a waste use established adjoining this site, it is now recognised that, given the circumstances, waste development is going to be difficult to achieve at this particular site. In consequence, this site should be withdrawn as an Area of Search. The Borough Council’s concern on primacy of their local plan misunderstands the approach by the 3 Authorities, and the Sites Plan does not have the effect envisaged by the Borough Council.

2.4 The landowner for the Sackville Goods Yard and the Hove Station Neighbourhood Forum have submitted objections to the allocation for waste uses for this site. Since the Proposed Submission draft of the Plan was published, the City Council has become aware, through discussions and representations, that the landowner’s plans for a comprehensive redevelopment of the combined Coal Yard and Sackville Trading Estate are at an advanced stage, and that the landowner would not entertain proposals for a waste use on the site. The landowner’s position and plans for redevelopment are strongly supported by the local Neighbourhood Forum which considers that a waste allocation would impede the redevelopment of the area as envisaged in the emerging Neighbourhood Plan. Landowner objection is not, in itself, a justification for not allocating a site as ownership can change over the lifetime of a plan. However, taking into account the advanced stage of the alternative development proposals and the incompatibility with the aims of the emerging Neighbourhood Plan, it is considered, in this instance, that the removal of the site is justified on the grounds that a waste facility is demonstrably undeliverable.

2.5 With regard to the Hoyle Road site at Peacehaven, the landowners have submitted objections. The site is included in the Plan as an ‘area of opportunity’ and is not safeguarded for waste uses. Areas of Opportunity provide guidance to potential developers that these sites are considered for employment uses and worthy of further investigation. They do not seek to prevent alternative development coming forward. No further changes are considered necessary at this stage.

2.6 Representations have been received in relation to other sites. With regard to the Old Factory Site, Lower Dicker, this included a petition. It is considered that the issues raised for all these sites should be debated at the forthcoming Public Examination, and no significant alterations to the draft WMSP are proposed at this stage.

2.7 A number of representations were received in support of the Plan or specific sections of the Plan, including representations from Lewes District Council, Wealden District Council, Surrey County Council, Kent County Council, Friends of Lewes, and, BPP Consulting on behalf of a waste operator. . Appendix B

2.8 Overall, it is considered that the WMSP is still sound if these changes are accepted. Whilst these alterations would mean that not all of the waste capacity requirements could be met at allocated sites or existing site extensions, it is felt that sufficient options exist for potential operators to find locations for waste development.

3. Conclusion and Reason for Recommendation

3.1 The analysis of the representations on the Pre-Submission WMSP should be noted. Appraisal of the objections received indicates that the flexible approach to options to meet the requirements for additional waste recycling and recovery facilities identified in the Plan should be retained, but certain refinements and strengthening of the wording of Policies should be agreed for submission to the Public Examination. Main Modifications should be agreed to extend the Area of Search at Land at Burgess Road on Hastings fringes, withdraw the Whitworth Road Area of Search and Sackville Goods Yard Waste Site Allocation, and, strengthen some of the Policies in the WMSP. Authority should be given to the Director of Communities, Economy and Transport to agree all the Main Modifications arising from the Public Examination for public consultation. The Minerals and Waste Development Scheme should be revised to indicate the new timetable for the document. It should be noted that all the Main and Minor Modifications to the Plan will ultimately be presented to Cabinet and Full Council in due course as part of the Adoption of the WMSP.

RUPERT CLUBB Director of Communities, Economy and Transport

Contact Officer: Tony Cook Tel. No. 01273 481653 Email: [email protected]

LOCAL MEMBERS All

BACKGROUND DOCUMENTS • East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (2013) • The Proposed Submission Draft Waste and Minerals Sites Plan • Draft Revised Minerals and Waste Development Scheme Appendix B

APPENDIX 1 - WASTE SITE CATEGORIES INCLUDED IN THE PRE-SUBMISSION WMSP

1 Waste Site Allocation

A Waste Site Allocation is a strategic site location that has been assessed as being suitable, in principle, for a waste treatment activity. It is considered that the location meets appropriate criteria and could be deliverable within the Plan period. There would be material considerations associated with these sites which would need to be appraised at the planning application stage. These site locations would be safeguarded in line with Policy SP 6 of the WMSP.

Proposed Allocations:

SP-A/A - Coal Yard adjacent to Sackville Trading Estate, Hove SP-A/B - Hangleton Bottom, Hangleton Link Road, North Portslade SP-A/C - Old Factory, West of A22, A271, and A267 Roundabout, Lower Dicker SP-A/D - Pumping Station, A271, nr Amberstone Bridge, Hailsham

2 Area of Opportunity on Previously Developed or Allocated Land

An Area of Opportunity on Previously Developed Land is a location that is suitable, in principle, for a waste treatment activity but a specific site allocation is not identified. These locations could be either existing mixed use areas, or sites with planning permission for employment, or, allocated land for employment use. They are likely to be deliverable within the Plan period. There would be material considerations associated with these sites which would need to be appraised at the planning application stage. These locations would not be safeguarded under Policy SP 6 of the WMSP.

