Hastings Local Development Framework – Core Strategy Informal Consultation Please give us your views on changes to our draft plan which sets out how the town will grow and develop up to 2028

27 June – 8 August 2011

Planning Policy Team www.hastings.gov.uk/ldf A large print or audio version of this document is available on request. Please call 01424 451098.

Contents

1.0 INTRODUCTION AND BACKGROUND ...... 3

2.0 HOW TO COMMENT ...... 5

3.0 HOW MANY NEW HOMES?...... 6 Housing provision...... 6

4.0 SIGNIFICANT POLICY CHANGES...... 8 Affordable housing ...... 8 Accommodation for travelling communities...... 10 Housing in multiple occupation...... 11 Creating Sustainable Communities ...... 12 Green Infrastructure and Open Space ...... 13 Nature conservation and biodiversity ...... 13 Promoting good design ...... 14 Low carbon development ...... 15 Heat density opportunity areas...... 16 Community Infrastructure ...... 16 Town Centre Retail Strategy ...... 17

5.0 SPATIAL STRATEGY ...... 20 Planning Focus Areas ...... 20 Proposed spatial spread of housing development ...... 22 Proposed spatial spread of employment, office and retail development...... 22

6.0 DRAFT INFRASTRUCTURE DELIVERY PLAN ...... 25 Introduction...... 25 Objectives and outcomes...... 25 Policy Context ...... 26 The type of infrastructure covered by this IDP ...... 26 The process of preparing the IDP ...... 26 Infrastructure Requirements...... 27 Infrastructure Delivery ...... 35 Monitoring...... 36

7.0 THE INFRASTRUCTURE DELIVERY SCHEDULE...... 37

APPENDIX A – FUTURE HOUSING PROVISION IN HASTINGS ...... 47 1.0 Introduction...... 47 2.0 Why we need more housing in Hastings? ...... 47 3.0 Levels of Housing Growth Considered ...... 51 4.0 Conclusions and Recommendations ...... 54

APPENDIX B – SUSTAINABILITY APPRAISAL (SA) OF HOUSING TARGET ...... 56 1.0 SA Introduction...... 56 2.0 Sustainability Appraisal (SA) of Scenarios ...... 57 3.0 SA - Analysis of Scenarios ...... 64 4.0 SA - Conclusion and Recommendations...... 66

2 1.0 Introduction and Background

1.1 The Council is preparing a new plan for how the town will change and develop over the period up to 2028. We’ve rolled the Plan forward by 2 years to 2028 because the Government says we need to identify enough sites and broad locations for development to deliver housing for at least 15 years from the date of the adoption of the plan.

1.2 This is your opportunity to say what you think about how the Plan is shaping up and to highlight any things you particularly agree with or which you think we have missed or got wrong.

1.3 This is an informal consultation – we are not obliged by law to consult or involve you in plan making at this stage, however, as there have been lots of changes to the planning system since we last consulted on our Preferred Approaches in 2008, we are now asking for your views on changes and new parts of the Plan.

Changes since 2008

1.4 We want your views on 3 main areas of change. Each of these is explained in more detail later in this document:

1. How many new homes?

1.5 The Government has advised that it intends to abolish the regional plan for the area (known as the South East Plan), and that when this happens it will be down to local planning authorities, like Hastings Borough Council, to determine and justify housing targets themselves. Therefore, we have set out a locally determined target that 3,418 new homes (201 per year) should be provided in the town between 2011 and 2028.

2. Significant policy changes

1.6 There have been several changes to policies, or new policies added, since the previous consultation on the Local Development Framework (LDF) Core Strategy Preferred Approaches in 2008 - these include:

• A revised affordable housing policy • a policy setting out the criteria against which planning applications for gypsies, traveller and travelling showpeople accommodation will be judged by the Council • a policy to control the spread of houses in multiple occupation (HMOs) • climate change, design, flood risk, green infrastructure and biodiversity policy changes, grouped together under the heading “sustainable communities” • policies on planning for renewable and low carbon energy • a strategy to show how we could accommodate retail growth in the town centre • a draft infrastructure delivery plan and schedule setting out what will be needed by way of school places, doctors, open space, transport improvements etc to support the levels of growth being planned

3 3. Spatial strategy

1.7 We have divided the town into 13 planning focus areas and set out the level of development planned for in each area, up to 2028. This makes it clear where major growth and change could happen in the town.

1.8 The Core Strategy must remain focussed on strategic issues. The more detailed issues such as protection of individual wildlife sites and open spaces, or allocation of specific areas of land for housing or employment development will be addressed through the Site Allocations and Development Management Plan, which will provide further opportunities for public involvement. Full details of the timetable for this are available at No longer available online.

4 2.0 How to comment

2.1 We would like your comments on the proposed targets, policies and strategies highlighted throughout the document referenced A to N along with the Draft Infrastructure Plan and Schedule at Sections 6 and 7.

2.2 To ensure comments are properly recorded and interpreted we would like you to make them online, or where this is not possible, using our official response form.

2.3 Your response can be made directly through our website at http://www.hastings.gov.uk/ldf/consultation.aspx. This includes instructions on how to comment.

2.4 This is primarily an online consultation although copies of the consultation material and official response form are available to pick up from Hastings Information Centre in Queens Square or Planning Reception in Aquila House during opening hours.

2.5 Consultation packs containing the document and official response form can also be obtained by telephoning 01424 451098 during office hours.

2.6 Updates and links will be posted on Twitter, and you can also find Shaping Hastings on Facebook.

Deadline for responses

2.7 The consultation is open from 27 June to 8 August 2011. All comments must be received by 4pm on Monday 8 August 2011.

What we will do with your responses

2.8 We will analyse all responses and prepare a report showing how they have been taken into account, and, where relevant, how we are changing the plan as a result. This will be reported to the Council’s Cabinet in November 2011 and will be made available on the Council’s website.

Will there be any more opportunities to comment on the plan?

2.9 Following this informal consultation we will prepare the final version of the plan, called the ‘Proposed Submission Version’ which will cover the issues contained in our Preferred Approaches and the changes consulted upon here. This is the document we will submit to an independent Planning Inspector for the next stage in the process – the ‘Examination in Public’.

2.10 The Council’s Cabinet is due to consider the Proposed Submission Version of the Plan in November 2011. Following that there will then be the opportunity for you to make ‘representations’ on the Plan between December 2011 and January 2012.

2.11 These representations will be considered by an independent Inspector and help him/her decide on the themes for the Examination in Public. We will provide plenty of publicity about this when the time comes, but if you would like more information about the examination process in the meantime, please go to: http://www.planningportal.gov.uk/planning/planningsystem/localplans

5 3.0 How many new homes?

Housing provision – What has changed?

3.1 Now that the Government is planning to withdraw the South East Plan there is an opportunity for Hastings to review its housing target.

3.2 In line with the Government’s localism agenda, it is now up to local authorities, working with their communities, to decide how many homes should be built in their area. It will still be necessary for us to justify whatever housing target is chosen and to be able to defend the target figure and future housing supply policies during the formal Examination process for our own local plan (the Local Development Framework Core Strategy). Previously the South East Plan dictated that 4,200 new homes should be built in Hastings between 2006 and 2026.

Getting more detail

3.3 This is only a summary of how we’ve arrived at our recommendation. More detail can be found in our background paper “Future Housing Provision in Hastings” (2011), at Appendix A.

Do we actually need a target?

3.4 As part of the LDF process we have a duty to assess future demand for new homes and to plan for it. The Government says that we still need to identify enough sites and broad areas for development to deliver enough new homes for at least 15 years from the adoption of our Plan and to have a five year constant supply of deliverable sites.

What factors do we need to consider?

3.5 Future housing development is a critical part of the regeneration and growth agenda for the town and in deciding on the number of new homes we need to plan for, we need to consider:

• the need/demand for housing to help support regeneration efforts • the level of housing need and affordability issues within the town • the demand for new housing arising from population and household change and growth • the quality and mix of the existing housing stock, and • the amount of land available in the town that new homes could be built on

What we recommend and why

3.6 The housing target we are recommending for the period 2011 to 2028 is 3,418 net new homes (201 per year). This is broadly in line with the South East Plan figure. Net new homes are the total overall change after demolitions, change of use and redevelopment have been taken into account.

3.7 Although the Government plans to abolish the South East Plan, there is still a significant body of evidence underpinning the housing numbers in it. Our research indicates that a target of 3,418 net new homes will support regeneration, whilst respecting the town’s environmental assets – which includes areas of wildlife, landscape, and recreation importance. The starting

6 point for this figure is one based on the amount of development that is already in the pipeline (that is, sites already under construction, with planning permission, or already allocated for development). New sites together with some reliance on windfall1 development will still be needed. The Strategic Housing Land Availability Assessment (SHLAA) 2 provides evidence that this target can be met.

What other possibilities have been considered?

3.8 We have considered higher and lower growth scenarios. If we look at population projections alone, this would result in a need to build many more new homes than previously thought possible – some 7,840 new homes by 2028 or 461 per year. Building at this level would require more high density development, and there would be far more pressure to build on undeveloped (Greenfield) land and in environmentally sensitive areas.

3.9 We have also considered a lower level of growth. This would result in approximately 1000 fewer new homes than the level we are recommending. As well as reducing our ability to address some of the demand for general market housing, it also means fewer affordable homes for people to live in, since the delivery of both are closely linked. It reduces our ability to promote housing choice – helping us to create opportunities for younger people to remain in the town, provide more family sized and larger homes and helping to attract more skilled workers to Hastings.

3.10 We have also carried out a Sustainability Appraisal to determine the likely effects of each scenario on our social, environmental and economic objectives. This is explained in more detail in Appendix B of this document.

Conclusions

3.11 We think the best way forward is to have a housing target that allows us to maximise and support the following issues without increasing the pressure to build in the town’s most environmentally sensitive areas:

• The need to provide housing to support regeneration, economic and skills growth and development in the town • That we wish to promote choice around housing, encouraging higher skilled people to move into the Town and creating opportunities for younger people to remain in Hastings. This includes providing more family homes and larger sized dwellings • The need to provide more affordable housing • The need to achieve a balance between meeting other competing land use requirements – chief among these is land required for creating jobs

A: Proposed Target – Housing Provision

Between 2011 and 2028 it is recommended that the net new homes target for Hastings should be 3,418 or 201 new homes per year.

1 Windfall sites are those which have not been previously identified as available for development. 2 http://www.hastings.gov.uk/ldf/shlaa.aspx

7 4.0 Significant Policy Changes

Affordable housing - What has changed?

4.1 The ongoing provision of affordable housing is a priority in the town. Affordable housing is defined as housing available to those who are unable to access accommodation suitable for their families’ needs, at a price that they can reasonably afford on the open market, whether for rent or home ownership. It should be available at a cost low enough to be afforded by eligible households, and is determined with regard to local incomes and house prices

4.2 The 2008 Preferred Approaches document included a development threshold (15 or more dwellings) at which the proposed affordable housing policy would have been applied. Our latest research (Housing Sites Viability and the Impact of Affordable Housing Study, March 2011) however, shows that a lower threshold will allow the Council to secure affordable housing provision on a significant number of sites that at present escape any affordable housing contribution. Consequently it should result in more affordable housing being delivered. This study is available to view or download at http://www.hastings.gov.uk/ldf/evidence.aspx

4.3 Our revised policy approach now looks to smaller sites to make a contribution to affordable housing provision, and includes an option of financial contributions instead of on site provision in certain circumstances. The money from this will be ring fenced for additional affordable housing - providing a useful source of matched funding for partnership schemes.

4.4 In the current economic climate this will be a useful way of maximising housing delivery outcomes. However, it must be acknowledged that due to viability issues and the range of difficult to develop sites in the town, there will be a need to negotiate levels of affordable housing/ financial contributions on individual sites.

4.5 This is a complex planning issue and a Supplementary Planning Document will be prepared to provide advice and guidance to developers on how the policy will work in practice.

B: Proposed Policy – Provision of Affordable Housing

a) Housing developments on previously developed land (Brownfield) should make the following provision for affordable housing:

Site size range Minimum On-site Or, financial (number of net percentage provision contribution in dwellings) requirement required? lieu of on-site Yes/No provision? Yes/No 1-4 10% financial No Yes contribution 5-14 20% Yes Yes 15+ or 0.5 ha or more 25% Yes No in size (irrespective of the number of dwellings)

8 b) Housing developments on Greenfield land should make the following provision for affordable housing:

Site size range Minimum On-site Or, financial (number of net percentage provision contribution in dwellings) requirement required? lieu of on-site Yes/No provision? Yes/No 1-4 20% financial No Yes contribution 5-9 20% Yes Yes 10-14 40% Yes Yes 15+ 40% Yes No

c) Affordable housing will be provided on the application site, except where the development involves 4 or less units where, a financial contribution will be required. However, where the Council determines that off-site provision can provide an equivalent or better housing solution, off-site provision or a financial contribution in lieu of on-site provision (of at least equivalent value) may be invited. This will only be done where the agreed approach contributes to the creation of mixed communities elsewhere in Hastings. This may be particularly relevant in situations referred to in paragraph (d) where a better tenure or housing mix can be achieved.

d) The type and level of provision on individual sites will be determined through negotiations – taking into account market conditions. The Council’s preferred approach is for the greater part of affordable housing to be for affordable rent, although other forms may be acceptable where they would complement wider strategic priorities for tenure diversification. Schemes should enable the provision of different forms of affordable housing where necessary, avoiding the over concentration of any one tenure.

e) The Council will work with the private sector and registered social providers to achieve the required level of affordable housing. If it can be demonstrated, by transparent financial evidence, that the full affordable housing contribution makes a site unviable, developers and the Council will work through a cascade3 approach until a site is made viable, whilst still retaining an element of affordable housing.

f) Due to the on-going level of need in the Borough, affordable housing will normally take precedence over other types of planning contributions.

g) If an allocated site comes forward as two or more separate development schemes, the Council will seek a level of affordable housing on each part to match, in total, the provision that would have been required for the site as a whole. h) Affordable homes must be well integrated within the development scheme and be indistinguishable from other tenures in terms of style,

3 Through reductions in other planning contributions, changes to the mix, tenure or number of affordable dwellings or by the payment of commuted sums in lieu of provision, the site becomes viable.

