Matter 3 – HBC, SR8 APPENDICES INDEX Appendix A HBC letter to ESCC 25 February 2016 Appendix B ESCC Cabinet Report 8 March 2016 Appendix C HBC comments on the draft Waste & Minerals Sites Plan 19 August 2014 Appendix D HBC comments on the draft Waste & Minerals Plan 09 December 2015 Appendix E Queensway Gateway Road Letter of Support from Rupert Clubb, Director of Communities, Economy & Transport 5 August 2015 Appendix F Statement from John Shaw, Chief Executive, SeaChange Sussex Appendix G Statement from Kerry Culbert, Planning Policy Manager, HBC Appendix H Hastings Local Plan, Hastings Planning Strategy 2011-2028 (adopted 19.02.14); Hastings Local Plan, Development Management Plan (adopted 23.09.15); Hastings Local Plan, Policies Map, Development Management Plan (adopted 23.09.15) (incorporating Planning Strategy Policies adopted 19.02.14) Appendix A Please quote: Your reference: Date: 25th February 2016 Please ask for: Kerry Culbert Telephone direct: 01424 783304 E-mail: [email protected] Web: www.hastings.gov.uk/planning Regeneration and Culture Aquila House, Breeds Place Hastings, East Sussex TN34 3UY Mr Tony Cook Planning Policy and Development Management Planning Services Communities, Economy and Transport County Hall St Anne’s Crescent Lewes East Sussex BN7 1UE By email and by post Dear Mr Cook Thank you for the opportunity to meet with yourself and Sarah Iles on the 9th February to discuss your potential proposed Main Modifications to the Waste & Minerals Sites Submission Plan (W&MSP). We also welcomed your invitation to Rother District to attend in light also of that Council’s concerns with the Plan. We were encouraged by the fact that you are now proposing some “Main Modifications” to the Plan prior to submission but I felt extreme disappointment that at the meeting it appeared that your proposals were a “final offer” rather than any realistic opportunity to further consider Hastings outstanding concerns. Since the meeting I have had the opportunity to discuss matters with our Lead Member for Regeneration, Communities & Culture. As I emphasised at our meeting you will be aware of the strength of our Cabinet’s response regarding your proposed submission plan. I am accordingly now charged to write formally to you to express our disappointment that following our meeting we remain concerned that despite our previous initial comment of support in principle for the draft W&MSP providing it was not in conflict with our emerging Development Management Plan (DMP) that there has been no direct or indeed any further liaison since that original comment when clearly we consider that there is now significant conflict with our now adopted DMP. We do not feel this approach meets the spirit of the Duty to Co-operate – and that this situation we are now in might otherwise easily have been avoided. 1. Firstly – just to reaffirm that my Council’s Cabinet resolution is very strong and that, whilst welcoming what we see as being clearly a move in the right direction, what is on the table at present (via your proposed “ Main Modifications”) simply does not meet this Council’s concerns. Whilst points 3 and, to some extent 4, of the Cabinet resolution have been addressed, points 1 and 2 have not really been touched upon. 2. We do welcome the deletion of the land at Whitworth Road which we have previously expressed concerns about – this addresses our Cabinet resolution at point 3. 3. However we remain particularly concerned at the inclusion of almost all of the DMP employment land allocations as areas of search or opportunity for waste purposes (the exceptions being Hastings town centre and your own land east of Queensway) and the apparently blanket ‘acceptable in principle’ approach to existing industrial estates. Appendix A 4. With regard particularly to the DMP’s employment allocations on land West of Queensway – this approach, as promulgated in your Plan will significantly undermine one of the principal planks of our economic strategy – of delivering a high quality, easily accessible employment corridor – capable of significantly raising the quality, number and prospects of job opportunities within the Borough. This remains the main strategic thrust of our DMP and Planning Strategy for employment land and growth and underlines our concerns regarding the W&MSP as currently drafted and its adverse impact upon this strategic objective. 5. The inclusion of the Queensway land also seems to be at odds with what your Council has supported, from an economic development perspective, at our EIP in respect of what our DMP is trying to achieve. And also in terms of the support given by your Council for the proposed Queensway Gateway Road, a strategic piece of highways infrastructure that has recently been approved and which greatly enhances this employment corridor and its ability to deliver that strategic employment corridor. 6. The use of this land west of Queensway for waste management purposes might well also impact adversely upon Marline Valley SSSI in terms of air quality, disturbance and risk of pollution for example. 