- Eastbourne Borough Council

The Eastbourne Plan:
Core Strategy Submission Version
Statement of Consultation
(Regulation 30(1) (d)
31st January, 2012
CONTENTS
Page No
1.
INTRODUCTION
3
2.
ISSUES AND OPTIONS CONSULTATION STAGE
9
3.
PREFRRED OPTIONS CONSULTATION STAGE
4.
SPATIAL DEVELOPMENT OPTIONS AND SUSTAINABLE NEIGHBOURHOOD
ASSESSMENT CONSULTATION STAGE
17
5.
PROPOSED CORE STRATEGY CONSULTATION STAGE
APPENDICES:
Appendix 1: Specific, General and Other Consultation Bodies
Appendix 2: List of Consultation Supporting Documents
Appendix 3: Cabinet Report (7th September, 2011)
Appendix 4: The Eastbourne Plan: Proposed Core Strategy 2006-2027
(December 2010) – Consultation Report
12
28
1.
INTRODUCTION
1.1.
This Statement of Consultation has been prepared in accordance with
Regulation 30 (1) (d) of the Town and Country Planning (Local Development)
(England) Regulations 2004, as amended by the Town and Country Planning
(Local Development) (England) (Amendment) Regulations 2008 and the Town
and
Country
Planning
(Local
Development)
(England)
(Amendment)
Regulations 2009. Its purpose is also to show how the preparation of the Core
Strategy Development Plan Document complies with the Council’s adopted
Statement of Community Involvement.
1.2.
The Statement of Consultation meets the requirements of Regulation 30
(1)(d) by setting out:
•
Which bodies and persons the local planning authority invited
to make representations under regulation 25 or regulation 26,
•
How
those
bodies
and
persons
were
invited
to
make
representations under either of those regulations,
•
A summary of the main issues raised by the representations
made pursuant to either of those regulations, and
•
How any representations made pursuant to either of those
regulations have been taken into account.
1.3.
The Eastbourne Plan (Core Strategy) has evolved over the last 5 years
through consultation with local people and civic groups. Eastbourne Borough
Council has also worked with its partners in Wealden District to ensure that
the technical research that informed this plan is complimentary for both
administrative areas that cover the wider Eastbourne and southern Wealden
area.
1.4.
What has grown out of all of that work is a strategic spatial plan that will
replace some policies within the existing Eastbourne Borough Plan and shape
the sustainable development of Eastbourne for the next 15 years.
1.5.
The Eastbourne Plan aligns closely with the government’s drive for localism
and the sustainability. It focuses on the protection of the high quality urban
3
and green Environment; and it has a strong emphasis on building healthy,
sustainable and just communities.
By separating the plan area into 14
distinct neighbourhoods local people have for the first time been able to
become more closely involved in shaping the future of their communities.
1.6.
The Statement of Consultation:
•
Identifies the different stages of consultation that have taken place
in preparation of the Plan (Section 2);
•
Lists the specific and generic consultation bodies as well as
individuals invited to make representations (Appendix 1);
•
Describes the methods that have been used to engage with the
consultation bodies and individuals (Section 3);
•
Provides a summary of the key issues raised at each key
consultation stage; and
•
Shows how the representations and key issues have been taken into
account as the Plan has developed. A more comprehensive analysis
is provided in the accompanying Consultation Report (Appendix 4).
1.7.
Eastbourne Borough Council has placed engaging with local communities at
the heart of decision-making for many years and is therefore confident that
the
extensive
and
inclusive
consultation
exercises
that
informed
the
Eastbourne Plan are fully in accordance with published Government guidance.
1.8.
The preparation of the Core Strategy has involved considerable background
research, evidence gathering and a wide and varied range of consultation
exercises that have sought to gain the views and opinions of the local public
and
stakeholders.
Eastbourne
The
Borough
Statement
Council
has
of
met
Consultation
all
the
demonstrates
necessary
how
consultation
requirements as amended throughout the process.
4
Overview of Key consultation Stages and compatibility with statement of
community involvement
1.9.
The list of the specific consultation bodies and general consultation bodies1
the Council formally sought representations from is provided in Appendix 1.
1.10. The precise details of each consultation stage and a full record and analysis of
all the comments and feedback is provided in Appendix 2. All of the relevant
supporting documents that have informed this document are available to view
on the Council’s website at www.eastbourne.gov.uk
Key Consultation Stages
1.11. The key consultation stages are set out as follows. Further details about each
stage is provided in Section 3:
• Issues and Options (May 2005 – September 2005)
• Preferred Options (November 2006 – February 2007)
• Spatial Development Options (November 2009 to January 2010)
• Proposed Core Strategy (December 2010 to March 2011)
Compatibility with Statement of Community Involvement
1.12. The most important document that has guided the approach to consultation
throughout
the
various
the
consultation
stages
is
the
Statement
of
Community Involvement (SCI). The SCI was originally approved by Cabinet in
April 2006 and published in May 2006. It was subsequently updated to take
into account new regulations and policy guidance and the Technical Update
was approved by full Council in July 2009.
1.13. The SCI provided details of how the local community can get involved in the
preparation of planning policy. It identified the key groups that the Council
seeks to consult with; the underlying intention being to engage with anyone
who has an interest in the future of the town, as a place to live, work or visit.
1
Before the regulations changed in 2008, these bodies were known as statutory and non-statutory
consultees respectively.