Proposed Areas of Opportunity:

SP-O/A - Beach Road (Land west of), Beach Rd / Railway Rd, Newhaven SP-O/B - Former Gasworks, Roedean Road, Brighton SP-O/C - Hollingdean Industrial Estate, Brighton SP-O/D - Hoyle Rd, Peacehaven SP-O/E - Maresfield Camp, Maresfield (Ashdown Business Park) SP-O/F - North Quay, Newhaven SP-O/G - Queensway (Land west of), Hastings SP-O/H - Station Road / Old Swan Lane Industrial Estate, Hailsham SP-O/I - Station Road Industrial Estate, Hailsham

3 Area of Search for New Mixed Use Development

An Area of Search for New Mixed Use Development is a location that is proposed by a Borough or District Council for mixed use development as part of the growth or expansion of a major urban area. The deliverability of these locations will be dependent on when the major expansion is brought forward and what phasing of housing and employment is undertaken. These locations would not be safeguarded under Policy SP 6 of the WMSP.

Proposed Areas of Search:

SP-S/A - Burgess Road, Hastings SP-S/B - Ivyhouse Lane Extension, Hastings SP-S/C - Land north of Sidley, Bexhill SP-S/D - Land at West Uckfield, Uckfield SP-S/E - Whitworth Rd, Hastings Appendix B

4 Physical Extension of Existing Waste Site

A Physical Extension of Existing Waste Site is a location where an existing waste management treatment activity has a vacant adjoining site that is capable, in principle, of also supporting waste treatment. These locations could be deliverable within the Plan period. There would be material considerations associated with these sites which would need to be appraised at the planning application stage. These locations would be safeguarded in line with Policy SP 6 of the WMSP.

Proposed Physical Extension of Existing Waste Site:

SP-E/A - Cophall Wood Waste Transfer Station (Land North of), A22, Polegate SP-E/B - Woodside Depot, A22, Polegate

4 Existing Industrial Estates Suitable for Waste Development

Finally, there are Existing Industrial Estates Suitable for Waste Development. A range of different waste management facilities can, in certain circumstances, be accommodated in industrial areas. Industrial estates can experience a degree of turnover in employment units which would be available on lease or for sale. These units may be suitable for waste management on a sui generis basis. Existing industrial estates would not be safeguarded under Policy SP 6 of the WMSP.

This waste category covers 48 locations in the Plan Area Appendix B

APPENDIX 2 - SUMMARY OF MAIN OBJECTIONS TO THE PRE-SUBMISSION WMSP

SP-A/A Coal Yard adjacent to Sackville Trading Estate, Hove

A number of representations were received in relation to A/A including representations from the landowner (SR48) and Hove Station Neighbourhood Forum (SR25). The Forum’s response included two petitions which contained approximately 600 signatures objecting to the designation. Issues raised were similar to the previous consultation. The issues identified centre on conflict between SP-A/A and the Brighton & Hove City Plan Policy DA6 and the Landowner’s alternative proposals for the site. The Landowner’s representation also indicates that proposals for alternative development are quite advanced.

SP-A/C Old Factory, West of A22, A271 and A267 Roundabout, Lower Dicker

Five representations were received, one of which, (Zoar Chapel, SR48), included a petition with 56 signatures objecting to the allocation. Issues included: the effect of development on the neighbouring Church; traffic; litter; odour; noise

SP-A/D Pumping Station, A271, nr Amberstone Bridge, Hailsham

Three representations were received. Herstmonceux Parish Council (SR33), the Environment Agency (EA) (SR36) and one individual object to the allocation. The EA is objecting on grounds of flood risk, but did indicate it would welcome a meeting. A meeting with the EA has been held and subject to agreed wording, the EA has indicated it is willing to withdraw the objection.

SP-O/B Former Gasworks, Roedean Road, Brighton

Three representations were received in relation to this site. The Landowner (SR41, SR45) maintains previous objections citing issues of viability, conflict with policy.

SP-O/D Hoyle Road

One representation was received (SR38). This was from the Landowner who objects to the sites identification citing that it would displace employment uses.

Bexhill / Hastings Expansion Sites (S/C Sidley (Land north of), Bexhill , S/B Ivyhouse Lane Extension, S/A Burgess Road, S/E Whitworth Road, O/G Land West of Queensway)

Representations from Hastings Borough Council and Rother District Council and others were received in relation to the above sites. HBC (SR8) cites conflict with their Development Management Plan and their Employment Strategy. RDC (SR17), in relation to S/C cites concern identification would deter inward investment. However, RDC supports Area of Search S/A and seeks the expansion of the site into Rother District. The EA objects to the identification of S/E Whitworth Road on the grounds of flood risk, but did indicate it would welcome a meeting. It may be possible to alleviate the EA’s concerns.

