The Planning Inspectorate
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The Planning Inspectorate Room 3/25 Hawk Wing Direct Line 0117-372 8848 Temple Quay House Switchboard 0117-372 8000 2 The Square Fax No 0117-372 6298 Temple Quay GTN 1371-8848 Bristol BS1 6PN e-mail: [email protected] http://www.planning-inspectorate.gov.uk Mr Derek Stevens Chief Executive Your Ref: Rother District Council Town Hall Our Ref: DP 532 BEXHILL-ON-SEA East Sussex Date: 13 December 2005 TN39 3JX Dear Sir ROTHER DISTRICT LOCAL PLAN INQUIRY INTO OBJECTIONS 1. I was appointed by the First Secretary of State to hold a public inquiry into objections to the above-mentioned Plan. A pre-inquiry meeting was held on 16 July 2004. The inquiry itself was held between 19 October 2004 and 20 May 2005 and sat on a total of 47 days (the equivalent of 43.7 full days). I was aided at the inquiry and during the writing of the report by my Assistant Inspector – Mr Robert Watson and we are in full agreement about the recommendations in the Report. Before, during and after the inquiry, Mr Watson and I made a series of unaccompanied visits to sites that were the subject of objections. We also made several accompanied visits during the inquiry. Between us we spent a total of 21 days making site visits. My report into the objections is attached to this letter. 2. Although it had been preceded by a Consultation Draft published in 1995, the formal processes of the Rother District Local Plan have followed the two-stage deposit process. In the first stage, the Initial Draft Rother District Local Plan was placed on deposit in January 2001. After the abandonment by the Government of a proposal for a by-pass for Hastings and Bexhill, a further informal Draft Planning Strategy for Rother District was issued for consultation purposes. There then followed the second formal stage with the preparation of the Revised Draft Rother District Local Plan. This commendably brief and succinct document incorporated considerable re- writing of the Initial Deposit version. It was placed on deposit in November 2003. The Revised Deposit Local Plan was the substantive document that was before me at the Inquiry. 3. Many of the original objections to the Initial Deposit Local Plan were withdrawn as a result of the changes that had been made. However there remained a significant number of outstanding objections and representations that had been submitted in respect of the Initial Deposit Local Plan which required to be considered in the context of the changes which had been made at the Revised Deposit stage. These included objections to text which had been removed from the Plan. 4. At the close of the inquiry, the position on representations in respect of the Initial and Revised Deposit versions of the Local Plan was as follows: • Number of duly made representations received:- Initial Deposit 1357 Revised Deposit 1133 TOTAL 2490 • Number of supporting representations Initial Deposit 55 Revised Deposit 198 TOTAL 253 • Number of representations commenting on the Plan Initial Deposit 65 Revised Deposit 86 TOTAL 151 • Number of objections received Initial Deposit 1237 Revised Deposit 837 TOTAL 2074 • Objections unconditionally withdrawn Initial Deposit 867 Revised deposit 131 TOTAL 998 • Objections dealt with at the inquiry 200 • Objections dealt with by written representations 870 TOTAL 1070 (includes objections that were conditionally withdrawn) 5. I have considered all the representations on the Plan including representations of support as well as the objections, and all the issues raised. In considering the objections, I have had regard to submissions made by or on behalf of the various objectors and the Council and to all other material considerations including, where appropriate, current national Planning Policy Guidance (PPG) notes, Planning Policy Statements (PPS) and Circulars. References to Government policy and advice usually relate to the versions that were extant at the close of the inquiry. However I do make reference to further Government advice and policy statements issued since the closure of the Inquiry. The Council will also need to take into account any PPG, PPS, Circular or other Government advice published subsequent to the completion of my report. There will be a general need when the Local Plan is adopted to update the specific references which the Plan makes to these policy documents and guidance. 6. I have not had regard to other changes in planning circumstances subsequent to my closing the inquiry as I have not received evidence or representations thereon. The Council will need to take any such changes into account in its consideration of my recommendations. 