5
1.14. The Town and Country Planning (Local Development) (England) (Amendment)
Regulations 2008 prescribed a series of stakeholders that the Council should
consult with during each consultation stage (see list in Appendix 1). The
Council also engaged with house builders, developers and landowners who
are interested in developing land or buildings for an alternative use.
1.15. The Council has a commitment to engaging with the Eastbourne Strategic
Partnership (ESP)2 in the preparation of the Local Development Framework
(LDF). The ESP contains several organisations that the Council already has a
statutory duty to consult with, as well as some additional organisations that
have an important role to play in the Eastbourne’s future prosperity. The ESP
has had the opportunity to discuss, debate and endorse many of the relevant
planning policy documents before they are agreed for distribution to the wider
community. It includes the following organisations:
• Sussex Police;
• 3VA (formerly Eastbourne Association of Voluntary Services);
• Eastbourne Momentum;
• East Sussex County Council;
• Eastbourne & District Chamber of Commerce;
• Eastbourne Borough Council;
• NHS East Sussex Downs and Weald Primary Care Trust;
• East Sussex Adult Learning and Skills Partnership;
• Eastbourne Community Environment Partnership;
• Eastbourne Housing Partnership;
• East Sussex Fire & Rescue; and
• Eastbourne Community Network.
2
The Eastbourne Strategic Partnership is a body of organisations working together collaboratively for the
Borough’s future.
6
1.16. In addition, the Council maintains a frequently updated mailing list of local
organisations that have expressed an interest in being consulted on planning
policy. The Council recognises the valuable input that these organisations
provide giving an alternative perspective on how the Borough should change
over the course of the plan period. They include:
•
Voluntary organisations;
•
Organisations which represent the interests of different racial,
ethnic or national groups;
•
Organisations which represent different faith groups;
•
Organisations which represent the interests of disabled persons;
•
Organisations which represent the interests of businesses operating
in Eastbourne; and
•
Organisations which represent amenity, conservation, recreational
and any other interests.
1.17. Finally, the Council has a commitment to engage with hard to reach groups
(those that may not have tended in the past to be involved in the planpreparation process but whose views are invaluable to ensuring a genuinely
sustainable and inclusive Plan). The Council recognises that more specialised
methods of consultation are needed to ensure that vulnerable and hard to
reach groups have an equal opportunity to have their say. The Council has
identified the following four specific groups that it made specific efforts to
involve in the plan-making process:
• People who do not speak English as their first language;
• Young people;
• People with learning difficulties; and
• Minority faith groups and other minority groups.
1.18. As well as providing information about the stakeholders, businesses,
organisations and all of the groups that the Council will consult with, the SCI
7
also lists the basic consultation standards employed on all of the LDDs. In
particular:
•
Copies of all documentation and any supporting information were
available
to
view
on
the
Council’s
website
at
www.eastbourne.gov.uk and at the Council’s main office at 1 Grove
Road, Eastbourne during office hours for the whole consultation
period;
•
Copies of the relevant documentation were sent to all statutory
consultees and any other targeted groups where appropriate.
•
A notice was placed in the local newspaper (Eastbourne Gazette)
and on the Council’s website at www.eastbourne.gov.uk. This
advised where and when the document can be inspected, how
copies can be obtained, what the closing date is, and where to send
representations”.
1.19. Paragraph 2.3.3 of the SCI states that “The consultation period will last for 12
weeks for a Local Development Document…as set out in the ‘Compact’
agreement in the East Sussex Integrated Sustainable Community Strategy”.
Each of the consultation stages has therefore taken place over a 12-week
period rather than the statutory 6-week period required in the Regulations.
This is an example of one the many ways in which the Council is committed
to exceeding the minimum requirement to ensure that more people from
different communities have had an opportunity to input into the plan-making
process.
8
2.
ISSUES AND OPTIONS CONSULTATION STAGE
Purpose of Consultation Stage
2.1.
The Council embarked on an information gathering process to determine the
needs and issues relevant to Eastbourne that should be considered in the
Core Strategy. Consultation on the Issues and Options took place from May
2005 to September 2005.
2.2.
Regulation 25 of the Town and Country Planning (Local Development)
(England) Regulations 2004 required local planning authorities to undertake
consultation with each of the specific consultation bodies, and general
consultation bodies (as appropriate) during the Issues and Options stage of
preparing the Core Strategy. All work on the Issues and Options was carried
out before amendments were made to regulations3.
Consultation Methods Used
2.3.
A notice informing local residents of the Issues and Options consultation
exercise was placed in the local newspaper. Discussion papers were mailed
out to 333 Eastbourne residents and 234 other stakeholders on the LDF
mailing list. In addition there were displays in two shopping centres (Arndale
Shopping Centre and Langney Shopping Centre) and the Central Library.
Copies of the discussion paper were also made available at the Council Offices
at 1 Grove Road, Eastbourne and on the Council’s website. Stakeholders were
invited to complete a questionnaire on a number of proposed strategic
options and 75 completed questionnaires were returned.
2.4.
In addition, a focus group session took place on 28th June 2005, which
identified
a
series
of
regeneration/economy;
key
priorities
community,
including
health
and
environment;
social
care;
housing;
skills
and
learning; and crime and disorder.
3
These amendments eliminated the statutory requirement for local planning authorities to undertake and
Issues and Options consultation stage.
9
Summary of Consultation Responses and Key Issues Arising
2.5.