SP5 Existing Industrial Estates

Three representations were received in relation to SP5. Hastings Borough Council states that Policy SP5 undermines their employment strategy (SR8), while Biffa (SR14) argues that the Area of Focus (WMP7a) should not apply to existing industrial estates. Appendix B

Waste Water

Southern Water (SR44) made a representation proposing minor changes to ensure the soundness of the Plan. It is proposed that the changes are accepted.

Minerals

One representation in relation to minerals was received. The representation (SR28), which was made by Brett Aggregates, argues that, the Plan does not make provision for seven years landbank for the whole Plan Period and should be altered to allocate additional reserves at Lydd Quarry. It is suggested that the existing policy position is maintained and additional minerals allocations are not made at this time. Appendix B

APPENDIX 3 – PROPOSED MAIN MODIFICATIONS TO THE PRE-SUBMISSION WMSP Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix B Appendix C

From: Tim Cookson Sent: 19 August 2014 17:30 To: '[email protected]' Subject: FW: Waste and Minerals Sites Plan - Comments of Hastings Borough Council

The comments of Hastings Borough Council on the East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan – Consultation Draft 2014 are as follows:

That the policies of the Waste and Minerals Sites Plan Consultation Draft 2014 are supported by Hastings Borough Council on the proviso that the possible future waste management facility uses will be in conformity with the policies of the Council’s Planning Strategy and Development Management Plan, and without adversely impacting on nearby residents. However, due to the critical importance of the intended prestigious business gateway site development allocated at Whitworth Road, The Ridge West (site reference LRA8 in the Hastings Local Plan – Development Management Plan (Revised Proposed Submission Version) March 2014) the site listed as WMSP- S/E Whitworth Road, Hastings should be excluded as a potential waste and recovery site and deleted from Policy WMSP4 Areas of Search for New Mixed Use Development (on page 14 and on the context map on page 11) as well as in the Waste Site Profile section (on pages 81, 98,99 and 100 and Map 18) and finally delete any reference in the documentation to the Whitworth Road site in this document and subsequent drafts or final versions. It is strongly considered that the inclusion of this site as a potential waste site would adversely impact on the marketing, promotion, development and regenerative impact of this site.

There is an existing concrete batching plant at Hanson Quarry on Sedlescombe Road North in St Leonards which is not listed in Policy WMSP10 for safeguarding such facilities, and may need to be considered for listing in order to safeguard its continued use as a batching plant.

Regards

Tim Cookson, Strategic Planning Manager HASTINGS BOROUGH COUNCIL Aquila House, Breeds Place, Hastings, TN34 3UY Tel: +44(0)1424 783201 Fax: +44(0)1424 783208 Minicom: +44(0)1424 781755 Email: [email protected] WWW: http://www.hastings.gov.uk

1 Appendix D

From: Stephanie Roots Sent: 09 December 2015 16:12 To: '[email protected]' Cc: Kerry Culbert Subject: Regulation 19 representations on Waste and Minerals Sites Plan

Dear Sirs

Please now find attached Hastings Borough Council’s formal response in the form of a Cabinet report, to the Regulation 19 Consultation on the Waste and Minerals Sites Plan in advance of the deadline of 23 December 2015. The Council’s Cabinet resolved that:

1. That the Council submit an objection to the emerging Waste and Minerals Sites Plan as a whole, in view of its significant conflict with the policies in the adopted Hastings Development Management Plan 2015. 2. That the Council specifically objects to the identification of 3 ‘Areas of Search’ sites and 1 ‘Area of Opportunity’ site within the Hastings borough boundary for the purposes of waste disposal/waste management. These are considered to be in direct conflict with Policies in the recently adopted Development Management Plan and will significantly prejudice delivery of employment opportunities within the Borough. 3. The Council would reaffirm its previous objection to the inclusion of the site at Whitworth Road as an area of search and in light of Hastings’ previously expressed concerns is disappointed that this appears in the Proposed Submission version of the Plan. 4. Urge East Sussex County Council to consider preparing a Revised Proposed Submission draft of the Waste and Minerals Sites Plan in light of this Council’s concerns. 5. The Council reserves the right to appear at future Hearing Sessions as part of the Waste and Minerals Site Plan Examination in Public in order to support its objection.

The Councils’ objection is based on issues soundness in respect of deliverability and other matters. These issues are explained in full in the attached report. We consider it necessary to be part of the oral Examination in Public.