7. Objections have been considered in the light of the case Electricity Supply Nominees Ltd and others v Secretary of State for the Environment and Northavon District Council / Kingswood Borough Council. In relation to many objections there was inadequate justification of the case for modification of the Plan. 2 8. For convenience, my report is divided into 16 sections. Sections 1 to 14 reflect the way that the Plan itself was organised. Section 15 refers to objections to the Proposals Map and Inset Maps where these are not dealt with elsewhere. I also attach various appendices. These deal with the following matters: Appendix 1 List of Persons Appearing for the Objectors at the Inquiry Appendix 2 List of Persons Appearing for the Council at the Inquiry Appendix 3 Summary List of Recommended Modifications Appendix 4 List of Representations (including withdrawn objections) Appendix 5 List of Core Documents Appendix 6 List of Objectors’ Proofs of Evidence and Statements Appendix 7 List of the District Council’s Proofs of Evidence and Statements. 9. I have utilised a skeleton report provided by the Council. I have made some changes where there were obvious anomalies. In particular, I have in many cases moved representations from the position to which they were previously assigned in the skeleton report. For example, objections that seek the addition of development site allocations which were omitted from the Revised Deposit Local Plan were to be found in the skeleton report variously recorded as objections to: Section 4 (Development Strategy); the Proposals Map and Inset Maps; or to Sections of the Plan which deal with particular settlements. These are now usually grouped in the settlement sections and I have included appropriate cross-references. 10.I have deleted the original Section 16 of the Skeleton Report which included a number of general and miscellaneous objections to the Plan that had not been assigned to any part of the Revised Deposit Local Plan. These are now to be found in Section 1 alongside other similar objections. However I make additional reference elsewhere in the Report to those single objections which also relate to a series of identified policies and provisions throughout the Plan. 11.For each subsection of the Local Plan, I present a list of the representations and a list of relevant issues together with my reasoning, conclusions and recommendations. With the support of the Council, a short reporting style has been adopted that does not also seek to summarise the cases for the parties although I have made brief references where this would assist understanding of the issues. I have considered the full range of issues raised in respect of each objection notwithstanding the fact that they are not all mentioned in my report. In addition, because I have sought to avoid excessive repetition, further arguments that may be relevant to any particular objection may be found in other parts of the report. 12.Before the Inquiry opened, the Council advertised a number of proposed pre- inquiry changes and further proposed changes. These proposed changes were themselves placed on deposit in July 2004 and September 2004 so that formal representations could be made. There has thus been an opportunity to comment on the pre-inquiry changes. A further proposed change concerning Etchingham was advertised during the inquiry in January 2005. Whilst all these changes are not part of the substantive draft Local Plan, I have been able to taken into account in writing my report all the representations which were received in response to these advertised changes. 13.I have also had regard to the unadvertised Inquiry Changes suggested by the Council’s officers during the Inquiry and which are summarised in Core Document 1.38. Most of these changes were referred to at the inquiry or in 3 the Council’s written representations and I have taken into account any relevant comments made in writing or at the Inquiry by respondents. The changes carry less weight where they have not been endorsed by the Council or where they were opposed at the Inquiry by the individual whose objection they sought to address. 14.I have included the text of the Council’s proposed changes in my reasoning on the relevant parts of the Local Plan. Main Issues 15.The Rother District Local Plan is to be the first district-wide local plan for Rother District. It has had a long gestation period since the publication in January 1995 of the Consultation Draft Local Plan. There are a number of matters that have been particularly controversial and on which I now summarise my main conclusions as follows:- Housing Supply 16.The East Sussex and Brighton and Hove Structure Plan 1991-2011 requires the provision of 5500 dwellings in Rother District. In 2004, the residual requirement from this total was 2560 dwellings. There has been much debate about whether the Structure Plan housing requirement can and will be met through the development of allocated sites and as a result of windfall developments on large and small sites including existing commitments.