A number of key recurring themes emerged from the analysis. These are set
out below:
•
Transport (lack of appropriate services and infrastructure)
•
Concern that additional development is not supported without
appropriate infrastructure in place
•
There is strong support for attracting better paid jobs and
affordable housing
•
There is a need to establish a wider range of shops and support
local business
2.6.
A statistical analysis paper was produced to pull together the responses from
the Issues and Options Consultation Document “Shaping a Future Together”.
This paper along with the Community Strategy (2005-2020) and emerging
South East Plan (2006-2026) helped to inform the production of 11 key
strategic themes.
2.7.
The key themes formed the basis for 11 working groups. The key themes
were orientated around questions that a Preferred Option would answer. The
members of each working group reflected the interests and organisations that
were critical to answering each of the questions. These comprised of both
internal and external representatives. The working groups worked to the
same meeting structure as follows:
• Discussion of issues;
• Discussion of evidence (documents and reports) to inform the issues;
• Creation of vision and spatial objectives;
• Creation of spatial options to deliver the spatial objectives;
• Sustainability appraisal of the spatial options; and
• Arrival at the preferred options.
10
2.8.
This led to the creation of a topic paper for each key theme pulling together
the issues, evidence and highlighting the conformity with national, regional
and local documents, in particular the emerging South East Plan and
Community Strategy. The findings of the topic papers were used to influence
the Council Preferred Option.
11
3.
PREFRRED OPTIONS CONSULTATION STAGE
Purpose of Consultation Stage
3.1.
The Preferred Options report set out to describe the overall vision, objectives
and strategy for the Borough up to 2026. It was the first Local Development
Framework Document other than the Statement of Community Involvement
that the Council had produced. It was produced closely along the lines of the
East Sussex Integrated Sustainable Community Strategy and the emerging
Strategic Environmental Assessment/ Sustainability Appraisal. The Core
Strategy Preferred Options report included a general strategy for change as
well as a set of strategic preferred development options.
3.2.
Consultation was undertaken in accordance with Regulations 26 and 27 of the
Town and Country Planning (Local Development) (England) Regulations 2004,
which were in force at the time the consultation was undertaken but have
subsequently been amended.
Consultation Methods and Techniques Used
3.3.
Two Stakeholder Forums were held, one on 1 June 2006 to discuss the first 5
key themes, and a second on 4 September 2006 to discuss the remaining 6
key themes. This was a further opportunity for organisations and individuals
who had expressed an interest in planning policy matters along with the
statutory stakeholders, to be involved in the preparation of the topic papers
and the preferred options.
3.4.
A Preferred Options Report was produced, pulling together the preferred and
alternative options for each key theme. This was presented at both Cabinet
and Planning Committee where it was approved. The six-week formal
consultation period for the Preferred Options ran from 5 January 2007 – 16
February 2007. The report was made available for 6 weeks before 5 January
2007 in line with the County Compact, but any representations made were
held until that date. An extensive ‘Consultation Plan’ outlined the events and
timetabling for the consultation period and was made available on the
Council’s website. This enabled people to see the events that are planned
with their locations, dates and timings.
12
3.5.
As part of this consultation stage, a notice and an advertisement were placed
in the local newspaper, the Eastbourne Herald on 5th January 2007.
Documents were made available at the Council offices and in the central and
local libraries. The website provided a link to consultation software that
enabled the public to view the Core Strategy: Preferred Options Report and
accompanying documents including the Sustainability Appraisal. All of these
were web enabled so people could make representations on-line for the first
time. For those not able to make on-line representations a consultation
response form was printed for consultees to post to the Council’s Planning
department.
3.6.
In order to ensure the greatest possible participation, the consultation
exercise focused on hard-to-reach groups as well as statutory and nonstatutory stakeholders. A letter setting out the principal details contained
within the Core Strategy Preferred options report, information about the
consultation period and advice about how to make representations was sent
to statutory and non-statutory stakeholders on 6th December 2006.
3.7.
The statutory stakeholders were also sent a pack containing a copy of the
Local Development Framework: Core Strategy – Preferred Options Report,
the Sustainability Appraisal and Appendix, and response forms. The statutory
stakeholders at the time of the consultation included:
•
The Regional Planning Body: the Government Office for the South
East (GOSE);
•
Relevant local authorities adjoining Eastbourne (Wealden District
Council);
•
The Countryside Agency;
•
The Environment Agency;
•
The Highways Agency;
•
The Historic Buildings and Monuments Commission for England;
•
English Nature;
13
• The Strategic Rail Authority;
• The
Regional
Development
Agency
(South
East
Regional
Development Agency);
• Any person to whom electronic communications code applies;
• Any person who owns or controls electronic communication apparatus
situated in Eastbourne; and
• Any of the following bodies exercising functions in the local
authority’s area: Strategic Health Authority, Person to whom a
licence has been granted under Section 7 (2) of the Gas Act 1986,
Sewage undertaker, and Water undertaker.
3.8.
424 non-statutory stakeholders were sent a Local Development Framework:
Core Strategy – Preferred Options Report Summary Leaflet, Response Form
and information on how to make representations, both in paper form and
online.
3.9.
Posters and leaflets were produced advertising the consultation process.
These included an LDF Summary Leaflet, A5 leaflets, bookmarks, A4 posters,
A3 posters, comic strip posters and A3 church posters. These posters and
leaflets were distributed on Eastbourne buses, at libraries across the Borough
(Eastbourne Central Library, Hampden Park Library, Willingdon Library and
Langney Library) and at Eastbourne railway station.