Yours faithfully

Stephanie Roots Senior Planner

Regeneration and Planning Policy Hastings Borough Council Aquila House Breeds Place Hastings East Sussex TN34 3UY

Web: www.hastings.gov.uk/localplan

1 Appendix D Twitter: http://twitter.com/ShapingHastings Facebook: www.facebook.com/shapinghastings

2 Appendix D

Report to: Cabinet

Date of Meeting: 7 December 2015

Report Title: East Sussex County Council Waste and Minerals Sites Plan - Proposed Submission Draft

Report By: Monica Adams-Acton Head of Regeneration and Planning Policy

Purpose of Report To gain Cabinet approval to submit formal representations on the Submission version of the County-wide Waste and Minerals Sites Plan, for consideration at Independent Examination

Recommendation(s)

Reasons for Recommendations To enable the Council’s strong concerns to be made known to the County Council as part of the preparation of its Waste and Minerals Sites Plan, and to allow them to be addressed in a final version of the Plan.

Report Template v28.0 Appendix D

To enable the Council’s views to be considered as part of the Examination in Public of the Waste and Minerals Sites Plan by an independent Planning Inspector.

Introduction

1. East Sussex County Council has published the final version (The Proposed Submission version) of its Waste and Minerals Sites Plan for formal consultation, prior to its submission and consideration by an independent Planning Inspector at Examination in Public.

2. Essentially the Waste and Minerals Sites Plan identifies sites for new waste management facilities, whilst protecting those existing. Its purpose is to identify enough new waste management facilities across the County to provide for the additional recovery and recycling capacity required to meet overall targets for diverting waste from landfill, and for East Sussex to be self-sufficient overall in waste management capacity. The proposed timescale of the Plan covers the period to 2026.

3. Notwithstanding the county wide coverage of the Plan in seeking to ensure that there is appropriate capacity for meeting this important function, this report focuses upon those elements of the Plan with particular relevance and concern to Hastings. The Waste and Minerals Sites Plan identifies 4 locations as being either areas of search for, or areas of opportunity for, waste related development within Hastings Borough. It is of particular concern that these locations are made up of 5 of the sites specifically allocated for employment purposes in the Council’s very recently adopted Development Management Plan (DMP). These 4 locations are:

• Ivyhouse Lane Extension • Burgess Road • Whitworth Road • Land west of Queensway (2 allocated sites in the DMP)

4. These sites are all formally allocated for employment (as a mix of B Use Classes) use in the recently adopted Hastings Development Management Plan. Such uses, under the Council’s now adopted Policies, would not include waste recovery or waste related uses.

5. Representations made at this stage will be forwarded to the appointed Planning Inspector for consideration during the Examination process of this Waste and Minerals Sites Plan. Representations made must be based on the “Tests of Soundness” and “Legal Compliance” as required by the National Planning Policy Framework (see paragraph 21 below).

Previous consultations

6. Hastings Borough Council previously submitted comments in August 2014 on the emerging draft Waste and Minerals Sites Plan. In summary, the Borough Council’s response was to:

Report Template v28.0 Appendix D a) Support the draft Plan providing that possible future waste management facility uses will be in conformity with policies in the Hastings Planning Strategy and Development Management Plan, and will not impact on the amenity of nearby residents b) Object to the inclusion of the site at Whitworth Road due to the potential impact on marketing, promotion, development and regenerative impact of the site, in light of the intended business gateway. c) Include existing concrete batching plant at Hanson Quarry on Sedlescombe Road North in relevant policy, in order to safeguard its continued use.

7. The County Council noted recommendation a), but did not accept recommendation b). They argue that modern waste management facilities are a source of secure long-term employment, and that investment in modern facilities can benefit the local economy. The version of the Plan now being consulted upon has been amended to take account of recommendation c).

Timetable

8. Representations on the County’s Plan must be formally submitted by Wednesday 23 December 2015.

Consideration

9. The Waste and Minerals Sites Plan is intended to be a guide to the suitability of potential waste sites, and the County Council indicates in its proposed submission Plan that not all proposals will need to be developed by the waste industry to meet their overall targets for recycling and recovery. The final number of waste development sites required depends largely on the size and capacity of the new facilities that do come forward. As the scale of what might be needed or proposed is not clear at this stage this does give some additional cause for concern in respect of potential impact upon allocated sites within the DMP.

10. Despite only a proportion of sites being likely to be required, the inclusion of sites in a Local Plan document such as this will establish the principle of such development, should the Waste and Minerals Sites Plan be adopted in its current form. In particular the establishment of such principle with regards to a number of the prime employment sites identified within the DMP could impact significantly upon the Council’s employment strategy. It is therefore important that this Council register any objections at this stage, and seek to change what is not considered to be in Hastings’ best interest.