9 location and build quality, small clusters of affordable housing would be preferred.

i) Homes should remain at an affordable price for future eligible households, or if these restrictions are lifted, for the development subsidy to be recycled for alternative affordable housing provision.

j) Reflecting the targets in a) and b) as a guide, the proportion, size and form of affordable housing will, where appropriate, be indicated for each housing site proposed in the Site Allocations and Development Management Plan.

k) Windfall sites4 will also be subject to this policy, as will planning applications for conversions and/or change of use which result in additional units of accommodation.

This policy will be supported by a Supplementary Planning Document giving further information together with details of Section 106 requirements.

Accommodation for travelling communities - What has changed?

4.6 This is a new policy that has been included in the Plan. It sets the criteria that will be used to assess planning applications for accommodation for Gypsies, Travellers and Travelling Showpeople. Any proposals for individual residential plots will be assessed against this policy.

C: Proposed Policy – Accommodation for travelling communities

In assessing the suitability of sites for allocation for permanent residential sites for Gypsies and Travellers, and for the purposes of considering planning applications for sites for Gypsies, Travellers and Travelling Showpeople, proposals will be supported where the following criteria are met, the site should:

a) respect areas of high conservation or ecological value b) be acceptable in respect of vehicular access and parking c) achieve a reasonable level of visual and acoustic privacy for both people living on the site and for those living nearby d) be accessible to local shops, services, schools and healthcare facilities, by walking, cycling, and public transport e) avoid locations where there is a risk of flooding, and is not adjacent to a potentially incompatible neighbouring use

In the case of sites for Travelling Showpeople, site suitability assessment will also take account of the nature and scale of the Showpeople’s business in terms of the land required for storage and/or the exercising of animals

4.7 In April 2011, the Government published draft guidance on “Planning for Traveller Sites”. This makes it clear that local planning authorities should set pitch and plot targets that address the likely permanent and transit site

4 Windfall sites are those that have not previously been identified as available for development

10 accommodation needs of travellers in the light of historic demand and through consultation with travellers and their representative bodies.

4.8 We will undertake this type of assessment and set any targets as part of the preparation of the Site Allocations and Development Management Plan.

Housing in multiple occupation - What has changed?

4.9 We need a new policy on Housing in Multiple Occupation (HMOs) to support the council’s licensing schemes for HMOs, and to provide a basis for planning decisions. This will also support the Council’s recent decision to take away permitted development rights for dwelling houses to change to small HMOs.

What is a HMO?

4.10 In planning terms, a HMO is defined according to size. It could be a shared dwelling house occupied by between 3 and 6 unrelated people who share basic amenities such as a bathroom and/or kitchen (this is known in planning terms as Use Class C4). Larger shared houses occupied by 7 or more unrelated people are considered to be “sui-generis” use, a term given to the uses of land or buildings, not falling into any of the other use classes identified by the Use Classes Order.

4.11 There are already high numbers of HMOs in the town. The 2007 Private Sector Housing Condition Survey noted that HMOs represent 8.1% of the private sector housing stock, compared with 2% or less in the other East Sussex Districts and 2% nationally. Further 85% of HMOs are concentrated in Braybrooke, Gensing, Central St Leonards and Castle wards.

4.12 It is likely that the number of HMOs in the town as a whole will increase, driven by increasing student numbers as a result of the new University campus, changes to housing benefit and the increase need for smaller affordable units of accommodation.

4.13 While we recognise that shared housing is important in meeting the needs of some residents, we also recognise the negative effects that high concentrations of this type of housing may have on local communities.

4.14 We want to make sure that in the future, local communities are mixed and balanced in terms of both the type of housing available, tenure, and the people that live there. We do not want to see situations where more neighbourhoods become dominated by shared housing.

D: Proposed Policy – Houses in multiple occupation

In order to support mixed and balanced communities and maintain an appropriate housing mix within the Borough, applications for changes of use from:

• a Class C3 (dwelling house) to a Class C4 (House in Multiple Occupation), or;

• a Class C3 (dwelling house) to a House in Multiple Occupation in a sui generis use (more than six people sharing)

11 will not be permitted where:

• more than 10% of the total numbers of properties within a 100m radius of the application property are already in use as either Class C4, mixed C3/C4 use or other types of HMO in a sui generis use.

In all cases regard shall be had to the following factors:

a) Whether the proposals would lead to a level of car-parking that would exceed the capacity of the street; b) Whether the proposals could provide acceptable arrangements for bin storage and other shared facilities; and c) Whether the design of any extension would be appropriate in terms of the property itself or the character of the area.

This policy will not apply to applications for social housing, care homes, children’s homes, bail hostels and properties occupied by students that will be managed by an educational establishment.

This policy will not apply to households who have foreign students staying as guests for a set period of time.

Creating Sustainable Communities - What has changed?

4.15 Our earlier consultation grouped several environmental policies under one heading – Environmental Sustainability and Design. This has now been more appropriately re-named “Creating Sustainable Communities”, and is supported by an overall strategy policy for the management of change in a sustainable way.

4.16 Flood risk, open space and landscape protection policies have not changed to such an extent that further consultation is required.

E: Proposed Policy – Strategy for managing change in a sustainable way

Growth and change will be managed so that development meets sustainability objectives, avoids significant vulnerability to the impacts of climate change, supports the diverse needs of communities and provides vibrant, safe, healthy and inclusive places where existing and future residents want to live and work. This will be achieved through:

a) meeting housing needs of all sectors of the community, including the provision of affordable housing b) providing access to education, training and jobs and supporting the creation of new enterprises to bring economic prosperity and greater self-sufficiency c) supporting the social, economic and environmental regeneration of disadvantaged areas and communities d) enhancing the cohesion and vitality of communities, providing neighbourhoods with a vibrant mix of flexible and compatible uses, services and community facilities

12 e) providing accessible forms of development that reduce the need to travel by car and are integrated with public transport and other sustainable modes of travel to allow for ease of movement and provide safe environments f) managing flood risk and reducing the potential effects of climate change on future communities g) requiring high quality architecture and urban design which adds to local character and sense of place h) reducing opportunities for crime and disorder through innovative design and the clear distinction of public and private space i) the provision of an accessible greenspace network and protection and enhancement of biodiversity j) protecting against light, air, water, land and noise pollution. k) supporting the move to a low carbon economy

Green Infrastructure and Open Space – What has changed?

4.17 This is a new policy, developed to take on board best practice advised by Natural England.

4.18 The network of green spaces (also known as the green infrastructure network) which includes open spaces, woodlands, wildlife habitats, parks, recreation areas, beach and other natural areas that provide multiple social, economic and environmental benefits. The protection, management and enhancement of this network is especially important in a dense urban area like Hastings.

F: Proposed Policy – Green Infrastructure

In recognition of the multifunctional role of our greenspaces, a green network comprising open space and nature conservation areas will be established to conserve and enhance priority natural areas, and the connections between them.

The network will ensure that everyone has access to natural open space, and will maximise opportunity to conserve and enhance biodiversity. New development will contribute to this network

The extent of the network will be established in the Site Allocations and Development Management Plan, and will be clearly shown on the Local Development Framework Proposals Map.

Nature conservation and biodiversity – What has changed?

4.19 The proposed policy has been amended in light of the responses received through our last consultation. It is now more relevant to local circumstances, and is clearer and more focused.

G: Proposed Policy – Nature conservation and improvement of biodiversity

The town’s biodiversity and geological resources will be protected and enhanced. Priority will be given to:

13 a) Protection of the integrity of the Hastings Cliffs Special Area of Conservation (SAC), and other European sites near the town b) Conserving and enhancing protected biodiversity and geodiversity sites and features including Sites of Special Scientific Interest, Local Nature Reserves, and Local Wildlife Sites, ensuring that unavoidable damage to biodiversity is minimised through mitigation, that any damage is compensated for, and that such measures are monitored. c) Improving the integrity and biodiversity of the green infrastructure network, d) Minimising potential impacts of new development on the Hastings Cliffs SAC through the delivery of new greenspace and through appropriate recreation management of Hastings Country Park to meet the European regulations e) Meeting the objectives and targets in the Hastings Local Biodiversity Action Plan and habitat restoration and creation in Biodiversity Opportunity Areas f) Protecting ancient woodland and veteran trees g) Strengthening populations of protected and target species h) Improving site management and increasing public access to wildlife i) Influencing and applying agri-environment schemes, forestry, flood defence and other land management practices to deliver biodiversity targets

Promoting good design – What has changed?

4.20 Our approach to ensuring good design was previously set out under the heading “Sense of Place and Local Identity”. Whilst still requiring design quality to be assessed through the “Building for Life Standards”5, we are now proposing a revised policy that takes account of the broader issues associated with good design and the need to mitigate against, and adapt to, climate change.

H: Proposed Policy – Promoting good design

All development must be designed to:

a) respect or enhance the character and street layout of the local area to contribute to the sense of place and local distinctiveness b) incorporate high quality design features and layouts that will reduce crime and the fear of crime and support inclusive communities, particularly in terms of accessibility and functionality. This includes creating opportunities for street play as part of residential developments c) incorporate appropriate climate change mitigation and adaptation measures such as green roofs and walls, sustainable drainage systems, multi-functional green space, protecting and enhancing biodiversity, waste reduction, recycling facilities and flood risk management d) enable a low carbon future in a changing climate by supporting proposals involving micro-generation technologies such as domestic wind turbines and solar panels and for retro-fitting existing properties to make them more energy efficient

5 http://webarchive.nationalarchives.gov.uk/20110107165544/http:/www.buildingforlife.org/

14 e) be adaptable and accessible to all

Design and access statements accompanying planning applications should demonstrate the evolution of the design prior to submission, the rationale behind the scheme, and how it meets the above criteria.

To assess design quality in major planning proposals for new homes (10 or more dwellings), the Council will require the applicant to address the 20 questions that make up the Commission for Architecture & the Building Environment (CABE) and the Home Builders Federation “Building for Life” standard6. We will expect schemes to score 14 and above. Planning permission will normally be refused for schemes that score less than 10 out of 20 in the assessment.

Low carbon development – What has changed?

4.21 Low carbon development and renewable energy policies have been separated out from the new “Sustainable Communities” chapter in order to make our approach clearer and easier to understand.

4.22 The revised policy has removed the requirement to adopt a London Borough of Merton approach in new development, where all new commercial development over 1000m2, or residential development of 10 or more dwellings, was expected to provide at least 10% of the energy requirements from onsite renewable energy generation. The requirement for all large scale development to meet at least Level 3 of the Code for Sustainable Homes, or equivalent BREEAM standards7, subject to viability has also been removed.

4.23 These changes have come about as a result of changing Government Guidance, and recommendations in the Hastings Renewable and Low Carbon Energy Study (2009), available at http://www.hastings.gov.uk/ldf/evidence.aspx The study did not identify any sites as being suitable for exceeding national standards for sustainable building set by either the Building Regulations or the Code for Sustainable Homes. Our revised policy therefore, concentrates on how best to achieve low carbon development in line with requirements set by the Code for Sustainable Homes and the step-by-step tightening of the Building Regulations. The national timetable for this is as follows:

Year Target Private Public Sector Sector 2008 The Code became mandatory 1 May 2008 Rating now Level 3 mandatory mandatory 2010 Code Level 3 - A 25% improvement in energy Level 3 Level 4 efficiency compared to Part L of the Building mandatory mandatory Regulations 2006 2013 Code Level 4 – A 44% improvement in energy Level 4 Level 6 efficiency compared to Part L of the Building mandatory mandatory Regulations 2006 2016 Code Level 6 – Zero Carbon homes Level 6 Level 6 mandatory mandatory

6 http://www.designcouncil.org.uk and search for ‘Building for Life’ 7 http://www.breeam.org/

15 I: Proposed Policy – Low Carbon Development

The energy hierarchy sets out the most suitable and cost effective method of achieving low carbon development. Developers are required to follow the hierarchical approach in achieving the energy and carbon dioxide emission requirements of the Building Regulations, for all new residential development. New non-residential development is encouraged to follow the same approach8

1. To improve energy efficiency through thermal and fabric performance improvement measures, then:- 2. Provide on site renewable energy generation or onsite connected heating, or Combined Heat and Power (CHP) technologies, then:- 3. The remainder of the CO2 reduction targets to meet the Building Regulations targets should be met through suitable additional measures such as larger CHP or district heating systems or Mega Watt (MW) scale wind offsetting.

Developers will be required to demonstrate compliance with this policy approach through design and access statements submitted with a planning application.

Heat density opportunity areas – What has changed?

4.24 This is a new policy area, resulting from the recommendations in the Hastings Renewable and Low Carbon Energy Study (2009).

J: Proposed Policy – District heating networks and combined heat and power systems

To help meet the Government’s timetable to deliver zero carbon homes and buildings, Hastings Borough Council will explore opportunities for Combined Heat and Power systems connected to district heating networks in the vicinity of the Conquest Hospital, Summerfields Sports Centre, and Hastings town centre. Opportunity areas will be identified in the Site Allocations and Development Management Plan.

Community Infrastructure – What has changed?

4.25 We have introduced a more comprehensive infrastructure policy, based on extensive consultation with key service providers and information in our Draft Infrastructure Delivery Plan. This is to ensure that the right infrastructure is in place at the right time to meet the needs of the town, and that providers are clear as to their role in implementing the proposed policies.

4.26 The Draft Infrastructure Delivery Plan and Infrastructure Delivery Schedule are set out in sections 6.0 and 7.0 of this document.