3.10. As well as presentations to local interest groups nine public exhibitions were
organised. The exhibitions were open to all members of the public and took
place at the following locations:
• St John’s Parish Hall, Meads;
• Langney Shopping Centre;
• Ratton Secondary School;
• Tesco Extra, Lottbridge Drove;
• Somerfield, Hampden Park;
14
• Waitrose, Old Town;
• Arndale Shopping Centre;
• ASDA Sovereign Harbour; and
• Bourne School, Devonshire.
Summary of Consultation Responses and Key Findings
3.11. There were a total of 369 representations made on the Core Strategy:
Preferred Options report. Of these, 177 (48%) were made via the website,
and 192 (52%) were made by post.
3.12. There were a total of 72 consultees who made representations on the Core
Strategy: Preferred Options report. Of these 72, 14 (19.4%) were made via
the website, and 58 (80.6%) were made by post. This suggests that the
website was mainly used by consultees who submitted a number of
representations.
3.13. The chapter that received the highest number of representations was the
housing chapter with 95, with over 25% of all representations received.
3.14. Overall, there was no outstanding support or objection to the Core Strategy
Preferred Options report, although some parts received more support or
objection than others. The most common type of representation was ‘Support
with conditions’, which received 28% of the total representations, although
there were a similar number of observations, objections and support.
3.15. The
most
common
representation
received
was
with
regard
to
the
implications of the Preferred Options report on the Wealden district, in
particular Polegate. There were a number of comments based on a
misunderstanding that there were policies directing allocations outside of the
Borough, using Polegate to help meet the needs of Eastbourne, for example
with regard to affordable housing.
3.16. The use of Developer Contributions attracted a number of comments across
different chapters. These mainly related to the types of infrastructure, service
or facility that the monies received would go towards.
15
3.17. The policies regarding flexible change of use are mentioned in a few chapters;
however there was only one chapter where it received a high number of
representations. In general, the representations were objecting to a flexible
change of use policy and suggested that there should be sustainable criteria
on which to make the decision.
3.18. There were strong objections to policies on energy efficiency standards,
claiming that the standards outlined in the report are unrealistic and
unachievable at the present time and were therefore inappropriate for the
Preferred Options report.
3.19. The Accessibility Standards also received a significant amount of objection,
with respondents suggesting that the standards outlined did not conform to
standards used by other bodies and were contrary to national guidance.
3.20. There were also a number of representations that objected to the fact that
Gypsies and Travellers were not mentioned throughout the report, and there
were specific chapters where it was felt that Gypsies and Travellers needed
specific reference.
16
4.
SPATIAL
DEVELOPMENT
OPTIONS
AND
SUSTAINABLE
NEIGHBOURHOOD ASSESSMENT CONSULTATION STAGE
4.1.
The next key consultation stage sought to gain feedback from the local
community and stakeholders on four spatial development options and a
sustainable neighbourhood assessment that had been undertaken to provide
a better understanding of the individual characteristics of each of the town’s
14 neighbourhoods. The consultation exercise therefore comprised two
principal elements:
• Spatial Development Options; and
• Initial findings of the Sustainable Neighbourhood Assessment.
Purpose of Consulting on the Spatial Development Options
4.2.
One of the main criticisms of the first LDF Core Strategy Preferred Options
report was that it wasn’t specific enough about where change would be likely
to take place in Eastbourne and clear enough as to whether the Council had
identified enough land to meet its need for affordable housing and its housing
development targets.
A detailed capacity survey was thus undertaken by
way of a Strategic Housing Land Availability Assessment (SHLAA).
4.3.
In 2009 the SHLAA revealed a baseline position that:
•
The Council had sufficient housing land to meet targets of 240 a
year for the next 5 years; and
•
4.4.
There was a significant shortfall in years 10-20 of 416 units.
Lead Councillors were informed that we needed to find alternative sources of
housing land supply which included some greenfield development and a
windfall allowance.
Each strategic choice considered could result in a
different pattern of growth and development across the town.
4.5.
These strategic choices were initially presented as a series of 9 Spatial
Scenarios, as to where future development should be directed in Eastbourne.
Targeted
confidential
landowners
etc,
e.g.
consultation
ESCC
/
with
GOSE
key
/
partner
Environment
organisations
/
Agency/Planning
17
Inspectorate then took place during the Summer 2009.
A high level
‘strategy’ working group made up of Lead Councillors agreed the ‘Spatial
Scenarios’ and the consultation strategy for engaging with local residents /
local businesses later in the year.
The number of spatial scenarios was
reduced to 4 combined spatial development options, which were easier for
the public to understand.
4.6.
A series of interactive exhibitions then took place in each of the town’s 14
neighbourhoods over a 12-week period in the winter months led by jointly by
officers and councillors. Local people and our strategic partners could clearly
influence the spatial strategy for their area. Key members of emerging
Neighbourhood Panels were also invited to participate. Each community could
see the impact of the strategic housing choices for their local area.
4.7.
The Spatial Development Options presented four different options that could
achieve Eastbourne’s future housing requirement of 4,800 net additional
dwellings between 2006 and 2026 as established in the South East Plan. Each
of the four options had a different spatial delivery pattern and consequently
affected each of the Borough’s 14 neighbourhoods in different ways. The four
spatial development options took into consideration:
• The different types of land that were available for development;
• The different strategies that could be brought forward; and
• The sustainability of different locations and neighbourhoods.