Allocation of sites for waste development – conflict with adopted Local Planning Policy

11. The Hastings Development Management Plan was formally adopted by Full Council on 23 September 2015, following detailed consideration at Examination in Public, and approval from the Secretary of State. There are 5 individual employment (mix of B use classes) allocations in the Development Management Plan that make up the 4 identified “Areas of Opportunity” and “Areas of Search” in the Waste and Minerals Sites Plan. The identification of these areas/sites for waste development purposes which are classified as a “sui-generis” use class, as opposed to our own employment (ie namely a mix of “B” use class) uses is

Report Template v28.0 Appendix D

therefore clearly a departure from the Development Management Plan allocations, and as such, is contrary to adopted Local Plan policy.

12. It should be emphasised that a critical part of this Council’s previous consultation response to the then emerging Waste and Minerals Plan was to support the draft Plan “providing that possible future waste management facility uses will be in conformity with policies in the Hastings Planning Strategy and Development Management Plan, and will not impact on the amenity of nearby residents”.

13. It is worrying that the Site Screening Document, which forms part of the submission documents that accompany the Waste and Minerals Sites Plan, does not acknowledge incompatibility or conflict with the employment allocations in the adopted Development Management Plan for any of the sites proposed, which is undoubtedly the case. This is a matter which was clearly a proviso set down in Hastings earlier supportive response to the then emerging Plan. It is further considered that the development of these sites for waste management/waste recovery purposes, including the as yet unknown scale of any waste facilities required, is also likely to impact upon nearby residents – an additional and important caveat set out in our earlier comments to the County’s emerging Plan.

Evidence and deliverability

14. The employment allocations for a mix of B class uses in this Council’s Development Management Plan are based on extensive evidence gathering and widespread consultation with landowners, businesses and residents in order to be able to demonstrate deliverability at Examination in Public. It is uncertain whether at this stage whether the County has approached relevant landowners in respect of their proposed “Areas of Search” and any willingness for the land to be used for this purpose. Land uses for such waste purposes might well attract significantly less value that those for other employment uses; and thus prove undeliverable on this basis. Certainly the Council’s previous objection to the identification of the site at Whitworth Road in particular (and which is Council owned) demonstrates that without the landowner’s agreement, there is little or no prospect of delivery, and therefore should not be allocated in the Waste and Minerals Sites Plan if it is to be considered “sound”.

Impact on job creation and demand

15. There is a compelling need within Hastings to ensure that the Council makes maximum use of our allocated employment space due to the continuing low job density rate in Hastings, together with the constrained/lack of available employment space. This is needed for a variety of reasons; but especially to ensure that increased job opportunities exist to support the existing population, reduce unemployment, and to provide for needs that will occur as part of the growth of “at least 3,400 new homes” proposed within the Council’s adopted Hastings Planning Strategy (2014). The Planning Strategy also sets an overall target for employment floorspace development, based on a sound and robust evidence base, that takes account of future job requirements, regeneration activity and need for economic growth, substantiated at its own Examination in Public. Whilst it is acknowledged that waste development opportunities will provide some element of job creation, this will be at a significantly lower density than would be achieved by our existing

Report Template v28.0 Appendix D

DMP allocations and would be especially damaging in respect of a number of the prime employment allocations now allocated in the adopted DMP.

16. All sites identified in the Development Management Plan are required to be retained for employment uses in order to meet the targets set in the adopted Planning Strategy; and to provide the number of jobs needed to meet existing demand, as well as the new demand created by the provision of new homes. Their loss would potentially undermine the employment strategy set and agreed for Hastings, and would impact significantly and negatively, not only on the local economy, but also in sustainability terms due to the subsequent increased need for residents to be forced to travel outside of the Borough for work.

Comments upon the County’s Proposed Submission document

17. The Waste and Minerals Sites Plan identifies Burgess Road, Ivyhouse and Whitworth Road as “Areas of Search for New Mixed Use Development within and as a location that is proposed by a Borough or District”. The Plan states that these sites form part of a wider mixed use development, and that waste development will be brought forward for development as part of the growth or expansion of a major urban area. It continues by suggesting that the deliverability of these locations will be dependent on when the major expansion is brought forward and what phasing of housing and employment land is undertaken.

18. Whilst the County document is somewhat unclear as to what it means by referring to these areas of “mixed use” development none of the sites proposed as part of the “Area of Search” are allocated for mixed use development within the DMP in terms of their being allocated for a general mix of employment purposes. They are located on established employment estates with clear objectives for bringing forward the DMP allocations and specifically relate, in a Policy sense, to B use classes only (under the Town and Country Planning Use Classes Order). These are unlikely to include uses such as those proposed in the proposed Waste and Minerals Plan, which are likely to be defined as “sui-generis”.

Existing employment estates

19. Policy SP5 of the Waste and Minerals Sites Plan is a broad criteria based policy that supports waste management development on identified existing industrial estates in principle, subject to certain criteria. In response to this Policy, it is questioned whether the broad assumption that such facilities can always be acceptable on established estates, particularly in instances where there is existing successful development and/or development opportunities centred on the B use classes. Depending upon the scale, nature and location of waste facilities required, it is accepted that it might be possible to accommodate some facility on some existing industrial sites. However the Council would maintain strong objection to such approach being promoted on the prime employment locations within the DMP and consider this would undermine its employment strategy.