8 Developers are referred to the Government’s timetable for non-domestic zero carbon development, and are encouraged to follow the same hierarchical approach http://www.communities.gov.uk/publications/planningandbuilding/newnondomesticconsult

16 K: Proposed Policy – Infrastructure and developer contributions

The Council will seek to ensure that the right infrastructure is in place at the right time to meet the needs of Hastings and will secure developer contributions from new development towards the necessary provision of environmental and social infrastructure. This will be achieved through the following:-

1. Preparing, regularly updating and facilitating the implementation of an Infrastructure Delivery Plan for the town. This will set out the infrastructure to be provided in Hastings by infrastructure partners, including the public sector and utilities, to meet future needs.

2. Mitigating inadequacies in infrastructure arising from proposed development through development contributions that will provide towards sufficient and appropriate improvement through upgrade, enhancement or new infrastructure.

3. Contributions will relate to all aspects of land use, community infrastructure and services that may be directly related to the development proposed and which accord with the council’s identified local priorities and objectives for delivering sustainable communities.

Further detailed guidance on the circumstances and range of developer contributions that may be sought from development will be set out in an Infrastructure Delivery Supplementary Planning Document (SPD) which will establish a sound basis and methodology for agreeing the level and type of infrastructure requirements necessary from developer contributions.

Town Centre Retail Strategy – What has changed?

4.27 The 2010 retail needs assessment update, available from http://www.hastings.gov.uk/ldf/evidence.aspx identified a requirement for an additional 30,000m2 of comparison goods floorspace in the town up to 2026 (comparison goods are non- food items like books, clothes, shoes etc). This study is now being updated to reflect new population forecasts, and to take into account the impact of the current economic downturn.

4.28 In 2010 an assessment was made of the potential within the town centre to accommodate this level of growth. This revealed only a small number of infill sites which could potentially provide additional floorspace, but not on the scale required by the study.

4.29 Given that the indications are that the new study is likely to revise the forecasted need downwards, and further into the future, the Council intends to deal with this uncertainty by drawing a clear boundary round the town centre, within which development for additional comparison goods floorspace will be encouraged. It will then be down to market forces to determine when, and if, the economic situation is right for such a development, and at the same time the boundary will give developers a clear steer about the area where such development would be encouraged.

17 4.30 St Andrews Square will not be included in the area where we will be looking to accommodate this additional retail development, based on previous research and consultation with the community.

L: Proposed Policy – Retail boundary

The following plan shows the proposed town centre retail boundary.

18 19 5.0 Spatial Strategy

Planning Focus Areas

5.1 To provide a more local perspective and sense of place in the Core Strategy, the town has been divided into a number of planning focus areas - these are broad areas where there is an identifiable community or geography, or where landscape and function means they make a logical area for spatial planning. In some cases they are areas which have common problems and issues. The boundaries have been drawn as close as possible to Super Output Area (SOA) boundaries, as this is the geography used for presentation of important statistics such as the Index of Multiple Deprivation and the Census data. These areas will provide a useful framework setting the scene for the preparation of the more detailed Site Allocations and Development Management Plan, and any Neighbourhood Plans which may be produced by the community.

5.2 The following 13 areas have been identified. Please note the boundaries of the areas are not part of the consultation as they have been developed to reflect the issues set out in 5.1 above.

1. Little Ridge and Ashdown 2. Greater Hollington 3. Filsham Valley and Bulverhythe 4. St Helen’s Wood 5. Silverhill and Alexandra Park 6. Maze Hill and Burtons’ St Leonards 7. Central St Leonards and Bohemia 8. Hastings Town Centre 9. Old Town 10. West Hill 11. Hillcrest and Ore Valley 12. Clive Vale and Ore Village 13. Hastings Country Park

5.3 Each of these is shown on the following map

20 21 Proposed spatial spread of housing development

5.4 Future housing growth in Hastings is likely to be spread across the town – there are no major strategic sites of 200 units or more. The pattern of development proposed below is based on an update of the Strategic Housing Land Availability Assessment at April 2011 – an assessment of the deliverability, developability and availability of land for housing available at http://www.hastings.gov.uk/ldf/shlaa.aspx.

5.5 The majority of new housing will come from sites already allocated in the 2004 Local Plan, and from sites which already have planning consent. This is a direct reflection of the built up nature of the town, with relatively few opportunities for new allocations. Windfall development will also be a significant source of future housing development. Windfall development occurs where a site has not been previously identified as being suitable for housing development and mainly comes about due to redevelopment and changes of use. Analysis of past windfall development shows that it tends to occur mostly in the inner, more densely developed parts of the town.

5.6 Hastings has a relatively large stock of empty homes and the Council is taking action through its Compulsory Purchase powers to bring a number of these back into use each year – this is an issue which local communities have said they want to see addressed. An allowance for the return of empty homes back into use has also been incorporated into the housing figures.

5.7 The Core Strategy is concerned with strategic issues such as the overall distribution of development – there will be the opportunity to comment on individual housing sites when work starts on the Site Allocations and Development Management Plan later this summer

5.8 The table ‘M - Proposed spatial spread of housing development’ on the following page, shows how much housing development could take place in each of the 13 areas up to 2028.

5.9 For each of the areas, the amount of new homes is expressed as a range. This takes account of development in the pipeline, potential new sites and an allowance for both windfall development and the return of long term empty homes back into use. The Core Strategy is required to be flexible and to be able to deal with changing circumstances. The use of the range introduces significant flexibility but at the same time indicates where it is expected that development is likely to be accommodated in the Borough. The detailed allocation of all types of sites, including housing, will follow in the Site Allocations and Development Management Plan.

5.10 We will monitor housing completions against the overall target. If the rate of completions is falling below acceptable levels, we will carry out a review of housing sites to identify any barriers to delivery and work with the development industry to bring forward sites.

Proposed spatial spread of employment, office and retail development.

5.11 The table on page 24 sets out where the major growth in employment related development is planned to occur in the period up to 2028. Hastings town

22 centre will continue to be a focus for change and growth; along with infill and extension opportunities at some of the town’s existing employment estates.

M – Proposed spatial spread of housing development

Area Name Potential range of dwellings by Area 1 Little Ridge & Ashdown 210 – 310 2 Greater Hollington 230 – 350 3 Filsham Valley and Bulverhythe 580 - 720 4 St Helen’s Wood 190 - 290 5 Silverhill & Alexandra Park 210 - 310 6 Maze Hill and Burtons’ St Leonards 240 - 360 7 Central St Leonards 390 - 550 8 Hastings Town Centre 220 - 320 9 Old Town 60 - 80 10 West Hill 60 - 80 11 Hillcrest and Ore Valley 400 - 600 12 Clive Vale and Ore Village 220 - 340 13 Hastings Country Park 0

23 N – Proposed spatial spread of employment, office and retail development

Area Name Sq metres of additional (net) Sq metres of additional (net) Sq metres of additional employment land up to 2028 office (B1a) development up to (net) retail comparison Mixed B1, B2 & B8 2028 floorspace between 2014 and 2028 1 Little Ridge & Ashdown 23,400m² (at Queensway & Whitworth Rd) already allocated in the 2004 Local Plan 2 Greater Hollington 13,300m² (at Churchfields, Castleham & Ponswood Industrial Estates) already allocated in the 2004 Local plan 3 Filsham Valley and Bulverhythe 4 St Helen’s Wood 5 Silverhill & Alexandra Park 6 Maze Hill and Burtons’ St Leonards 7 Central St Leonards 8 Hastings Town Centre 21,700m² (the remaining phases Up to 30,000m² of of the Priory Quarter development comparison retail space - potential new allocation) (potential new allocation) in town centre 9 Old Town 10 West Hill 11 Hillcrest and Ore Valley 11,400m² (at Ivyhouse Lane Industrial Estate) already allocated in the 2004 Local plan 12 Clive Vale and Ore Village 800m² (Land to rear of 430-438 Old London Road, Graystone Lane 13 Hastings Country Park

24 6.0 Draft Infrastructure Delivery Plan

Introduction

6.1 The draft Infrastructure Delivery Plan (IDP) for Hastings supports the town’s Local Development Framework (LDF) Core Strategy, which covers the planning period from 2012 to 2028. At the time that consultation with infrastructure providers was undertaken it covered the period 2006 to 2026. This timescale has therefore been retained but will be updated at the first review of the IDP. The Core Strategy must be supported by evidence of what physical, social and environmental infrastructure is required to enable future growth and development to take place.

6.2 The provision of necessary infrastructure alongside new housing and employment development is required to create and maintain sustainable communities. Additional physical infrastructure in the form of utility services, transport, schools, open space, community, health and leisure services is necessary to support the expanding local population, create balanced growth and provide for those who visit or work in the Borough.

6.3 The IDP consists of a written statement and a schedule which identifies the key pieces of infrastructure that are required in Hastings; when they are required; who is responsible for their provision; their cost, if known and how they will be funded (Section 7). The IDP draws on, and influences the investment plans, of a wide range of infrastructure providers, including the Borough and County Councils. It will help to co-ordinate public and private investment in Hastings.

6.4 Hastings Borough Council is working with other Local Authorities in East Sussex to explore the implications of Community Infrastructure Levy (CIL) introduced by the Government in 2010. The IDP could be used to provide a basis to calculate appropriate charging mechanisms for CIL. This is a unit charge per dwelling or square metre of commercial development that will be applied to qualifying development under CIL.

6.5 The IDP has been prepared at a time of unprecedented change, with government spending cuts affecting the way that services are provided both nationally and locally and radical changes planned in services such as the NHS. This could have major implications for the way that essential infrastructure is provided in the future and the IDP Delivery schedule will be updated on an annual basis.

Objectives and outcomes

6.6 The Infrastructure Policy of the Core Strategy seeks to ensure that the right infrastructure is in place at the right time to meet the needs of Hastings. The main objective of the IDP is therefore to ensure that these infrastructure needs are identified in a structured way and that providers are clear as to their role in implementing the Strategy. The key outcome is a Delivery Plan which supports and underpins the implementation of the Core Strategy and helps to determine and co-ordinate the investment plans of infrastructure providers.

25 Policy Context

6.7 The Government’s policy on infrastructure planning is set out in Planning Policy Statement 12 (PPS 12), which highlights the importance of infrastructure planning to underpin the preparation of the LDF Core Strategy. PPS 12 states that the infrastructure planning process should identify:

• infrastructure needs and costs; • the phasing of development; • funding sources; and • responsibility for delivery;

6.8 The approach taken in this IDP reflects the requirements of PPS 12.

The type of infrastructure covered by this IDP

6.9 The IDP addresses both physical and community infrastructure. Physical infrastructure includes transport, electricity, gas, water, communications, waste and flood protection. Community infrastructure includes open space, leisure facilities, education, community centres and health. It must be stressed that this Plan is only concerned with the infrastructure needs of the various infrastructure providers, not with the way in which they manage or operate their service.

The process of preparing the IDP

6.10 In order to inform the IDP, 45 infrastructure providers were consulted and asked a number of questions, to establish their existing requirements and what their additional requirements would be, based on the South East Plan target of 4,200 dwellings between 2006 and 2026. This figure has now been revised and the period extended to 2028 as set out in the “Future Housing Provision in Hastings” paper at Appendix A.

6.11 Where relevant, consultees were also provided with copies of the Council’s Strategic Housing Land Availability Assessment (SHLAA), which lists all potential housing sites within the Borough together with the best estimate of their capacity and when they are likely to be developed. We are still waiting to hear from a number of those contacted.

6.12 The IDP has also been informed by a Parks and Open Spaces Strategy prepared by the Council in 2006, it will also be informed by the outcome of traffic modelling currently being undertaken to assess the impact on the road network of levels of development proposed in both Hastings and Rother Core Strategies. The information provided by organisations has helped the Council to identify current deficiencies in the provision of social and physical infrastructure and the threshold levels in terms of housing numbers that would trigger a specific infrastructure requirement. The remainder of this document details the specific types of social and physical infrastructure that are required to deliver the LDF Core Strategy.

26 Infrastructure Requirements

Education

6.13 East Sussex County Council (ESCC) is the Local Education Authority and has a statutory duty to provide school places in the town. The Education Authority is responsible for running a Pupil Forecasting Model taking account of the projected level of housing growth, Office of National Statistics (ONS) Live Birth data and the County Council’s policy based population projections. The County Council updated the Model in March 2011 and the requirements set out below for primary and secondary education represent the position at that date. Early years and 16+ provision is still being assessed and the requirements set out below are based on the 2010 Model.

6.14 For the purposes of this IDP, new school place requirements are broken down into the following categories:

• early years provision; • primary school places; • secondary school places; • further education provision.

Early years provision 6.15 For the purposes of this exercise, ESCC has adopted the same school planning areas are used for primary school planning. These are:

• Hastings South Western (SW) – including wards of Braybrooke, Central St Leonards, Gensing, Maze Hill, West St Leonards • Western (NW) – including wards of Ashdown, Conquest, Hollington, Silverhill, Wishing Tree • Hastings South Eastern (SE) – including wards of Baird, Castle, Old Hastings, St Helens, Tressell • Hastings North Eastern (E) – including Ore ward • Hastings RC Schools – including all wards

6.16 Results from the last Early Years, Childcare and Extended Schools Service (EYCESS) Childcare Sufficiency Assessment 2008 and more current vacancy data have been used by the County Council to test the options to indicate where shortages of Early Year places are likely to occur. ESCC’s current capital projects for Early Learning provision are:

• Maplehurst Nursery – on-site relocation of 32 place provision. • St Leonards Primary School – new 30 place Pre-school. • Four Courts, St Leonards – relocation of 24 place Pre-school.