4.8.
The aim of this consultation exercise was to provide an opportunity for the
Council to gain an understanding of the public and stakeholders’ views before
agreeing a preferred spatial development strategy for the Borough. The four
spatial development options considered are set out below:
• Option1: Urban Intensification;
• Option 2: Creating Sustainable Centres;
• Option 3: Sustainable Neighbourhoods; and
• Option 4: Greenfield Urban Extensions.
18
4.9.
Option 1: Urban Intensification -
proposed developing available brownfield
sites and a small number of Greenfield sites that were of low value and poor
quality.
4.10. Option 2: Creating Sustainable Centres
- sought to focus development in
centres which could become more sustainable by way of providing new
facilities through balanced housing-led growth. It included the Town Centre,
the Sovereign area and the Langney Shopping Centre4.
4.11. Option 3: Sustainable Neighbourhoods - proposed focusing future housing in
the Borough’s most sustainable neighbourhoods5, which currently have the
best access to services and facilities. It sought to achieve this by maximising
the density of development in specific neighbourhoods.
4.12. Option 4: Greenfield Urban Extensions - proposed extending the current
development boundary of Eastbourne to include parcels of greenfield land at
Kings Drive and Priory Heights.
Purpose of Consulting on the Sustainable Neighbourhood Assessment
4.13. The findings of a comprehensive Sustainable Neighbourhoods Assessment
were also presented and local people had a chance to inform the resulting
wider vision / policy for their neighbourhood. The Sustainable Neighbourhood
Assessment consultation engaged the community in the assessment of each
of the town’s 14 neighbourhoods. It sought to take into account residents’
views and different experiences of living across the Borough and use them to
inform the Core Strategy and ensure that it best reflected the opinions of
people living within the Borough’s different neighbourhoods.
4.14. The
Sustainable
Neighbourhood
Assessment
was
an
audit
of
each
neighbourhood. It sought to analyse in a quantitative and qualitative way how
each neighbourhood looked, felt, and functioned for its local community. It
looked at current issues and identified any future needs and improvements
4
Langney Shopping Centre was subsequently removed as having the potential to become a sustainable
centre.
5
The six most sustainable neighbourhoods were identified as Langney, Meads, Old Town, Seaside, Town
Centre and Upperton.
19
that could be made to the neighbourhood to make it more sustainable in
planning terms.
4.15. The criteria used and the results of the draft Sustainable Neighbourhood
Assessment were presented at the 15 interactive consultation events held
between November and December 2009. Different communities across the
Borough were invited to help in the assessment by commenting on what they
liked about their neighbourhood, the key issues that needed to be addressed
and any improvements that they felt should be made to the neighbourhood in
the future to make it a better place to live and/or work.
4.16. The outcome of the Sustainable Neighbourhood Assessment was used to
identify what it was that made each neighbourhood unique and sustainable,
where any problems or issues might lie, and possible ways of addressing
these issues in order to make it more sustainable. It provided the evidence
needed to develop the neighbourhood visions and policies in the Core
Strategy.
4.17. The consultation events were tailored to each specific neighbourhood and
included a number of different surveys for people to complete. The purpose of
these surveys was to support the assumptions that had been made in the
Sustainable Neighbourhood Assessment and to gather the community’s own
experiences of how each neighbourhood functions in reality.
4.18. As well as asking people to draw their own vision for their community,
members of each local community were also asked about their own
experiences in four different aspects of their neighbourhood. These included:
• Traffic and Highways;
• Litter, graffiti and vandalism;
• Trees and open spaces;
• Facilities for children and young people; and
• Pedestrian and cycling facilities.
20
Consultation Methods and Techniques Used for the Spatial development
options and the Sustainable Neighbourhood Assessment
4.19. The Spatial Development Options and the Sustainable Neighbourhood
Assessment consultation stage took place over a 12-week period from 2nd
November 2009 to 25th January 2010. The consultation exercise involved
interactive neighbourhood exhibitions at 15 different venues across the
Borough. This included one event in each of the Borough’s 14 neighbourhoods
between 2nd November 2009 and 11th December 2009, and a Borough-wide
summary event for statutory consultees, other organisations, and anyone
else that was unable to attend the neighbourhood event in his or her
neighbourhood on 15th December 2009 (see Table 1).