7. Whilst we welcome the proposed additional wording and references that are now within the proposed “Main Modifications” to the W&MSP, to our own DMP and Planning Strategy (Local Plan) we fear these could all too easily be overridden in the event of an application being considered. 8. In determining the appropriate level of new employment needed over the lifetime of the Local Plan, the Council has had due regard to the continuing need for regeneration. The Hastings Planning Strategy seeks to protect and enhance the Borough as a major centre of diversified employment, and to that end it proposes up to 70,000 sq m of employment floorspace during 2008-2028. The DMP employment allocations are clearly needed to meet this target which is now enshrined within the adopted Planning Strategy. We are greatly concerned as outlined at (3) above, that since the scale of what might be needed or proposed for waste management purposes is not clear at this stage the impact on allocated sites and existing IEs and ultimately the Council’s ability to meet its own Local Plan employment targets will be seriously undermined. 9. In fully accepting the need for waste and recycling facilities to be located close to the point of waste generation, in order to serve a growing Hastings and Rother population, we consider that there are clear and much more preferable alternatives that will not cause such damaging impacts upon the successful delivery of jobs within Hastings. There is considerable merit in looking at the Burgess Road area (land within Hastings and Rother) to provide for the future waste needs of both Authorities. That said, the current planning application at Burgess Road both vindicates our DMP allocation and emphasises our concerns as expressed to yourself at our recent meeting as to the apparent lack of rigour your Council has shown in the drafting of its Plan in terms of approaching landowners. We will of course be pleased to continue to be available to discuss this matter further and would again urge you to reconsider our concerns and point 4 of my Cabinet’s resolution to submit a revised proposed Submission version to more appropriately address these concerns. As matters stand we feel that we will have no option but to maintain our formal objection to the Submission Plan. May I finally take the opportunity to clarify our understanding of what you advised us at the meeting of 9th February, namely that you do not intend to separately publish your proposed Main Modifications for public consultation but instead expect that these will be consulted upon at the same time as any Main Modifications that may be recommended by the Inspector appointed to examine the Plan. I further understand that you are intending to report upon the matter of the Plan to your forthcoming Cabinet on the 7th March. Yours sincerely, Kerry Culbert Planning Policy Manager Cc Cllr P Chowney – Leader, Hastings Borough Council Cc Cllr Dawn Poole – Lead Member Regeneration, Communities & Culture Appendix B Report to: Cabinet Date of meeting: 8 March 2016 By: Director of Communities, Economy and Transport Title: East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan – Regulation 19 Consultation – Response to Objections Purpose: To agree an initial response to Objections received during the Regulation 19 Consultation on the Waste and Minerals Sites Plan to be submitted to the Inspector as part of the Public Examination, and, seek delegation to officers to agree and consult on draft Main Modifications to the Plan. RECOMMENDATIONS: Cabinet is recommended to: (1) Agree, subject to the endorsement of Brighton & Hove City Council and the South Downs National Park Authority, to the proposed approach to the Objections to the Pre- Submission Waste and Minerals Sites Plan and, to the submission of draft Main Modifications to the Inspector as included in Appendix 3, and thereby, alter the Minerals and Waste Development Scheme to reflect the revised programme; (2) Authorise the Director of Communities, Economy and Transport to agree, in consultation with Brighton & Hove City Council and South Downs National Park Authority, for subsequent public consultation, the draft Main Modifications and any further Main Modifications arising from the Public Examination necessary to make the Waste and Minerals Sites Plan sound, except where any subsequent change would involve a significant shift in the policy approach whereby this would be referred to Cabinet for approval prior to public consultation; (3) Authorise the Director of Communities, Economy and Transport to make, if necessary, minor changes to the document arising from any views of the City Council and National Park Authority, or, arising from the Public Examination; and (4) Note that all Main and Minor Modifications to the Plan will ultimately be presented to Cabinet and Full Council in due course as part of the Adoption of the Waste and Minerals Sites Plan 1.