6.17 The early Years Capital Programme was completed on the 31st March 2011 and there are currently no Early Years funding programmes planned beyond 2011. As a result of the testing of the LDF proposals undertaken by ESCC, a need for an additional 2-3 forms of entry provision has been identified, 120- 180 places in total to 2026. Hastings South West has immediate requirements for new places. Other areas would be phased depending on the timing of development. Provision is likely to be made in Hastings SW, NW or SE school place planning areas. Additional early years provision may be a mixture of the following:

27 • new buildings on, or the use of classrooms within existing school sites • new buildings on development sites where provision of land under the LDF is likely to be required. • seeking change of use for existing commercial or residential properties.

6.18 More detailed advice is awaited from ESCC.

Primary school places 6.19 We are having ongoing discussions with East Sussex County Council to determine future needs in terms of primary school places.

Secondary school places 6.20 Currently there are five secondary schools – William Parker (boys only), Helenswood (girls only), Hillcrest, Filsham Valley and The Grove. Expenditure on secondary school Capital Projects is subject to government spending reviews.

6.21 We are having ongoing discussions with East Sussex County Council to determine future needs in terms of secondary school places.

Academies provision 6.22 From academic year 2011/12, two new Academies will be created in Hastings. A planning application has been submitted for the redevelopment of the Hillcrest site to provide a new Academy.

Further & Higher education provision 6.23 Sussex Coast College Hastings has recently relocated to a purpose built campus at Station Plaza in the town centre with a subsidiary campus in the Ore Valley. In the next three years, the College will need to consider development of the fifth floor expansion space at Station Plaza to increase capacity.

6.24 The University of Brighton has a campus in Hastings at the University Centre in Havelock Road. The phase 2 expansion of the University – adjacent to Priory Square within Hastings town centre, is currently under construction, with an anticipated completion date of October 2011. The University considers the opportunity to have more dwellings in the town would be very helpful as they have the capacity to take more students. They are considering the development of the residential component of Station Plaza as student accommodation.

Community Facilities

Sports and Leisure facilities 6.25 The Council’s £500,000 programme of refurbishment to Summerfields Leisure Centre and Falaise Fitness Centre has been completed, giving these facilities an additional 15 year lifespan. The Council has a 5 year contract with Freedom Leisure, to manage the facilities, which expires in 2016. The situation will be reviewed as we prepare for retendering the contract. The Council has an aspiration to build a new leisure centre but no funding has been identified at present. Further work is required to identify the need, shape and optimum timing of future Council provision.

6.26 The Council has a joint use agreement for the Sports Hall at Hillcrest .With the building of the new Academy, the Council will seek to re-negotiate the

28 agreement. The Strategy review has not identified any further need for Sports Halls in Hastings.

6.27 The athletics track at William Parker Sports College requires significant investment, possibly £300,000, in about 5 years time to replace the aging track surface. No source of funding has yet been identified.

6.28 There are various other facilities around the town including the refurbished skate park at White Rock Gardens which opened on 21 August 20109

Library services 6.29 ESCC has a statutory duty to provide library and information services. Across the Hastings area it provides a variety of services via a network of static libraries, mobile libraries and a mobile office, as part of a county-wide library service. The construction of the levels of housing in the Core Strategy will have an impact on existing service delivery. Options for the most effective way to provide library services will be considered. The potential to provide access to services in different and innovative ways will be investigated. The Library and Information Service may also enter into partnerships with, developers, schools, community centres, retail centres and others.

6.30 The County Council has recently decided to upgrade and renovate the main library to incorporate the children’s library in Hastings town centre, rather than construct a new library.

Public Art 6.31 Public art can play an important role in enhancing local distinctiveness and a sense of place. It can also benefit the local economy, by providing opportunities for local artists and local community involvement, and can also help to enhance the appeal of Hastings and St Leonards as a tourist destination.

6.32 Where major developments are proposed, the Council will seek a contribution towards art from developers. The nature of contribution will be negotiated with the developer and will take the form, either of provision for works of art or artists’ input to the building and its surroundings, or through a financial contribution towards public art works, art facilities or events. The type of public art and level of contribution will depend on the nature of the development proposal, the characteristics of the site and its surroundings. However, a nationally acceptable guideline is that it will be around 1% of the construction costs10.

Community centres 6.33 Community facilities are being provided as part of the Stade development. Jackson Hall has been refurbished and now provides an administrative centre for the voluntary services in the town. The hall at Churchwood Primary School is used by the community in the evenings. There is a proposal to provide an additional mobile classroom on site for school use during the day and community use in the evening.

9 http://www.hastings.gov.uk/sport/sports_pitches_courts.aspx 10 http://www.hastings.gov.uk/regeneration/public_art.aspx 29 Health 6.34 East Sussex Hospitals Trust has indicated that there is no requirement for additional land to serve the Conquest Hospital. In earlier consultations, the Hastings and Rother Primary Care Trust (PCT) advised that Hastings is currently underprovided in terms of GP services but that a planned network of 3 new primary care centres would overcome this shortfall and provide some additional capacity for future population growth. One centre has opened at Station Plaza, however with radical reforms to the way that the National Health Service operates planned by the Government, the need for future facilities will be assessed when the mechanisms for health premises are confirmed.

Adult social care 6.35 We are currently consulting with ESCC on future adult social care provision.

Utilities

Electricity and Gas 6.36 The National Grid has a statutory duty to develop and maintain an efficient and co-ordinated transmission system of electricity and gas supply across the country. It does not have any transmission assets located within Hastings. Specific proposals within the area will not have a significant effect upon National Grid’s transmission infrastructure.

6.37 The electricity distribution company in the area is EDF Energy Networks. Because of the downturn in the economy they are forecasting very low growth levels over the next few years. Ofgen do not specifically allow the company to invest in infrastructure ahead of need. When new development proposals come forward the EDF Energy Projects Gateway Team will examine the proposals and provide an economic design for connection. The Developer is required to meet all appropriate costs in accordance with the current industry regulations.

6.38 Scotia Gas Networks are responsible for managing and maintaining gas supplies to Hastings, which is within the South East Local Distribution Zone. Although there are currently no specific capacity issues in Hastings, any new development will be assessed and where necessary reinforcement of the gas system may be required. Scotia Gas Networks also have an ongoing mains replacement programme and part of this programme is likely to involve significant investment in Hastings. We are currently awaiting further details of this investment from Scotia Gas Networks.

Water and sewerage 6.39 Southern Water Services (SWS) provide water and sewerage services in Hastings. SWS has undertaken an assessment of all of the sites in the Council’s Strategic Housing Land Availability Assessment (SHLAA). In terms of water supply, the vast majority of sites have existing distribution capacity available and connections can be made without any perceived major off-site investment or strategic capacity implications. The situation with sewerage disposal is rather different with the vast majority of sites having no existing sewer capacity available. SWS requires development to connect to a point where there is adequate capacity. This is outside the scope of planning policy and the formal requisition procedures set out in the Water Industry Act 1991 provide a legal mechanism for developers to provide the necessary infrastructure to service their sites.

30 Telecommunications 6.40 Hastings is served by three telephone exchanges, one in the town centre and two significantly smaller ones in newer parts of the town. BT does not have any current plans for the central exchange in Havelock Road beyond those already agreed with the University Centre.

6.41 BT Openreach (the regulated arm of BT responsible for the telephone network) is currently rolling out a brand new fibre network to deliver SuperFast Broadband across the UK. Openreach has committed to delivering this new technology to 66% of the country. Although Hastings is not on the published list for deployment in the next 12 months, the town is at present being considered for inclusion in the 66% coverage area. Discussions with Openreach are ongoing to ensure Hastings inclusion. The issue of cable channelling will be addressed in the Site Allocations and Development Management Plan.

6.42 Because of the rapidly changing technology, it is not possible for mobile phone operators to give a clear indication of their infrastructure requirements in the medium to long term. The operators submit annual rollout plans to all local planning authorities, which give an indication of those additional sites each operator anticipates requiring over the next twelve months.

Waste 6.43 East Sussex County Council (ESCC) is the Waste Planning and Waste Disposal Authority for the Borough, with responsibility for producing the Waste Local Plan. HBC has responsibility for household and other municipal waste collection. The Borough is jointly responsible with ESCC for the recycling of household waste, but ESCC has direct responsibility for the provision and management of waste recycling sites. The current Household Waste Recycling Site (HWRS) is working over capacity. ESCC has planning permission for a new HWRS at the Pebsham Waste Transfer Station in Rother, which it is planned to build and commission in the next year. ESCC’s waste service forecasting includes for additional housing in the Hastings Area and its service provision is expected to meet the LDF potential housing provision. The new HWRS is considerably larger than the existing one.

Coast and flood protection 6.44 The Council are responsible for coast protection, except for Bulverthythe, which has been retained by the Environment Agency (EA), who are also responsible for coastal flood protection. The EA has recently completed a scheme at Bulverhythe utilizing large rock revetments and will in future undertake routine maintenance work. The Council maintains the other defences in accordance with the Shoreline Management Plan11 where the policy is to hold the line.

6.45 A concrete structures survey of the Promenade, commissioned by the Council in 2011, has identified that deterioration has continued at a significant pace in parts of the 1930s structures since the last survey in 2005. Substantial repairs will be necessary to prolong the life of the structures beyond the medium term. This work is currently being assessed and is not yet funded.

6.46 A Department for Food and Rural Affairs (DEFRA) funded survey of all coast defence assets in Hastings is being undertaken, with the exception of the

11 http://www.hastings.gov.uk/conservation/conservation_coastal.aspx 31 Harbour Arm and groynes to the east. The report, which will take the form of a 25 year programme will be available in the autumn of 2011. Up to 2026 the replacement/refurbishment of timber groynes would be the priority to maintain levels of shingle at a cost £17million. The work, which is in the EA’s Medium Term Plan, would be 100% funded by DEFRA.

6.47 A DEFRA funded Coastal Pathfinder study of the impacts on the fishing fleet of climate change and possible solutions, including the Harbour Arm, is being undertaken by the Borough Council and should be available in Autumn 2011. Any work would be 100% DEFRA funded.

6.48 The Council has also obtained a grant of £100.000 to prepare a Surface Water Management Plan for the town. This is being reported to the Council’s Cabinet in summer 2011 and is not likely to identify any need for Capital Works.

6.49 In terms of water quality, the revised Bathing Water Directive requires much more stringent testing of bathing water quality than previously required. There is a risk that bathing water at Pelham may not meet these new standards unless improvements to surface water systems are identified and implemented by Southern Water. It is therefore important that we continue to work closely with Southern Water and the Environment Agency on this issue.

Open Space and Green Infrastructure

Open space 6.50 The Council’s 2006 Parks and Open Spaces Strategy specifies that the focus for the future will be to improve the quality and value of existing open spaces rather than establish new ones, with priority for sites within or adjacent to the most deprived neighbourhoods. The Council will seek planning agreements and development contributions in appropriate cases to secure the enhancement of existing open spaces. Where major new development is proposed in areas with no access to open space, new provision may be required.

6.51 Two major new open spaces are proposed - one in the Ore Valley and the other at Pebsham Countryside Park, which is mainly in Rother District. The Ore Valley Open Space proposals are linked to the wider regeneration plans for Ore, which previously enjoyed Millennium Communities programme status. Discussions are currently underway with the Homes & Community Agency regarding proposals for future phases of construction at Ore. The timing of the improvements to the green space will form part of these discussions as they are linked to future delivery of housing on the sites.

6.52 The creation of Pebsham Countryside Park is a priority for Hastings, Rother and East Sussex County Councils, and a Member-level Management Board, and other structures have been established to take this forward. These Councils, private landowners and others make various contributions to the project. In particular, ESCC holds £362,000 (as at Feb 2011), as a contribution towards the establishment of the park, from Southern Water as part of their Waste Water Treatment Works in the park area. The Board employs a Park Ranger. Discussions are on-going with Cinque Ports Rugby Club and may result in new pitches and a refurbished clubhouse at the Bexhill Road end of the Pebsham site.

32 Children’s play space 6.53 The Open Spaces Audit undertaken in 2005 found that the Council’s policy to provide fully equipped formal children’s play areas was not working well, and they were often underused and are expensive to maintain and manage. The preferred approach was adopted that there should be a relatively small number of large equipped play spaces at key locations around the town that are accessible to all. Developers will be required to contribute toward this provision.

6.54 In 2010 the Council undertook a re-audit of play facilities operated by HBC and Amicus Horizon. There has been considerable investment in recent years through government and lottery funding in the refurbishment and improvement of existing playground sites and the provision of an adventure playground in the Ore Valley. This improvement is reflected in the results of the audit. Nevertheless deficiencies were identified in a number of areas and some sites of poor value/ quality were identified for closure. As a result of the re-audit the Council has adopted a policy of providing good quality/value playgrounds within 600 metres of all households and to close poor sites that are within 600 metres of better quality/value provision. Developers will be expected to contribute to the improvement of existing sites close to new development or to the provision of new sites in areas of deficiency.

Green infrastructure 6.55 A network of green infrastructure is to be established in the town. This includes major open spaces such as Alexandra Park, the seafront, nature reserves, outdoor sports facilities, children’s’ play areas, allotments and cemeteries. Developments will be expected to contribute positively to the network. Two major pieces of green infrastructure are proposed in the town – Pebsham Country Park and the Ore Valley.

Transport

Strategic roads 6.56 Our top priority for new road infrastructure is the Bexhill to Hastings Link Road, which is the responsibility of the County Council. As a result of the Government’s Spending Review, the Link Road is now in a Development Pool of 45 schemes. The Department for Transport (DfT) has indicated that there is £600 million available for Development Pool schemes, about half the funding necessary. The DfT is expected to make decisions on which schemes will go forward by the end of the year 2011.

6.57 In addition the Council considers the following road improvement schemes, which are the responsibility of the Highways Agency, to be important to reduce the isolation of Hastings:

• A21 Baldslow Junction • A21 Tonbridge to Pembury • A21 Kipping Cross to Lamberhurst • A21 Flimwell to Robertsbridge

6.58 As a result of the Government Spending Review, with the exception of the A21 Tonbridge to Pembury scheme, all of the above A21 schemes have been cancelled. The A21 Tonbridge to Pembury scheme has been retained but no funding is allocated before 2015. Kent County Council has approached the Government to discuss the possibility of it being brought forward.