Table 1: Consultation Events
Neighbourhood
Date
Time
Venue
Neighbourhood 3: Seaside
Monday 2nd
3pm – 7pm
Christ Church,
November 2009
Neighbourhood 6: Roselands
Tuesday 3rd
& Bridgemere
November 2009
Neighbourhood 4: Old Town
Monday 9th
Seaside
3pm – 7pm
Courtland Road
3pm – 7pm
November 2009
Neighbourhood 7: Hampden
Wednesday 11th
Park
November 2009
Suncoast Church,
Community Wise,
Old Town
3pm – 7pm
Hampden Park
Community
Centre
Neighbourhood 14:
Saturday 14th
Sovereign
November 2009
Neighbourhood 11: Meads
Monday 16th
11am – 3pm
The Haven School
3pm – 7pm
St John’s Church
November 2009
Neighbourhood 2: Upperton
Tuesday 17th
Hall, Meads Road
3pm – 7pm
November 2009
Neighbourhood 1: Town
Monday 23rd
Elim Church,
Hartfield Road
3pm – 7pm
Salvation Army
Hall, Langney
21
Centre
November 2009
Neighbourhood 10:
Wednesday 25th
Summerdown/Saffrons
November 2009
Neighbourhood 9:
Monday 30th
Shinewater/North Langney
November 2009
Road
3pm – 7pm
Eastbourne Town
Hall
3pm – 7pm
Shinewater
Community
Centre
Neighbourhood 8: Langney
Tuesday 1st
3pm – 7pm
December 2009
Langney
Community
Centre
Neighbourhood 12:
Monday 7th
Ratton/Willingdon Village
December 2009
3pm – 7pm
St Mary’s Church
Hall, Willingdon
Village
Neighbourhood 13: St
Tuesday 8th
Anthony’s/Langney Point
December 2009
3pm – 7pm
St Anthony’s
Centre, St
Anthony’s Avenue
Neighbourhood 5:
Friday 11th
Ocklynge/Rodmill
December 2009
Borough Wide Event
Tuesday 15th
3pm – 7pm
Victoria Baptist
Hall, Eldon Road
3pm – 7pm
December 2009
Eastbourne Town
Hall
Table 1: showing the Consultation Events
4.20. In addition to this, a presentation was given to the ‘Developers and Agents
Forum on 26th November 2009, which included developers, architects, and
planning agents as well as the Eastbourne Strategic Partnership.
4.21. The consultation events were publicised extensively on the Council’s website
as well as on the local radio station, Heart FM website’s front page. Articles
explaining and advertising consultation events were also published in the
Eastbourne Herald on Friday 16th October 2009 and in the Council’s
newsletter, as well as the Eastbourne Review, which was distributed to all
households in the Borough on 16th November 2009.
22
4.22. Approximately 10,000 leaflets were distributed by Neighbourhood Watch
Volunteers, and an additional 2,000 were made available in Council buildings
and
in
community
Approximately
150
buildings
posters
and
were
shops
across
displayed
each
neighbourhood.
throughout
the
Borough
advertising the consultation events. They were delivered to local shops,
places of worship, community centres, social clubs and general notice boards;
they were also delivered to all of the venues holding consultation events and
on the day of the events, leaflets were handed out to passers-by.
4.23. Letters providing details of all the consultation events shown in Table 1 were
sent to
• Chairpersons of the Neighbourhood Panels (23rd October 2009);
• All consultees on the Local Development Framework mailing list (27
October 2009); and
• All local schools’ headteachers (5th November 2009).
4.24. All the consultation material and results including maps and data that were
specific to each neighbourhood were made available to the public after the
consultation event. These were displayed on the Council’s online consultation
portal
at:
http://eastbourne-consult.limehouse.co.uk/portal.
Stakeholders
and individuals were encouraged to respond using the online portal but were
also advised that responses could be made by post or email.
Consultation Responses: Spatial Development Options
4.25. A total of 472 people attended the consultation events, with a further 49
individuals or organisations making formal representations by post or online.
This resulted in a total of 967 responses being made in support or opposition
to
the
four
spatial
development
options.
In
addition
to
the
formal
representations received, three petitions were sent to the Council in
opposition to Option 4: Greenfield Urban Extensions.
4.26. The highest level of attendance was in Neighbourhood 5: Ocklynge & Rodmill
consultation event where 111 people attended. This was anticipated as two
Greenfield sites in the area surrounding the neighbourhood (at Kings Drive
23
and Priory Heights) had been identified for potential residential development
under Option 4: Greenfield Urban Extensions.
Table 2: showing level of support and opposition to each of the four spatial
development options proposed
Support
Oppose
Total
Respondents
Spatial
Development
Option
1:
122
40
162
Option
2:
132
61
193
3:
63
37
100
4:
12
504
516* (in
Urban Intensification
Spatial
Development
Creating Sustainable Centres
Spatial
Development
Option
Sustainable Neighbourhoods
Spatial
Development
Option
Greenfield Urban Extensions
addition, 3
petitions with
384 signatures
were submitted
Table 2: showing level of support and opposition to each of the four spatial
development options proposed
4.27. Table 2 sets out the overall level of support and opposition for each of the
four spatial development options. It demonstrates that the level of support
exceeded the level of opposition for Options 1, 2 and 3 but that there was
considerable opposition to Option 4.
4.28. In addition to the consultation exercise described above, each of the four
spatial development options was subjected to a Sustainability Appraisal,
which assessed each approach against 22 different sustainability criteria.
4.29. The Sustainability Appraisal clearly demonstrated that Option 1: Urban
Intensification and Option 4: Greenfield Urban Extensions were the least
sustainable options for future growth. The Council considered that an
approach that sought to develop on greenfield sites was inconsistent with the
24
principles of sustainable development. It therefore sought to focus on
concentrating development in existing centres which need the most action but
where there is most potential for becoming more sustainable by way of
providing facilities through balanced housing-led growth.
Table 3: showing the sustainability rankings of each of the four spatial
development options
Spatial Development Option
Sustainability Score
Ranking
Spatial Development Option 1: Urban
21
3rd
44.5
1st
30.5
2nd
19
4th
Intensification
Spatial Development Option 2: Creating
Sustainable Centres
Spatial Development Option 3: Sustainable
Neighbourhoods
Spatial Development Option 4: Greenfield
Urban Extensions
Table 3: showing the sustainability rankings of each of the four spatial
development options
4.30. Having
assessed
all
the
information
from
the
consultation
and
the
sustainability appraisal, paragraph 6.1 of the Report to Cabinet acknowledged
that: “Agreeing the proposed spatial development strategy involves some
difficult
choices.