Material change in status of the Hastings Local Plan

20. There has been a significant material change in the status of the Development Management Plan since representations were previously submitted to the County Council on its then emerging Waste and Minerals Plan in August 2014. At that

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time, the Development Management Plan had not been formally adopted, nor indeed had its examination in public even begun. The DMP therefore did not carry full weight in the decision making process. Hastings Borough Council now has a full, sound and legally compliant statutory development plan, which has undergone its own thorough examination process and should retain primacy in the decision making process and in providing for the future needs of Hastings.

Tests of Soundness and Legal Compliance

21. With regards the examination of the Waste and Minerals Plan there are 4 tests of soundness as required by National Planning Policy Framework (NPPF) that are used in the Examination of development plans. The Plan in question must be:

1. Positively prepared – a strategy that seeks to meet objectively assessed development and infrastructure requirements 2. Justified – be the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence 3. Effective – be deliverable and based on effective joint working 4. Consistent with national planning policy

22. The Plan should also be legally compliant and consistent with all relevant legislation and guidance. All representations must be made in accordance with these tests.

Conclusion and Recommendations

23. Taking account of the issues discussed in the main body of this report, it is recommended that Hastings Borough Council submit formal representations as objections on the Waste and Minerals Sites Plan as recommended within this report. In respect of more detailed matters and those which would be further explored at examination these would be based, but not exclusively, upon the Plan’s failure to meet the Tests of Soundness “Justified” and “Effective”. These representations would include:

• The lack of acknowledgement of incompatibility with a recently adopted Development Management Plan, and the potential to undermine its delivery, particularly of jobs and associated regeneration and economic benefits as well as overall integrity of the DMP.

• What evidence is there of reasonable alternatives to the Areas of Search/Opportunity within Hastings having been considered (including across County)?

• Concern and disappointment at previous objections not being taken on board.

• The lack of evidence presented to support the Waste and Minerals Sites Plan that demonstrates its ability to be deliverable and effective, particularly in terms of discussions with land owners and the availability of the land for the purposes proposed

• Lack of evidence of assessment of impacts upon neighbouring properties

Report Template v28.0 Appendix D • The significant impact on Hastings’ employment strategy in terms of the potential loss of some of our largest and most viable employment allocations

• The significant impact on job creation and thus sustainability and demand should allocated employment sites be developed for alternative uses.

• Potential negative impact on existing estates

• The sites that make up the “Areas of Search” within the Hastings Borough boundary do not form part of a wider mixed use development as stated in the Submission Plan but have been specifically allocated for a mix of B class uses.

24. In light of the strength of these concerns the Council should reserve the right to appear at the relevant Hearing Sessions at the formal Examination in Public of the Waste and Minerals Plan to present its case in support of these objections.

Wards Affected

Ashdown, Baird, Braybrooke, Castle, Central St. Leonards, Conquest, Gensing, Hollington, Maze Hill, Old Hastings, Ore, Silverhill, St. Helens, Tressell, West St. Leonards, Wishing Tree

Policy Implications

Please identify if this report contains any implications for the following:

Equalities and Community Cohesiveness No Crime and Fear of Crime (Section 17) No Risk Management No Environmental Issues Yes Economic/Financial Implications Yes Human Rights Act No Organisational Consequences No Local People’s Views Yes Anti-Poverty No

Additional Information Waste and Minerals Sites Plan: http://consult.eastsussex.gov.uk/portal/wmsp/submission/

Officer to Contact

Stephanie Roots [email protected] 01424 783329

Report Template v28.0 Appendix E Communities, Economy and Transport County Hall St Anne’s Crescent Rupert Clubb Lewes BEng (Hons) CEng MICE East Sussex Director BN7 1UE

Tel: 0345 60 80 190 Fax: 01273 479536 www.eastsussex.gov.uk

Hastings Borough Council 3rd Floor Aquila House Breeds Place Hastings TN34 3UY

5th August 2015

Dear Mr Hubbard

QUEENSWAY GATEWAY ROAD – LETTER OF SUPPORT

Ahead of the Borough Council’s Planning Committee further consideration of planning application HS/14/0832 submitted by Sea Change Sussex, I write to express the County Council’s support for the proposed Queensway Gateway Road.

As you will be aware, a solution to improve the transport network in North Hastings, for what has previously been referred to as the Baldslow junction improvement with the A21, has been at issue for many years. In 2006 a scheme was included in regional funding allocations and retained in the refreshed allocations in 2009. The original intention was to complete the improvement in parallel with the Bexhill Hastings Link Road, however, following delays in the project and post the May 2010 election, the previous scheme was cancelled as part of the Coalition Government’s Comprehensive Spending Review.