33 Local roads 6.59 The County Council wishes to safeguard the route for the Hastings Spur road Phase 2, until the Bexhill to Hastings Link Road has been operational for at least a year.

Rail 6.60 We have identified the following rail schemes as being important:

• upgrading of Ore Station • Ashford to Hastings line capacity improvements • Hastings to Tonbridge capacity Improvements • development of a new station at Glyne Gap

6.61 Network Rail, who own, maintain, develop and operate Britain’s rail infrastructure, have indicated that they believe that there is sufficient capacity on the Coastal route and the route towards London via Tonbridge to cater for the increased local and commuting demand created by 3,516 houses. The strategy for these routes is to deliver incremental capacity and capability enhancements, such as improved journey times. They have however indicated their willingness to engage with Kent County Council to fund a study into route enhancements on the Ashford to Hastings route. Southern Railway, one of the Franchise holders operating on the coastal route, considers that the additional dwellings will have a small positive impact on their services through increased commuting. They will also benefit from a small number of additional off peak leisure and business journeys.

Buses 6.62 Stagecoach, one of the main bus operators in the Hastings area, considers that they can accommodate the greater demand arising from the potential 3,516 dwellings through incremental growth, such as the provision of larger vehicles and increased frequencies. However, most new developments do require some level of revenue funding for bus services to ensure that a level of service sufficient to attract new residents before the site is fully developed. Bus subsidies are the responsibility of the County Council. Rambler Coaches, another operator in the town, have indicated that they would benefit from the additional dwellings which would mean more students to take to college.

6.63 Neither Stagecoach nor Rambler Coaches have any new fixed infrastructure needs in Hastings.

6.64 As part of the potential package of Link Road complementary measures, the County Council proposes to improve the facilities for buses running along the A259 Bexhill Road corridor between the two towns. Hastings Borough Council is also part of the Quality Bus Partnership12 with ESCC and Stagecoach.

Local sustainable accessibility improvement contribution (LSAIC) 6.65 New development may need to make a LSAIC contribution towards relevant Local Transport Plan (LTP) packages, providing small scale local transport

12 A Quality Bus Partnership (QBP) provides a forum where all the stakeholders with responsibilities that impact on the quality of bus service delivery agree common objectives and take responsibility for those factors under their control. Typically, QBPs include commitments by bus operators on the introduction of low floor buses and, often, service improvements; by the local authority on infrastructure improvements; and by the police or local authority on enforcement. 34 improvements aimed at making the development more sustainable in transport terms. There is a scale of charges, depending on the type of development, set by the County Highway Authority13.

Pedestrian and cycle routes 6.66 A strategic network of cycle and pedestrian routes, linking communities with green infrastructure, the seafront, the town centre etc. will be achieved in the plan period by a combination of public and private investment and developer contributions. The Council will also support the extension of the existing National Cycleway Network along the seafront. SUSTRANS and ESCC are jointly responsible for the provision of the section of the Network between Bulverthythe and Glyne Gap at a cost of £800,000. The Council are responsible for the provision of the section between Robertson Street and the Old Town at a cost of £5,000.

Emergency Services

Police 6.67 We are awaiting a response to our enquiries from the Police.

Ambulance Service 6.68 We are awaiting a response to our enquiries from the Ambulance Service.

Fire and Rescue service 6.69 The East Sussex Fire and Rescue Service has recently commissioned a study of the short, medium and long term needs for all fire stations within their area. Hastings has two fire stations, a main station on Bohemia Road and a second station on The Ridge. The study does not identify any need to upgrade or relocate either station in the short term (2010-2012). It does however recommend that the possibility and benefits of the amalgamation of the two stations on a new site is investigated in the medium term (2012- 2018).

Infrastructure Delivery

6.70 The infrastructure identified in the schedule in section 7 will be delivered in a number of ways. In some cases it will be the sole responsibility of the infrastructure provider. In others it may be funded by the co-operation of a number of partners. The schedule identifies responsibility in each individual case. In appropriate cases the Borough Council will use its powers under Section 106 of the Town and Country Planning Act 1990 to secure developer contributions. Since the coming into force of the national Community Infrastructure Levy (CIL) there is now a legal requirement for contributions to meet the following tests:

• necessary to the development in planning terms; • directly related to the development; • fairly and reasonably related in scale and kind to the development.

13 http://www.eastsussex.gov.uk/environment/planning/development/newapproach/downloadsa. htm 35 6.71 This limits the range of infrastructure for which Council’s can seek developer contributions. After 2014 the range will be limited even further, basically to on- site infrastructure.

6.72 One of the problems that Hastings faces is that land values are relatively low and the amount that individual developments can contribute to is low compared with other parts of the South East. Both the County and District Council have adopted Supplementary Planning Guidance (SPG) on developer contributions14.

6.73 The County Council’s SPG “A New Approach to Development Contributions” applies a tariff based structure to secure developer contributions to County Services. The SPG mainly adopts a threshold of 15 dwellings and above. Below that contributions are not normally required, except for LSIAC where a threshold of 5 or more dwellings has been adopted. Contributions are also required from certain larger commercial developments.

6.74 The Council has not adopted the County SPG but in 2004 adopted an SPG of its own “Development Contributions”15. Because of the low land values in Hastings referred to above, the SPG sets out the Council’s priority order for development contributions. These are:

1. essential on-site infrastructure 2. essential off-site infrastructure 3. affordable housing 4. sustainable transport 5. education 6. all other infrastructure

6.75 It is intended to produce a new Supplementary Planning Document (SPD) in the light of the Infrastructure Delivery Plan.

6.76 Should the Council decide to implement CIL locally, this would replace developer contributions under Section 106 except for specific items of on-site infrastructure. CIL is therefore included in the Infrastructure Delivery Schedule as a possible alternative to Section 106 Agreements.

Monitoring

6.77 Progress on the implementation of the Infrastructure Delivery Schedule will be monitored as part of the Council’s Annual Monitoring Report.

14 http://www.eastsussex.gov.uk/environment/planning/development/newapproach/default.htm 15 http://www.hastings.gov.uk/local_plan/default.aspx#lp_spg 36 7.0 The Infrastructure Delivery Schedule

7.1 The Infrastructure Delivery Schedule (shown in the tables on the following pages). It sets out the key infrastructure that will be required to deliver the Local Development Framework Core Strategy.

7.2 The following notations are used in the Schedule to aid understanding:

Priority of scheme HIGH - The infrastructure proposed is critical to the delivery of the Core Strategy and should be identified as a priority MEDIUM - The infrastructure proposed is required to support the Core Strategy, but does not need to be prioritised. LOW - The infrastructure proposed is desirable, but not essential to the delivery of the Core Strategy.

Timing SHORT TERM - 2011 to 2015 MEDIUM TERM - 2016 to 2020 LONGER TERM - 2021 to 2026

37 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

Early Years Provision New Nursery Output - 120 Evidence: East Sussex Not Government Scheme does Indicative at To be No identified risks Building to to 180 ESCC Early County Available. grant not link to other this stage. provided by at this stage. provide 2-3 nursery years, Council Sure Start infrastructure 2026, forms of entry school places. childcare and Section 106 requirements or depending on Likely to be Extended Agreements/ need to pace of Priority: HIGH provided in Schools CIL precede development. Hastings SW, Service ESCC has a development. SE or NW Childcare tariff for MEDIUM TO school place Sufficiency determining LONGER planning Assessment Development TERM areas. 2008. contributions. (See “A New Approach to Development Contributions” SPG) Primary School Provision Creation of 3 Output – up to Evidence: East Sussex £18.5 million Basic Needs Scheme is Indicative at 240 to 420 No identified risks to 5 forms of 780 primary ESCC Pupil County Capital critical to this stage. spaces­ at this stage. entry school places Forecasting Council Funding for ensure that 2013 to in total. Model 2011 Schools sufficient 2020/21 Priority: HIGH Provided by Section 106 primary school expansion of Agreements/ places are 420 to 630 existing CIL available to spaces – schools. ESCC has a meet needs 2021/22 to tariff for arising from 2025/26 determining new Development development. (S106 funding contributions. cannot cover (See “A New temporary Approach to classrooms) Development Contributions” SHORT, SPG.) MEDIUM AND

38 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

LONGER TERM Academies Provision Academy Output – new Evidence: East Sussex Uncertain Government Good quality Detailed Construction No risks identified East Academy to ESCC County Grant secondary plans drawn due to start in replace Council schools are up and 2011/12. Priority: HIGH Hillcrest essential to planning School deliver strategic application SHORT objectives for submitted TERM training and for skills. redevelopm ent of Hillcrest site. Academy Output – new Evidence: East Sussex Uncertain Government . Good quality Site Construction No risks identified West Academy to ESCC County Grant and secondary selected. due to start in replace Council ESCC schools are Scheme 2011/12. Priority: HIGH Filsham essential to being drawn Valley and deliver strategic up. SHORT The Grove objectives for TERM Schools. training and skills. Sports & Leisure Facilities New indoor Output – New Evidence : Hastings No allocated HBC Capital The scheme is Aspirational. Provision Main risk is leisure Centre Leisure HBC 2009 – Borough cost Budget not critical to Further likely to be availability of Centre to 2020 Leisure Council Section the Strategy at work 2020 onwards funding Priority: LOW replace Facilities 106/CIL this time required to Summerfields Strategy Other sources because of the establish LONGER Leisure Review. of funding. adequacy of need, shape TERM Centre. existing and Location yet facilities but will optimum to be decided become more timing critical with time. Athletics Output – ESCC/HBC £300,000 No sources of The scheme is At Required in Main risk is Track Replacement Evidence: funding important but conceptual about 5 years availability of Replacement track surface HBC 2009 – identified not critical to stage time. funding

39 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures surface at William 2020 Leisure the Core Parker School Facilities Strategy MEDIUM Priority: Strategy objective to TERM MEDIUM Review. enable an increased take up of sports. Library Service Renovation of Output – Evidence: ESCC To be ESCC Capital Important but Agreed by N/A town centre Renovated ESCC Library confirmed budget. not critical to ESCC SHORT library central library. Service. the TERM implementation Priority: of the core MEDIUM Strategy.

Public Art Installation of Contribution Evidence: HBC and Varies Developer Important for 2004 Local Ongoing Failure to secure public art towards http://www.ha Developers depending on contribution regeneration Plan Policy through Section public art from stings.gov.uk/ scheme around 1% of of the town DG20 106 agreements Priority: developers of planning/publi construction MEDIUM major c_art.aspx costs schemes Health Primary Care Need to be Evidence : Local health No costs NHS, General Scheme is Subject to Unknown at Main risk is Centres determined service available Practicioners important to confirmation this stage planned changes once budgets achieving Core of structures to the way that the Priority: HIGH structures for Strategy health for local NHS operates at local health objectives. health the local level. provision are provision confirmed

Telecommunications Super Fast Output – Evidence : BT No costs BT Openreach Scheme is Hastings is No timescale The main risk is Broadband Super Fast BT Openreach available critical to not in the yet available. that Hastings is broadband Openreach achieving the list for not included in the Priority: HIGH available to Core Strategy deployment SHORT 66% national the whole business in the next TERM coverage.

40 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

Borough. development 12 months, objectives. but is being considered for inclusion in the 66% national coverage Coast and Flood Protection Repairs to Output – Evidence : HBC £1,235,000 Sum included Scheme is At the 5 year The main risk is Hastings essential Concrete in HBC Capital critical to proposal programme the availability of Promenade repairs to Structures Budget but not achieving the stage, no post 2014. funding. concrete Survey of yet funded Core Strategy detailed Priority: HIGH sections of Promenade objectives for designs yet MEDIUM the the seafront drawn up. TERM Promenade and flood including prevention Bottle Alley, White Rock Baths and grand Parade car park. Replacement/ Output - Evidence : Environment £17 million. 100% DEFRA Scheme is In EA’s 25 year Main risk refurbishment Refurbishmen DEFRA Agency funded critical to Medium programme. availability of of timber t/ replacement funded achieving the Term Plan funding groynes of groynes Survey of Core Strategy MEDIUM TO along whole Coast objectives for LONGER Priority: HIGH of seafront Defence the seafront TERM excluding the assets in and flood Harbour Arm Hastings prevention. and groins to the East Replacement/ Output – Evidence: HBC No costs yet 100% DEFRA Scheme is The results No timescales The Study may refurbishment refurbishment DEFRA available funded critical to of a Study available. not identify any of timber / replacement funded achieving the are awaited need for capital groynes of timber Coastal Core Strategy which may MEDIUM TO works. Availability groynes in Pathfinder objectives for identify the LONGER of funding is section of Study the seafront need for TERM another risk.