However,
through
the
consultation
the
Council
has
considered the comments from a wide range of consultees in order to develop
an informed and ‘sound’ preferred development strategy for the Core
Strategy”. Paragraph 6.2 of the Report to Cabinet noted that “Of the four
options, Options 2 & 3 are considered the most sustainable, and deliver the
highest amount of housing growth which can help support and provide other
much needed facilities…In addition, an increase in residential density will be
sought on developments in the most sustainable neighbourhoods”.
4.31. On 26th May 2010, Cabinet approved the recommendations and supported the
spatial development approach that sought a combination of Option 2:
25
Creating Sustainable Centres and Option 3: Sustainable Neighbourhoods, on
the basis that an aggregation of the two approaches represented the most
sustainable option and the one that would be most effective in delivering the
highest amount of housing and ensure best access to shops, services and
facilities. These options also benefitted from having the support of the
majority of the people who responded to the consultation. This approach was
endorsed by full Council on 21st July 2010.
Consultation Responses: Sustainable Neighbourhood Assessment
4.32. Comments and representations were made on each of the Borough’s 14
neighbourhoods.
There were a number of key messages and common
themes that were clear from the neighbourhood consultation events. Many of
these issues affect the whole Borough whilst others were more specific to
individual neighbourhoods.
4.33. The lack of cycling facilities was a very common theme that was mentioned at
the majority of events. The over-riding feeling across the Borough was that
there are not enough cycle lanes and paths and there was a perception
amongst many people that cycling on the road was too dangerous. There was
also frustration that existing cycle lanes were not sufficiently joined up and
integrated with one another.
4.34. The lack of employment opportunities in the Borough was an issue that was
raised in a number of neighbourhoods and there was a perception that the
additional houses proposed would worsen the situation if there were not
sufficient job opportunities for new residents.
4.35. Concern was raised about the provision of buses, not only across different
parts of the town but also within individual neighbourhoods. Many people
were pleased with the quality of their bus service, however others were
unhappy because routes no longer served their area or frequencies were
poor.
4.36. Traffic levels were frequently mentioned and a number of specific locations
were singled out as having particular congestion problems. These included
areas including Kings Drive and the Rodmill roundabout, Victoria Street/Green
26
Street junction, St Anthony’s Avenue and the roundabout at Lottbridge
Drive/Seaside.
4.37. Car parking was raised as an issue in most neighbourhoods. In some
neighbourhoods, consultees complained that they were unable to find a
parking space close to their homes because there was too much on-street
parking and insufficient off-street parking for residents and visitors.
4.38. Many people across the Borough felt that there was a general lack of facilities
for children and young people. Many neighbourhoods felt there was an
existing deficiency in the number of playgrounds and play facilities. There was
also concern about the lack of activities for older children and teenagers.
4.39. There was a particular concern in Sovereign where many people felt that the
provision of services and facilities was poor. Respondents suggested that
there was a particular need for a community centre, medical centre and
additional children’s play space.
4.40. Broadly speaking, communities appeared satisfied with the neighbourhood
boundaries although there was specific concern in Sovereign that the
neighbourhood should exclude Kingsmere.
4.41. A
more
comprehensive
Neighbourhood
analysis
Assessment
is
of
the
results
of
contained
within
the
the
Sustainable
Core
Strategy
Consultation Feedback Report: Spatial Development Options & Sustainable
Neighbourhood Assessment.
27
5.
PROPOSED CORE STRATEGY CONSULTATION STAGE
Purpose of Consultation Exercise
5.1.
The outcomes of above Spatial Development Options and Sustainable
Neighbourhood Assessment consultation informed the resulting Proposed
Core Strategy also known as the Eastbourne Plan.
Led by the Local
Development Framework Steering Group, Core Strategy Policies and visions
for each neighbourhood were developed and streamlined, and a monitoring
and implementation framework added. The purpose of this additional
consultation stage was to give the general public an opportunity to comment
on the visions for each of the neighbourhoods as well as the emerging policies
and implementation framework before finalising the more formal statutory
Proposed Submission version.
5.2.
This (most recent) consultation exercise collected views on the draft Proposed
Submission Version of the Core Strategy. This was undertaken as an
additional consultation stage intended to enable any final adjustments to be
made to reflect local issues and opinions. It was also intended to demonstrate
the considerable importance that Eastbourne Borough Council places on
community engagement and thus increase the likelihood of the Core Strategy
ultimately being found “sound” by an independent planning inspector at the
Examination in Public, scheduled to take place in April/ May 2012.
Consultation Methods and Techniques Used
5.3.
The public consultation period which ran from 17th December 2010 to 11th
March 2011, included a central intensive 6 week event period between 7th
January 2011 and 18th February 2011. During this period a programme of
publicity/consultation exhibitions and 12 events were held around the
Borough to provide the residents and other stakeholders, in each of the 14
Neighbourhoods in Eastbourne, an opportunity to consider and comment on
the overall strategy and on the draft proposed policies and development
proposals. The consultation undertaken was extensive, reflecting the key
strategic importance of the Eastbourne Plan as the document, which sets out
the overarching spatial strategy for the whole Borough.
28
5.4.