The South East Local Enterprise Partnership’s Strategic Economic Plan was published in May 2014 and sets out the ambitious growth plans and required infrastructure to support the delivery of these plans across the LEP over the next 6 years. The SEP identifies the area of Bexhill and Hastings as one of 12 Growth Corridors across the LEP area, referred to as the ‘A21/A259 Hastings-Bexhill Growth Corridor. The area contains some of the most severe deprivation in the SELEP area, but also major opportunity sites to accommodate growth in employment and housing.

Because of the constraints on the existing road network, this corridor has suffered from severe congestion which has in turn inhibited growth. The soon to be completed Bexhill Hastings Link Road forms the core infrastructure for the Growth Corridor, unlocking the growth plans for Bexhill and Hastings as well as improving the reliability of journey times to and from the two towns. The Queensway Gateway Road, identified in the Strategic Economic Plan, will support this significant investment from both the Department for Transport and the County Council in the Bexhill Hastings Link Road.

The road would serve a strategic purpose in linking Bexhill in the west and the A21 to the east of the Growth Corridor by relieving congestion on The Ridge and improving traffic flows onto the A21. Critically, Queensway Gateway Road connects the Bexhill Appendix E Hastings Link Road (BHLR) to the A21, redistributing traffic from the BHLR and The Ridge heading towards the A21. The opening of the BHLR will change the balance of traffic movements in the Hastings/Bexhill area, increasing traffic volumes along The Ridge and Queensway. The link between The Ridge and the A21 already displays signs of capacity problems. By relieving congestion, the Queensway Gateway Road will improve strategic connectivity in the Growth Corridor, improving employment development potential in Queensway and employment and housing growth potential in North Bexhill.

Importantly, the Queensway Gateway Road would provide access to designated employment development sites within the Bexhill Hastings Growth Corridor which would otherwise not be brought forward. The new road allows land to be released around the road for employment development identified in policies LRA 7 and 8 of the Hastings Planning Strategy adopted last year. Specifically, the road opens up the development potential of key sites south of The Ridge, with capacity for up to 12,000sqm of employment floor space, which would create up to 900 jobs.

In summary, we welcome Sea Change Sussex’s application to bring forward the Queensway Gateway Road which supports the growth plans set out in the Strategic Economic Plan and delivers improvements to the wider transport network in the Hastings area. The funding has been secured through the LEP’s Local Growth Deal to enable its delivery and therefore we would urge the Planning Committee to approve the application for this investment in the Hastings Community supported by Government, the LEP and East Sussex County Council.

Yours sincerely

Rupert Clubb Director of Communities, Economy and Transport

T: 01273 482200 E: [email protected] Appendix F Appendix F Appendix G

Statement from Kerry Culbert, Planning Policy Manager

The Hastings Planning Strategy (HPS) seeks to protect and enhance Hastings as a major centre of diversified employment, and to that end Policy DS2 in the HPS identifies a need for up to 70,000m2 of employment floorspace between 2008 and 2028. The objectives of this Policy are to support economic regeneration, local economic growth and aid employment diversification. This will be achieved in a number of ways, including the continuing development of new office-based employment opportunities at Priory Quarter in Hastings town centre, the provision of employment land in the Queensway Employment Corridor (about 15,300m2) and additional employment floorspace in existing employment areas, mainly at Churchfields.

The Development Management Plan (DMP) carries forward this overall approach with the identification and allocation of land for employment purposes. These allocations will widen employment choices both at the neighbourhood level and across the Borough as a whole. These provisions stem from the findings of the Hastings and Rother Employment Study & Land Review (August 2011) (ESLR).

Policies E1 and DS2 in the HPS provide for the renewal and protection of the existing stock of employment land and premises, reflecting the importance of ensuring the effective use of these existing assets by securing their retention and generally resisting changes to alternative uses. The Policies allow for intensification, redevelopment and extensions to premises and should support and enable start-up businesses in particular.

The approach in the DMP to employment land allocation is that of concentrating new office floorspace in Hastings town centre and the allocation of land for other employment purposes close to existing employment areas off Queensway and close to it at The Ridge West. These allocations currently benefit from the financial advantages of Assisted Area status and better accessibility as a result of the recently completed Bexhill-Hastings Link Road, and the proposed improvements to the A21 road (the Queensway Gateway scheme). The existing and allocated employment areas in this part of the Borough now need to take advantage of the Government’s £56,000,000 of support for this Link Road to facilitate economic regeneration in one of the most deprived area of the South East. Significantly, at the DMP EIP, these employment policies were supported by both Rother District Council and East Sussex County Council and promoted by Sea Change Sussex, the economic regeneration company for East Sussex.