41 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

seafront at and flood refurbished/ Harbour Arm prevention. replacement and groynes. eastwards. (Subject to results of Study) Open Space and Green Infrastructure Ore Valley Output - Evidence: HBC/ No costs Funding Scheme is Discussion Timescale Main risks are Open Space Large Open Ore Valley Seaspace available sources not yet important but are currently uncertain. availability of space in Ore Masterplan identified not critical to underway funding and Priority: Valley and Design the Core with Homes MEDIUM failure to reach MEDIUM Codes. Strategy Health & TERM agreement on objectives. Community management Agency regarding proposals for future phases of construction . The timing of the improvemen ts to the green space will form part of these discussions Pebsham Output – Evidence: ESCC/Rother Costs not ESCC Scheme is Site has Should be Main risk is Countryside Large new Pebsham HBC available Rother District critical to been provided availability of Park Countryside Masterplan Council achieving the prepared within 5 years funding. Park between HBC Core Strategy ready for Priority: HIGH Hastings and ESCC hold Health implementat MEDIUM Bexhill, £362,000 in a objectives. ion TERM mainly in fund for Rother District establishment of the park

42 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

Improvement Output – Evidence: HBC Costs not Section 106 Scheme is Dependant Timescale Development of existing, Improvement Parks and available Agreements/ critical to the on dependant on does not go and provision of existing Open Spaces CIL Core Strategy contribution contributions. ahead. of new open well located Strategy Health s from spaces and open spaces 2006. objectives. developmen SHORT, children’s’ and play Open Space t MEDIUM play spaces spaces and Audit 2005 AND new provision and re-audit LONGER Priority: HIGH in areas of 2010 TERM deficiency. The aim is to provide a good quality playground within 600metres of every home. Transportation Bexhill to Output – New Evidence : ESCC £95 million Awaiting This road is of Detailed If government The Bexhill to Hastings Link road between ESCC (subject to announcement critical designs give go ahead Hastings Link Road the A259 in review) expected later importance to have been to the Road has been Bexhill and this year. the prepared scheme, it is included by the Priority: HIGH Queensway in regeneration of and expected to Government in a Hastings to Hastings and to planning start in 2013 “Development ease the provision of permission for completion Pool” of 45 congestion housing and has been in 2014. schemes. In and pollution employment in obtained. January 2011 the on Bexhill North Bexhill, SHORT County Council Road and to which will TERM submitted an open up North benefit Hastings “expression of Bexhill for as well as interest“ to the commercial easing Government with and housing congestion on a view to securing development. the A259. funding for the scheme. The County Council is now working on a

43 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

“Best and Final Bid” for submission to DfT in September 2011. The Government is expected to make a decision on which schemes will go ahead later in 2011. Hastings Spur Output – Evidence : ESCC No costs ESCC This scheme A line for Timing The County Road Improvements ESCC available may not be the Spur dependant on Council intends to Phase 2 on Gilsmans Need to be necessary Road is Link Road. review the need Hill between re-assessed 1 depending on safeguarded for this scheme 1 Priority: LOW Wishing Tree year after Link the effect of the in the MEDIUM year after Road and Road Link Road. Hastings TERM completion of the Sedlescombe completed. Local Plan Link Road. Road South.. 2004. Ashford to Output – Evidence: Network Rail No costs Network Rail Improvements At the initial Timing not yet Progress is Hastings Rail Improvements KCC available to the Ashford study stage. known. dependent on the Line to Ashford to Line are outcome of a Hastings Line important in Study. Priority: to increase terms of MEDIUM capacity and improving improve accessibility journey times. between Subject to a Hastings and Study. the Ashford Growth Area. A259 Bexhill Output – Bus Evidence: ESCC Costs being ESCC Scheme is Conceptual. Timing Greatest risk is Road Bus Corridor on ESCC investigated dependent on depends on that the Link Road Corridor Bexhill Road Proposals for the provision of Link Road. does not go following Link Road. the Link Road. ahead. In these Priority: HIGH construction MEDIUM circumstances of the Bexhill TERM consideration to Hastings would need to be

44 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

Link Road. given to what bus priority could be achieved in existing traffic conditions. Local Output – Evidence: ESCC ESCC has a Section 106 Contributions Scheme in On-going Will not be Sustainable financial ESCC formula for Agreements/ are sought from operation. possible to require Accessibility contribution “A New assessing CIL all these Improvement from Approach to contributions developments contributions after Contribution developments Developer . of 5 or more 2014 unless CIL (LSAIC) of 5 or more Contributions” dwellings prior introduced. dwellings . to development Priority: towards taking place. MEDIUM transport measures that will improve sustainable access in local areas. Strategic Output – Evidence : HBC Costs not ESCC Scheme is Routes Timescale Main risks are pedestrian network Core Strategy available HBC critical to the identified dependant on availability of and cycle linking main Key Diagram Section 106 Core Strategy diagrammati availability of funding and network destinations Agreements/ health cally in Core funding. identification of in Hastings. CIL objectives. Strategy routes. Priority: HIGH Other sources Key SHORT, of funding will Diagram. MEDIUM be sought AND LONGER TERM National Outputs – Evidence : Bulverhythe Bulverhythe Bulverhythe – Scheme is Routes Timescales Main risk is Cycleway Provision of SUSTRANS section – section - SUSTRANS/ critical to identified dependant on availability of Network sections of SUSTRANS/ £800,000 ESCC achieving the funding. funding. route between ESCC Robertson Robertson Core Strategy Priority: HIGH Bulverhythe Robertson Street Street - HBC objectives for SHORT and Glyne Street section section - the Seafront TERM Gap and - HBC £5000 between

45 Scheme Output Impact and Delivery Cost Funding Scheme Status of Timing Risk and Name Supporting Agency Arrangements Dependencies scheme Contingency Evidence Measures

Robertson Street and the Old Town. Fire Service New Fire Output – Under ESCC No costs ESCC Scheme is at At the initial 2012-18 The investigation Station Amalgamatio investigation available the initial study investigation may not identify n of existing stage and is not stage. MEDIUM any benefit in Priority: LOW Fire Stations of high priority TERM amalgamating at Bohemia at the present stations. Road and The time. Ridge on a new site, subject to an investigation. No site identified.

46 Appendix A – Future housing provision in Hastings This is a background paper for information only and is not available for comment as part of the consultation

1.0 Introduction

1.1 Now that the Government is planning to withdraw the South East Plan, there is an opportunity for Hastings to review its housing target for the period up to 2028.

1.2 The purpose of this paper is to set out how many new homes should be provided within Hastings up to 2028. We need to take account of (i) local housing need and demand; (ii) the level of housing needed to support the growth and regeneration agenda for the Town, and (iii) the potential developable space available in Hastings. The challenge is to provide enough new homes to meet need and demand, as far as possible, whilst still maintaining the Town’s attractive environment and ensuring the infrastructure to support the development can be provided.

1.3 This paper will look at: why we need more homes, how much can be provided within Hastings, and what the scenarios are around setting a target number. The present Government believes that in abolishing top-down regional housing targets and promoting greater community consultation and involvement in planning decisions, communities will be more willing to accept new housing because development proposals will more closely reflect the preferences of the community1.

1.4 The question of housing numbers in Hastings is part of the ongoing consultation on the Hastings Core Strategy. Previous consultation versions of the plan have set a housing target of 4,200 net new homes between 2006 and 2026, which is equivalent to 210 net new homes annually. This figure came from the South East Plan which Hastings had to comply with. However, the Government is planning to abolish regional plans and local authorities now have the opportunity to review their housing targets.

1.5 It will still be necessary for us to justify whatever housing target is chosen and to be able to defend both the target figure and future housing supply policies during the LDF Examination process. This means continuing to build on and rely upon our evidence base. The Government says that we still need to identify enough sites and broad areas for development to deliver enough housing for at least 15 years from the adoption of our Plan (i.e. the Core Strategy) and to have a five year supply of deliverable sites2. This means we need to plan for housing needs up to 2028.

1.6 Although the Government has placed the responsibility for setting housing targets with local authorities, it has also very clearly said that it is committed to housing growth3.

2.0 Why we need more housing in Hastings?

2.1 Access to a decent home for everyone is the foundation for a decent quality of life and a key priority for the Council and its partners. It is a priority to increase the

1 DCLG Localism Bill: abolition of the regional tier and introduction of the Duty to Cooperate Impact Assessment, Jan 2011 2 DCLG Planning Policy Statement 3: Housing June 2010 paragraph 53 3 Parliamentary Statement - Revoking Regional Strategies Rt Hon SoS Eric Pickles, 6 July 2010

47 availability, affordability and quality of housing to ensure all sections of our community, in all housing tenures, enjoy housing that is affordable, accessible and appropriate for their needs and aspirations4.

Local Economic Growth and Recovery

2.2 The supply of new homes is also critical to the town’s economic performance and the wider regeneration agenda. Hastings has been pursuing an ambitious, collaborative approach to economic and cultural renaissance. Since its formation in 2003, Sea Space and the wider Hastings & Bexhill Task Force has:

• constructed over 18,000m² of high quality business space in Hastings, including Lacuna Place and a Creative Media and Innovation Centre • facilitated over 7,000m² of education space for higher / further education use – Hastings is now a University town; • established Enviro21, a modern industrial park focused on the growth of environmental technology companies and advanced manufacturing; • created capacity for 1,700 new jobs, including the recently announced SAGA investment into Hastings’ Priory Quarter, creating over 700 additional private sector jobs.

2.3 These developments offer a real and lasting opportunity to promote the town as a thriving, high quality business location and a desirable place to live and enjoy quality recreation time. We need to consider the need/demand for housing in the context of these regeneration efforts, and whether or not both the quality and type of the existing homes available in the town is a factor holding back regeneration efforts.

2.4 Both the quality and mix of new homes within Hastings will be important to the local economy in terms of (i) existing businesses and their ability to attract employees; and (ii) new businesses setting up or locating in the town. The right type of housing could also help attract more skilled workers to the town. A more skilled workforce should enhance the ability of Hastings to attract mobile business investment and thus contribute to economic development.

2.5 In relation to future housing provision, we need to continue to ensure we make provision for the right mix of housing types to support the growing employment sectors and to attract and retain higher skilled workers and their families.

2.6 In deciding how many new homes we need, we should be aiming to get the balance right between homes, jobs, workforce and population. This includes meeting the needs of those of working age, the housing needs of the growing number of people of retirement age, and meeting objectives for housing affordability and sustainable travel to work patterns.

Evidence of Local Housing Need

The Housing Register 2.7 Demand for suitable and affordable housing in Hastings far outweighs supply. There is an acute need for housing as many people are living in unsuitable accommodation, such as properties which are overcrowded or in a state of disrepair. There is also a high level of unemployment and deprivation in Hastings and many people cannot afford their own home or are insecurely housed, e.g. temporarily

4 Hastings & St Leonards Sustainable Community Strategy, Refreshed Strategy 2009 -2026, July 2009

48 residing with friends/family. As at February 2011 there were 1,812 households on the Housing Register in housing need, this includes homeless households and those where their housing is having a detrimental effect on their health. Thus more housing is required to enable people on the housing register to move into a home that is suitable for their needs.

2.8 Throughout a decade of rising prices (1998-2008) and through the current economic downturn, average house prices in Hastings have consistently remained below the average for the South East – the gap being around £40,000. This is due to a range of factors including the mix of housing5. However, the affordability of housing is about the relationship between income and house prices. In Hastings, this ratio is on a par with many areas in the South East because of our low wage economy. The average lower quartile house price is currently 6-7 times the lower quartile income in Hastings6. The need, therefore, for affordable housing still vastly outweighs the supply. After accounting for re-lets within the existing stock of social rented housing, research in 2005 identified a shortfall of 596 affordable dwellings for that year7. This significantly exceeded what had been delivered by way of new affordable housing in recent years, with the annual average over the last five years being just 65 units. In addition, this shortfall is almost three times the old annual South East Plan requirement of 210 dwellings per year for all types of housing.

The Private Rented Sector 2.9 In addition to those people who appear on our housing register, there is also a significant number of people who want a home but lack the finances to either buy or rent one without assistance, and so rely on private renting with top-up support from local housing allowance. Data on housing benefit recipients shows that 6,350 claimants in Hastings live in the private rented sector8. This indicates that the private rented sector is playing a significant role in meeting housing need in Hastings and that the number of households on the housing register would be higher if it were not for this supply of low-cost rented accommodation. However, we also know that there is a high proportion of this privately rented accommodation, often in multiple occupation, which is well below minimum acceptable standards. There are some 2,800 Houses in Multiple Occupation (HMO) throughout the Town9. Evidence shows that 64% of all HMOs fail to meet the Government’s Decent Homes Standard. Many suffer from low standards of fire safety, management and maintenance, and in some cases, tenants are treated very poorly and the buildings are a focus for crime and anti social behaviour.

2.10 There is, therefore, a pressing need for more housing and more choice of housing in Hastings, especially affordable housing, to ensure that people have somewhere to live and somewhere that meets their needs.

5 Hastings & Rother Strategic Housing Market Assessment Update 2009/10 http://www.hastings.gov.uk/ldf/evidence.aspx 6 As above, to measure housing market affordability in an area, the ratio of lower quartile house prices to lower quartile earnings is used, i.e. this ratio shows if people with the lowest income can afford the cheapest housing. A high ratio means that housing is less affordable 7 Hastings Borough Council Housing Needs Survey 2005, DCA http://www.hastings.gov.uk/ldf/evidence.aspx “Affordable housing includes social rented and intermediate housing, provided to specified eligible households whose needs are not met by the market.” DCLG PPS 3 Housing, June 2010 8 Hastings & Rother Strategic Housing Market Assessment Update 2009/10 http://www.hastings.gov.uk/ldf/evidence.aspx 9 2007 Private Sector house Condition Survey

49 Population Change

2.11 If we consider the demand for new housing arising from future population changes alone, the latest trend-based population forecast for Hastings shows the population increasing by some 12% between 2011 and 2028, and the number of households’ increases by some 18%. This is because, in line with national tends, the average household size is set to get smaller. The demand for new housing arising from this level of population and household growth would require a further 7,840 homes by 202810. We do not think trying to meet this level of demand is realistic. This is explored further in this paper at paragraphs 3.2 to 3.7.

Capacity to Accommodate Housing Growth

2.12 Choices with regard to the location of new housing in Hastings are very limited. Hastings is now getting close to its limits in terms of further outward growth and development. The town’s environmental assets, the nationally important Area of Outstanding Natural Beauty to the north and east of the existing built-up area, the internationally important Hastings Cliffs on the eastern boundary, and the network of important greenspaces across the town including Hastings Country Park to the east and Pebsham Countryside Park to the west, act as restraints to major outward growth.

2.13 The Council has carried out an assessment of all land/sites in Hastings to identify sites that could be suitable for housing11. Housing capacity up to 2028 as at April 2011 is calculated from: • development in the pipeline (sites with planning permission and either under construction or not started) • sites identified for housing in the 2004 Hastings Local Plan • potential sites identified through the assessment. • a windfall allowance to take into account dwellings that may come forward on sites that have not been identified.