The floorspace requirements identified in the joint ESLR and subsequently taken forward in the HPS were informed by the Employment Densities Guide prepared by the Homes and Communities Agency. Employment density refers to the average floorspace (in m²) per Full- Time Equivalent (FTE) member of staff. It is used as a measure of intensity of building use and an indicator of how much space each person occupies within the workplace. Accordingly it can be used to calculate the additional new jobs arising from new development.

Table 1 below shows the difference in job creation from different types of B class uses for the two DMP sites LRA6 & LRA9, proposed as opportunity sites in the submission Plan. Both sites are allocated for B use class purposes in the Development Management Plan. These sites are suitable for high quality business development, possibly for a single large user or more likely for several medium sizes business units or a range of small ones. Both sites are currently being marketed for B-use class purposes including B1. Appendix G

Table 1: Job density estimates based on B class employment uses

Use Use type Density – Site LRA6 – Site LRA9 Site HOV11 Site GH8, 9, Class floorspace Queensway – Marline – Ivy House 10 & 11 – (m2) per North Fields Lane Churchfields worker (FTE) (9,700m2) – (5,600m2) (7,000m2) (9,500m2) estimated estimated estimated estimated number of number of number of number of jobs jobs jobs jobs B1a General 13 (Net 537 (based 310 387 526 Office Internal Area) on total GEA (based on (based on (based on converted to total GEA total GEA total GEA NIA) converted converted converted to to NIA) to NIA) NIA) B2 General 36 (Gross 243 (based 140 175 (based 237 Internal Area) on total GEA (based on on total (based on converted to total GEA GEA total GEA GIA) converted converted converted to to GIA) to GIA) GIA) B8 Storage and 70 (Gross 139 80 100 135 Distribution External Area) To calculate the net internal area conversion the following allowances have been made - gross external is typically 10% higher than gross internal, and gross internal is typically up to 20% higher than net internal space (HCA, 2015)

Table 1 shows that these strategically important sites have the potential to both help meet employment floorspace targets enshrined within the Local Plan, and consequently also have the potential to accommodate a very significant number of new jobs. This is in stark contrast to the lack of detail as to the exact nature and scale of waste facilities proposed first in terms of land take and second, future job creation both in terms of employment numbers and skill levels. Although there are no specialist studies indicating a consistent relationship between volumes of waste and numbers of jobs, there is general agreement that the most labour- intensive activities are manual sorting, some separate collection processes and waste and scrap wholesale. The least labour-intensive activities include for example composting, together with most forms of collection. Other data indicate that waste management jobs are mainly low-skilled and low-paid. The poorest quality jobs appear to be in collection and transport, manual sorting and composting. Higher-quality jobs are associated with the more technology-intensive, specialised activities.

Concerns regarding job numbers are certainly borne out when considering existing waste management facilities in Hastings and those proposed elsewhere in Sussex and contrast sharply with job numbers associated with B use class developments shown in Table 1. At one end of the scale Sussex Waste Management Ltd occupies a 0.9Ha site in Hastings and employs c.9 people but the development of a waste facility at the former Wealden Brickworks site, Langhurstwood Road, Horsham which would manage up to 200,000 tonnes of mixed commercial, industrial and municipal wastes per annum is expected to create only 12 full-time jobs. Our research suggests that employment densities range from 1 worker per 80m2 to 1 worker per 160m2; that such operations are land hungry; and for the building floorspace to be operational, 3 to 4 times as much outdoor space is needed. More technologically led waste operations tend to create fewer jobs on site. Appendix G

Table 2: Job density numbers arising from Waste Operations Facility Floorspace Site Job m2 Area numbers (FTEs) Proposed waste transfer facility to handle inert and non- 9,934 3.12 12 inert waste with associated open air inert waste recycling operations, landscape improvements and vehicle parking Change of use from storage and distribution (former 2,845 1.13 23 FTE & builders merchant depot) to waste recycling facility (sui 4 part time generis) including the erection of a storage building and modular building, and installation of solar panels Operation of a Waste Transfer Station and Materials 1,925 0.69 25 Recycling Facility to process mixed skip waste including the construction of a 1925 m2 building, concrete pad and drainage infrastructure Proposed development and operation of a waste treatment 9,645 5.40 60 facility, New Circular Technology Park Data taken from waste related development proposals in West Sussex Appendix H

Hastings Local Plan, Hastings Planning Strategy 2011-2028 (adopted 19 February 2014) http://www.planvu.co.uk/hbc2015/contents_written.htm

Hastings Local Plan, Development Management Plan (adopted 23 September 2015) http://www.planvu.co.uk/hbc2015/contents_written.htm

Hastings Local Plan, Policies Map, Development Management Plan (adopted 23 September 2015) (incorporating Planning Strategy Policies adopted 19 February 2014) http://www.hastings.gov.uk/planning/policy/adoptedlocalplan/policies/