2.14 This capacity assessment is one of the key pieces of evidence that will help support our decision on both the amount of new housing and where this will be built. Our full assessment was produced in January 2010 but will be regularly updated in order to reflect the latest information around the availability and deliverability of individual sites. Prepared against the background of the South East Plan and its specific housing requirement, the assessment has revealed, through extensive research, that there is no potential to meet housing requirements through a strategic Greenfield release on the town’s urban edges12. Instead, future housing requirements will need to be met essentially through urban sites. The current assessments indicate that the capacity for new homes in the Town ranges from a minimum of 2,480 to a maximum of approximately 3,800. The minimum figure is made up of development that is already in the pipeline – that is already, under construction, with planning permission or allocated for development. The maximum capacity includes potential new housing sites, windfall development13 and the return of empty homes back in to use.

10 The latest set of trend-based population projections were produced by East Sussex County Council in April 2011. Importantly trend based projections do not reflect the impact of future housing delivery. 11 This assessment is called a Strategic Housing Land Availability Assessment (SHLAA) Jan 2010 and April 2011 update, see http://www.hastings.gov.uk/ldf/evidence.aspx 12http://www.hastings.gov.uk/meetings/meetings_docs/100301~cabinet~report06~Hastings_Local_De velopment_Framework_-_Strategic_Housing_Options.htm 13 Windfall sites are those which have not been specifically identified as available for development

50 Empty Homes

2.15 Empty homes are a wasted asset, and a good deal of progress has been made by the Council in tackling empty homes in recent years. However, whilst bringing empty homes back into use does not increase the overall housing stock, it does increase the effectiveness of the existing stock.

2.16 In 2010 there was estimated to be approximately 400 long term empty homes in the town. Some vacancies are necessary to allow the normal operation of the housing market (eg a property is empty pending re-sale or re-let and some will be under repair).

2.17 The Council’s Empty Homes Strategy (2009-13)14 outlines our continued commitment to bringing empty homes back into use through advice, financial assistance and enforcement. On the basis of the current Strategy, it may be realistic to assume that approximately 255 former empty homes may be returned to use over the Plan period.

2.18 Clearly, the return of long term empty properties back into use is only part of the picture and more new homes will be needed if we are to address some of the issues already outlined.

3.0 Levels of Housing Growth Considered

3.1 We have examined 3 potential growth scenarios before arriving at a recommendation on a future housing growth target:

Scenario 1 High Growth: 3.2 7,840 net new dwellings or 461 per annum to be provided to 2028

3.3 This scenario takes account of predicted trend-based population growth between now and 2028.

3.4 The main drivers of population change include natural change (births minus deaths) and migration. The latest trend based projections were compiled in April 2011 by East Sussex County Council (ESCC). Importantly, trend based projections do not take in to account planned future housing delivery.

3.5 Planning to meet the demand for new homes arising from the trend based population forecast would see the population rise by 12% between 2011 and 2028 and would require a further 7,840 new homes.

3.6 There is a degree of uncertainty that applies to aspects of these projections. Projections of future population sizes are based on the assumption that recent trends will continue in the future, which is by no means certain. In particular it is recognised that current methodology for estimating current and therefore future migration at the local level is problematic. Trend-based projections also do not take into account specific local issues, such as constraints to development, industrial changes, short- term worker migration patterns or unforeseen national circumstances such as economic downturns. Whilst the natural growth component of population projections is unlikely to change, assumptions around migration levels may well change over time, particularly in relation to both local and national economic growth.

14 http://www.hastings.gov.uk/empty_homes/empty_homes_strategy.aspx

51 3.7 The issues associated with pursuing this level of housing growth are that: • it offers the biggest capacity for growth. • since the scope for providing affordable housing is closely linked to overall housing provision, this option would provide the greatest opportunity to maximise the provision of new-build affordable homes. • seeking to accommodate this level of growth takes no account of local factors such as environmental constraints or the ability to generate jobs locally. • pursuing this level of housing growth would not be achievable without building at much higher densities – something which is not always popular with parts of the market but which can help improve affordability and address the housing needs of younger people such as first time buyers or, at the other end of the spectrum people looking to downsize and those whose children have left home. • pursuing this level of housing growth would not be achievable without building in environmentally sensitive locations. • there is a degree of uncertainty that applies to aspects of these projections. • it relies on a level of housing delivery likely to exceed that which the market has achieved in recent years. • this level of development will impact on the local road network and could lead, if unconstrained and unmanaged, to unacceptable levels of congestion.

Scenario 2 Lower Growth: 3.8 2,478 net new dwellings or 146 dwellings per annum to 2028

3.9 This lower scenario figure would be based on existing allocations and permissions – development already in the pipeline and would not necessarily involve the allocation of any new sites or windfall development. After allowing for homes that have already been built since 2006, this target would result in almost 1,000 fewer new homes by 2028 than the medium growth option. This lower target would be the equivalent of building 146 homes a year, a significantly lower number than average annual completions over the last five years (between 2006 – 2011 an average of approximately 200 net new dwellings have been built each year). However, this level of housing growth still relies on numerous schemes already approved for medium to high density development for 1 and 2-bedroom flats rather than houses.

3.10 The issues associated with pursuing this level of housing growth are that: • it doesn’t support the regeneration agenda • site viability will continue to be an issue in Hastings, particularly whilst the outlook for the housing market remains uncertain – inevitably in such a climate a lower target may be more achievable • because the supply of affordable homes is closely linked to the overall supply of new dwellings, setting a lower overall target would have the effect of reducing the delivery of affordable homes for which there is a significant need in Hastings, and which is a stated priority of the Council and the Local Strategic Partnership15.

Scenario 3 Medium Growth: 3.11 3,418 net new dwellings or 201 per annum to 2028.

3.12 This scenario is based on a continuation of the original South East Plan (SEP) target of 4,200 new homes which was for the period 2006-2026. The South East Plan figure for Hastings aimed to support urban renaissance, and to accommodate further development in a way that respected environmental constraints. In particular, the

15 http://www.hastings.gov.uk/lsp/default.aspx

52 decision was made not to use demographic forecasts alone as a driver for housing development. This is because the relationship with the economic growth and regeneration, and environmental constraints is much more important in Hastings. The scale of housing development proposed in the South East Plan is made on the basis that housing growth should not outstrip the ability of the local economy to provide jobs at a corresponding rate. Otherwise we would simply be adding to unsustainable out-commuting16. The starting point for the South East Plan figure is one based on the amount of development that is already in the pipeline (that is, sites already allocated for development and with planning permission).

3.13 Although the Government plans to abolish the South East Plan, there is still a significant body of evidence underpinning the housing numbers in it. After allowing for homes that have already been built between 2006 and 2011, the revised requirement to 2028 would be 3,661 new homes following the original South East Plan rates.

3.14 Meeting this target would require the allocation of new sites in addition to development that is already in the pipeline together with some reliance on windfall and the return of empty homes back into use. Information, as at 1st April 2011, shows that this rate of growth could be made up from the following sources:

Source of supply No of units (a) Development in the pipeline 2,252 (b) Potential new sites 611 (c) Windfall development 680 (d) Empty Homes 255 + Sub total 3,798 (e) Minus 10% contingency 380 - TOTAL 3,418

3.15 Development in the pipeline (a) includes sites under construction, with planning permission or already identified (allocated in the current Local Plan) for housing development. Aiming to meet this level of growth will mean relying to some extent on schemes already approved for medium to high density development for 1 and 2- bedroom flats rather than houses.

3.16 Potential new sites (b) have been identified via the SHLAA.

3.17 Windfall development (c) has made a significant contribution to housing delivery in the past and our research suggests we should continue to expect a good rate of delivery from this source. A figure of 680 (or 40 dwellings per year) can be assumed from our research.

3.18 Empty Homes (d) would be included under special circumstances as a source of supply. As well as recognising that empty homes are a wasted resource, the number of long term empty homes17 in the town is recognised as an issue by the Council. In a town where development opportunities are limited, the Council is committed to making the best use of resources and tackling empty homes forms an important part of our strategic approach to housing in order to help meet local housing need. The

16 Whilst commuting is inevitable given the diverse nature of employment, and a degree of net out- commuting is not necessarily detrimental to local prosperity. The trend of an increasing reliance on this, much by car – does have adverse consequences in terms of sustainability and access to housing at affordable prices. 17 These are defined as homes that are empty for 2 or more years

53 Empty Homes Strategy 2009-13 outlines the Council’s continued commitment to bringing empty homes back into use through advice, financial assistance and enforcement. The empty homes Compulsory Purchase Order (CPO) programme is a significant component of our enforcement model for bringing long term empty homes back into use and will be used return homes to use, where other approaches have been exhausted. We estimate, that Council’s efforts will result in 15 empty homes per year returning to use up to 2028

3.19 Finally, we also have to acknowledge that there is a possibility that not every scheme currently identified will necessarily be developed at the density currently envisaged and/or within the timeframe of the Plan. As well as the possibility that some existing planning permissions may lapse and remain undeveloped, potential new sites will need to be tested via the Site allocations and Development Management Plan. Because of this uncertainty and the need to retain flexibility around our ability to meet 5 and 15 year housing land supply requirement, we propose to build in a 10% contingency (e) to allow for this.

3.20 All of the above would mean working to a target of 3,418 between 2011 and 2028, which is equivalent to 201 per year.

3.21 The issues associated with pursuing this level of housing growth are that: • the capacity work suggests that this target can be met • 201 dwellings per annum better reflects recent levels of housing delivery • this level of housing improves the ability to address pressing affordable housing need both in terms of numbers and the range of household needs • the level of development is within the environmental capacity of the town • estimates of the resultant workforce which will arise from this level of housing growth is consistent with the regeneration agenda and the capacity to provide new employment locations and attract and retain jobs locally • it helps take into account the current downturn both nationally and locally in the housing market, and the subsequent fall in completions figures in recent times, it may be a number of years before we see house building return to more normal levels in Hastings. • the current capacity assessment shows a sizeable reliance on high-volume schemes involving the development of flats. Whilst the outlook for the housing market locally remains uncertain, site viability will continue to be an issue in Hastings and developers may either delay or move away from the delivery of flats with a resultant fall in overall housing delivery.

4.0 Conclusions and Recommendations

4.1 The current assessments indicate that the capacity for new homes in the Town ranges from a minimum of some 2,480 to a maximum of about 3,800 dwellings.

4.2 It is recommended that scenario 3 (medium level growth) is adopted as the housing target for the Borough to 2028 (using a base date of April 2011).

4.3 It is recognised that, in recommending this medium level of growth, this is significantly less than the current trend-based population and household projections identified in scenario 1. However, Hastings is a built up town with tightly defined boundaries and not many opportunities for development. Therefore the town is limited in the amount of housing that it can provide. Scenario 1 would result in levels of housing growth which would vastly outweigh what could reasonably be delivered

54 in both environmental and economic terms. Whilst Scenario 2 (low growth) reduces the opportunity to provide affordable homes, provides less opportunity for people to move out of poor quality housing, may lead to higher house prices by restricting supply and does not support the regeneration agenda in helping to match housing and jobs growth

4.4 Instead, we think the best way forward is to look at deriving a housing target that allows us to maximise and support the following issues whilst remaining within the environmental constraints of the town: • the need to provide housing to support regeneration, economic and skills growth and development in the town • that we wish to promote choice around housing, encouraging higher skilled people to move into the Town and creating opportunities for younger people to remain in Hastings. This includes providing more family homes and larger sized dwellings • the need to provide more affordable housing • the need to achieve a balance between meeting other competing land use requirements – chief among these is land required for employment generating purposes

55 Appendix B – Sustainability Appraisal (SA) of Housing Target

1.0 SA Introduction

1.1 The Planning and Compulsory Purchase Act 2004 requires Sustainability Appraisal (SA) to be undertaken in the preparation of the Local Development Documents making up the Local Development Framework (LDF). The purpose of the SA process is to ensure that plans and policies take into account the principles of Sustainable Development, and that the impact of these on defined social, environmental and economic objectives is fully considered.

1.2 This document is the Sustainability Appraisal of the amended housing target for inclusion in the Core Strategy. It sits alongside the proposed target on housing provision, details of which are provided in Appendix A of this document.

1.3 The LDF SA Framework was used to appraise the revised target. This is available to view or download from No longer available online.

1.4 A full SA report will accompany the proposed submission version of the Core Strategy, due for publication during December 2011 – January 2012.

56 2.0 Sustainability Appraisal (SA) of Scenarios

2.1 This paper assesses the sustainability effects of the 3 scenarios for housing provision set out in Appendix A. These options are:

Scenario 1 – High Growth: 7,840 net new dwellings (461 per annum) up to 2028 Scenario 2 – Lower Growth: 2,478 net new dwellings (146 per annum) up to 2028 Scenario 3 – Medium Growth: 3,418 net new dwellings (201 per annum) up to 2028

2.2 The appraisal uses the existing sustainability appraisal framework set out in the Revised Scoping Report, which provides a way in which the sustainability effects of each scenario can be described, analysed and compared.

2.3 Each scenario has been scored according to its impact on the sustainability of the town, using the following criteria: Score Effect The option will have a significant negative effect on XX the sustainability objective The option will have a slight negative effect on the X sustainability objective The impact can not be predicted at this stage - ? potential/uncertain effect - No effect/direct link at this stage The option will have a slight positive effect on the sustainability objective The option will have a significant positive effect on the sustainability objective Table 1: Sustainability criteria

2.4 They have also been assessed and scored against the short, medium and long term. The definitions used are as follows: Short term (S) – 0-5 years Medium term (M) – 5-15 years Long term (L) – 15+ years

2.5 The findings of the assessment are shown in table 2 below.

57 Scenario 1 - High Growth Scenario 2 - Lower Growth Scenario 3 - Medium Growth 7,840 net new dwellings (461 per 2,478 net new dwellings (146 per annum) 3,418 net new dwellings (201 per Sustainability Objective annum) up to 2028 up to 2028 annum) up to 2028 Effect Comments Effect Comments Effect Comments 1. More opportunities are The link between house The link between house building The link between house provided for everyone to S building and affordable and affordable housing provision building and affordable live in a decent, sustainably housing provision will will lead to more opportunities housing provision will lead constructed and affordable lead to more opportunities being provided. to more opportunities being home M being provided. This provided. option will provide the most opportunities. L

2. The health and well-being Health and well being Health and well being may Health and well being may of the population is may improve if there are improve if there are more improve if there are more improved and inequalities in S /? more opportunities for ? opportunities for everyone to live ? opportunities for everyone health are reduced everyone to live in a in a decent home. to live in a decent home. decent home. This option will enable more affordable housing to be M /? targeted at those in ? ? greatest need.

L /? ? ?

3. Levels of poverty and May result in a more May result in a more mixed May result in a more mixed S social exclusion are mixed community and community and greater community and greater reduced and the deprivation greater investment in investment in deprived areas investment in deprived gap is closed between the M deprived areas areas more deprived areas in Hastings and the rest of the L town

58 4. Education and skills of S - No direct link - No direct link - No direct link the population improve M - - - L - - - 5. All sectors of the New housing does not New housing does not have a New housing does not have community have improved have a direct link to direct link to accessibility, and this a direct link to accessibility. accessibility to services, S ? accessibility. However, ? level of growth will have the least ? However, this level of facilities, jobs, and social, this level of growth will effect in terms of access to growth will create some cultural and recreational create significant demand services as it provides for the demand but does not opportunities but does not necessarily fewest dwellings. Impact will necessarily provide for M ? provide for improved ? depend on levels of social ? improved accessibility. accessibility. Impact will infrastructure provided with new Impact will depend on depend on levels of social development. levels of social infrastructure provided infrastructure provided with with new development. new development. L ? ? ?

6. Safe and secure No direct link, although No direct link, although design No direct link, although S environments are created - design policies should - policies should incorporate - design policies should and there is a reduction in incorporate 'Secure By 'Secure By Design Principles' for incorporate 'Secure By M crime and the fear of crime - Design Principles' for - larger developments - Design Principles' for larger larger developments developments L - - - 7. Vibrant and locally S - No direct link - dependent - No direct link - dependent on - No direct link - dependent distinctive communities are M - on design policies and - design policies and type/mix of - on design policies and created and sustained L - type/mix of housing - housing - type/mix of housing 8. Land and buildings are Will encourage the re-use Will encourage the re-use of Will encourage the re-use used more efficiently and of existing buildings and existing buildings and more of existing buildings and urban renaissance S more efficient use of land efficient use of land through more efficient use of land encouraged through higher density higher density development, through higher density development, although although also dependent on development, although also

59 also dependent on location and type of new dependent on location and location and type of new development. type of new development. M development. This option is likely to do this to the highest extent. This scenario will increase the pressure to build on more Greenfield land and in L environmentally sensitive areas.

9. Biodiversity is protected, Higher levels of Still potential for impact on Higher levels of conserved and enhanced development likely to biodiversity - require mitigation development likely to have S X have greater impact on ? through policy ?/X greater impact on biodiversity, as it will biodiversity, as it will involve development of a involve development of a greater number of sites, greater number of sites. likely to comprise Encourage development in M X significant Greenfield ? ?/X built up area first, although development. Will need to still has potential for effect encourage development on biodiversity. Require in built up area first, mitigation through policy although still has potential L X for effect on biodiversity. ? X Require mitigation through policy. 10. The risk of flooding Risk mainly dependent on (fluvial & tidal) and coastal S ?/X location of development. ? ? Mitigation measures to Mitigation measures to reduce erosion is managed and However, high levels of reduce surface water run­ surface water run-off etc, and reduced now and in the development more likely off etc, and development development located away from future M to increase flood risk from located away from areas of ?/X ? areas of risk - Use of Strategic ? surface water run-off, risk - Use of Strategic Flood Flood Risk Assessment (SFRA) regardless of mitigation Risk Assessment (SFRA) and sequential test L ?/X measures. ? ? and sequential test

11. Parks and gardens, May result in more May result in more pressure for May result in more pressure S countryside, coast and the X pressure for development X development in these areas. An X for development in these

60 historic environment/ in these areas. An increasing population may also areas. An increasing M townscape and landscape X increasing population X result in increased use of these X population may also result are protected, enhanced may also result in areas in increased use of these and made more accessible L increased use of these areas X areas X X 12. Air pollution is reduced Construction of greater Construction of greater numbers Construction of greater and air quality continues to S X numbers of housing is X of housing is likely to contribute to X numbers of housing is likely improve likely to contribute to pollution. Mitigate through other to contribute to pollution. pollution. This option policy e.g. low emission Mitigate through other likely to have the most development policy e.g. low emission M X negative effect, X X development particularly over longer term. Mitigate through L XX other policy e.g. low X X emission development 13. The causes of climate All new development will All new development will result in All new development will change are addressed S X result in additional X additional pressure on resources, X result in additional pressure through reducing emissions pressure on resources, including water and energy. on resources, including of greenhouse gases including water and However, locating development in water and energy. The (mitigation) and ensuring energy. The greater accessible locations and ensuring greater number of homes the Borough is prepared for M XX number of homes will X sustainable design through X will mean the most its impacts (adaptation) mean the most significant design briefs will help to mitigate significant effect. However, effect. However, locating this. locating development in development in accessible locations and accessible locations and ensuring sustainable design L XX ensuring sustainable X XX through design briefs will design through design help to mitigate this. briefs will help to mitigate this. 14. Water quality of More homes may lead to More homes may lead to greater More homes may lead to freshwater bodies, S X greater amounts of X amounts of sewage, waste water X greater amounts of sewage, waterways and the marine sewage, waste water and and increased levels of water waste water and increased environment is maintained M X increased levels of water X consumption. Mitigation as above. X levels of water and improved and water consumption. Mitigation consumption. Mitigation as consumption is reduced as above. above. L X X X

61 15. Energy efficiency is Higher levels of All development will provide All development will provide increased, fuel poverty is S development will provide further opportunities for on site further opportunities for on reduced and the proportion more opportunities for on energy generation, although site energy generation, of energy generated from M site renewable energy scenarios 2 and 3 to a lesser although scenarios 2 and 3 renewable resources is generation and could extent due to fewer housing to a lesser extent due to increased facilitate stand alone numbers fewer housing numbers L schemes

16. Through waste re-use, Construction of more Construction of more dwellings is Construction of more recycling and minimisation S X dwellings is likely to result X likely to result in an overall X dwellings is likely to result the amount of waste for in an overall increase in increase in the amount of waste. in an overall increase in the disposal is reduced the amount of waste. As amount of waste. M X this option provides the X X most housing, it is likely to have the most L XX significant effect over the X X long term. 17. Road congestion and Higher levels of Higher levels of development will Higher levels of pollution levels are reduced, S /X development will result in /X result in increased car use and /X development will result in and there is less car increased car use and congestion. However, new increased car use and dependency and greater congestion. However, housing development could congestion. However, new travel choice new housing generate further sustainable housing development could M /X development could /X transport options, depending on /X generate further generate further its size and location. sustainable transport sustainable transport options, depending on its L /X options, depending on its /X /X size and location. size and location. 18. There are high and No direct link No direct link No direct link stable levels of employment S - - - and rewarding and satisfying employment opportunities for all M - - -

62 L - - -

19. Economic revival in the S More better quality More better quality housing in More better quality housing more deprived areas of the housing in these areas these areas may increase in these areas may town is stimulated and M may increase business business and investor confidence increase business and successfully achieved and investor confidence investor confidence L 20. The sustained The provision of good The provision of good economic growth of the quality housing may quality housing may S borough is achieved and /? encourage more skilled /? encourage more skilled linked closely to social workers to the area. In The provision of good quality workers to the area. In regeneration turn, this could attract housing to meet this option will turn, this could attract business and investment, still attract skilled workers, business and investment. M /? resulting in an expanding /? although it may not maintain a big This level of growth is workforce and business enough workforce to attract new unlikely to have such an growth. However, it could business or support existing effect that could lead to also lead to unsustainable growth significant out-commuting. L /? levels of out-commuting. /?

21. Indigenous and inward This option will not make This option will not make more This option will not make investment is encouraged S /? more land available for /? land available for employment /? more land available for and accommodated employment related uses, related uses, but the provision of employment related uses, but the provision of good good quality homes could attract but the provision of good M /? quality homes could /? further investment to the area. /? quality homes could attract attract further investment further investment to the to the area. area. L /? /? /?

Table 2 – Sustainability appraisal of housing scenarios

63 3.0 SA - Analysis of Scenarios

Scenario 1

3.1 Scenario 1 provides for the highest number of new homes – an additional 7,840 new dwellings up to 2028 (461 per annum), based on population growth. This exceeds the former South East Plan target of 4,200 dwellings up to 2026.

3.2 Work on the Strategic Housing Land Availability Assessment (SHLAA) has indicated that this level of development cannot be accommodated on sites currently available within the town.

3.3 Performance against the social objectives is broadly positive as the provision of this level of housing will meet identified housing need and maximise the opportunity to provide affordable housing in the town. However, creating this volume of new housing will undoubtedly put significant pressure on the town’s existing services, including health provision, and the likely impact is heavily dependent on the scale, design and location of developments that will take place, as well as adequate provision of supporting infrastructure.

3.4 The effect of Scenario 1 on the environmental objectives is inevitably negative as such quantities of development result in potentially significant impacts on the towns natural resources, including biodiversity, water and energy, as well as contributing to increased congestion, air pollution and waste. In addition, this option could result in a significantly increased risk of flooding from surface water run-off, despite mitigation measures and locating development away from high risk areas.

3.5 New development on this scale will, however, provide the most opportunities for on-site renewable energy generation. It will also increase the likelihood of viable standalone schemes and the provision of sustainable transport options to serve larger developments.

3.6 Whilst the Future Housing Provision in Hastings paper is not concerned with the provision of new employment floorspace, there is a relationship between the provision of good quality housing, and the retention and attraction of skilled workers to the area, which will support existing businesses, and could in turn encourage additional businesses and investment. The provision of this number of new homes will positively affect this, but also poses the risk of increasing out commuting, since population growth is likely to outstrip the growth in job opportunities locally, leading to uncertain effect in terms of the sustainability objectives.

Scenario 2

3.7 This scenario proposes the fewest dwellings up to 2028 – 2,478 (net), which amounts to 146 per annum. This figure is based on existing allocations and planning permissions, and would not necessarily involve the allocation of any new sites.

3.8 Performance against the social objectives is positive as it still provides housing that will contribute to the towns housing needs. However, of the 3 scenarios, this level of housing development will make the smallest contribution to meeting both the demand for general market housing and identified affordable housing needs, as it proposes the fewest dwellings.

64 3.9 Any level of development has a negative effect on the environmental objectives as a whole, due to the impact on the town’s resources and the increase in congestion, pollution and waste. However, as this scenario provides the fewest number of dwellings, the negative effects are the least in comparison. Providing fewer dwellings will also reduce the ability to generate as much on site renewable energy, or support stand alone schemes. The risk of surface water flooding still remains, although fewer dwellings should have a lesser effect.

3.10 The provision of good quality housing to meet this scenario will still help to attract and retain skilled workers to the area, having a positive effect on the employment related objectives, but to a lesser degree than scenarios 1 and 3. As this scenario will provide the fewest new homes, it is expected to result in a smaller workforce, reducing the town’s ability to attract new business or support existing growth.

Scenario 3

3.11 Scenario 3 is broadly based on the level of new homes previously required by the South East Plan. The SHLAA has indicated that the majority of these homes can be accommodated on identifiable sites in the town, although some windfall allowance would still be needed. This scenario therefore, provides for a greater certainty of delivery between now and 2028.

3.12 Scenario 3 performs positively against social objectives as it also supports the provision of new homes to meet housing need, including affordable homes. However, owing to capacity issues the full identified need for affordable homes cannot be met. Development to this level will put pressure on existing services, although to a lesser extent than scenario 1.

3.13 The effect on environmental objectives is generally negative due to the impact of development on the town’s resources and the increase in congestion, pollution and waste. However, as research has suggested that this level of development can be accommodated on sites already assessed through the SHLAA, providing suitable mitigation measures are provided, the effect on the environment is likely to be less than it would be for scenario 1.

3.14 Scenario 3 performs more positively against the economic objectives, as it is expected that pursuing this level of housing growth will help support the wider regeneration agenda. Both the quantity and mix of new homes within Hastings will be important to the local economy in terms of (i) existing businesses and their ability to attract employees; and (ii) new businesses setting up or locating in the town. The right type of housing may help to retain/attract more skilled workers to the town. A more skilled workforce should enhance the ability of Hastings to attract mobile business investment and thus contribute to economic development. Unlike scenario 1, this level of development is unlikely to have such an effect that could lead to significant unsustainable levels of out commuting.

65 4.0 SA - Conclusion and Recommendations

4.1 Analysis of these scenarios has shown that scenario 1 whilst providing the most new homes scores poorly in meeting environmental objectives. Scenario 3, and scenario 2 have broadly similar impacts – the main difference being that scenario 2 (the lowest amount of housing) will not provide as many opportunities for everyone to have access to a decent home. Whilst scenario 3 (medium growth) may achieve slightly more in terms of stimulating economic revival in the more deprived parts on the town; and will go further in meeting housing need.

4.2 Given the regeneration vision of the Plan, scenario 3 is the preferred way forward. Mitigation measures for this level of development will be achieved through policies in the Core Strategy which aim to protect the environment, ensure good design and provide the necessary infrastructure to support development.

66