The aim of the consultation was to give all those who visit, live in and work in
the Borough, an opportunity to share their views on what sort of place they
would like Eastbourne to be by 2027. This was the final opportunity for
people to get involved in shaping the future strategic direction of the
Council’s spatial development policies before the formal submission stages so
extra effort was made to provide intensive and extensive publicity coverage
to reach as wide an audience as possible. The public and stakeholders were
asked to comment on the overall vision, the key spatial objectives, policies
and individuals neighbourhoods within the Borough.
5.5.
At the end of the six week event period, the public consultation consisted of a
web based consultation, when all publicity material could be accessed online
from
the
Council’s
hosted
consultation
portal
and
through
which
representations could be submitted electronically. However publicity leaflets,
summary brochures and reply paid consultation response forms were
distributed throughout the 12 week period to local community groups,
libraries and shops as well as being available from the Council offices.
5.6.
A final public surgery event was held in the Town Hall to provide an
opportunity for people who missed their local event an additional chance to
view and ask questions. The consultation programme was intended to provide
the local community and other interested parties, a chance to see,
understand and comment on the proposed Core Strategy, and enable the
Council to gather views and opinions before preparing the formal submission
document
5.7.
As with all the other rounds of consultation it exceeded the requirements of
the Council’s adopted Statement of Community Involvement (SCI) and the
requirements of Planning Policy Statement 12 (PPS12): Local Spatial Planning
and therefore reflects the importance that the Council places on engagement
with the people of Eastbourne and the need to gather as much feedback as
possible in order to ensure the policies and options are “sound” and reflect
what the public want to see.
5.8.
Several letters advising of the consultation were sent out to various
organisations, businesses and the general public. These are detailed below:
29
• Letters to stakeholders and consultees on the LDF mailing list
informing them of the consultation events, where the document
could be viewed, and inviting them to a Stakeholder Event at the
Town Hall on 23rd February 2011;
• Letters to all those who had attended a consultation event before or
had made representations on previous LDF documents, informing
them of consultation events;
• Letters to the Headteachers of Eastbourne’s schools with an offer for
Officers to visit and provide an interactive presentation to children.
5.9.
A summary brochure was produced which provided:
• An introduction to the Eastbourne Plan;
• Details of the Vision for Eastbourne;
• The Overall Strategy for the Future of Eastbourne;
• Themes for the Eastbourne Plan;
• Details on Community-Led Neighbourhoods;
•A
development
development;
map
showing
the
road
approach
to
future
• Details about how to Have Your Say on the Future of Eastbourne;
• Information about the neighbourhood events taking place; and
• A Response Form.
5.10. This brochure was circulated to neighbourhood groups and local residents’
associations. It was also available at the receptions of civic buildings, libraries
and all of the exhibition venues. A number of local businesses and
organisations agreed to display them.
5.11. Posters advertising the consultation were displayed on Stagecoach buses, on
notice boards throughout the Borough and in all libraries. Neighbourhood
leaflets were prepared for each of the Borough’s fourteen neighbourhoods.
These summarised the key proposals for each neighbourhood, setting out the
vision and showing a diagram with the proposals for each.
30
5.12. A
dedicated
page
was
set
up
on
the
Council’s
website
(http://www.eastbourne.gov.uk/EastbournePlan). It publicised the dates and
venues of exhibitions and all other consultation events.
5.13. The
website
also
enabled
the
Eastbourne
Plan
and
accompanying
Sustainability Appraisal to be viewed and/or downloaded and provided a link
to ‘Limehouse’, the Council’s online consultation portal (http://eastbourneconsult.limehouse.co.uk/portal).
This ensured that anyone who had an
interest in the future of the town centre could make a general comment about
the Eastbourne Plan or respond to more specific questions contained within
the report.
5.14. The
Council
utilised
the
social
(www.facebook.com/EastbourneC)
networking
sites
and
of
‘Facebook’
‘Twitter’
(www.twitter.com@EastbourneBC).
5.15. A news release entitled ‘Help piece together the future of Eastbourne’ was
sent to The Herald, The Argus, BBC Sussex, Sovereign Radio, Sussex Life,
BBC South East, Meridian and Heart FM.
5.16. A public notice was placed in ‘The Advertiser’ confirming the dates of the
Issues and Options consultation, advising that the Report was available for
viewing on the Council’s website and detailing the dates and venues of the
exhibitions. The Herald also published articles on the Eastbourne Plan and the
accompanying consultation exercise. Cllr David Tutt (Leader of the Council)
was interviewed by Sovereign Radio, urging those who visit, live, work or has
an interest in the town centre to have their say on its future.
5.17. In order to provide opportunities for the public to have maximum involvement
in the consultation process, a series of exhibitions were prepared. An
unmanned, permanent exhibition was on display in the Central Library for the
entire 12-week consultation period. A partially manned, roving exhibition was
displayed at the following venues across the town:
• Sovereign Centre, Eastbourne;
• Eastbourne Andale Centre;
• Langney Shopping Centre, Eastbourne; and
31
• Old Town Library, Eastbourne.
5.18. In
addition
to
the
permanent
and
roving
exhibitions,
a
series
of
neighbourhood events took place at the following locations:
• Town Hall, Grove Road (Town Centre, and Summerdown & Saffrons;
• Elim Church, Hartfield Road (Upperton);
• St Agnes’ Church Hall,
Bridgemere);
Whitley Road (Seaside, and Roselands &
• Community Wise, Ocklynge Road (Old Town);
• Victoria Baptist Church, Eldon Road (Ocklynge & Rodmill);
• Hampden Park Community Hall (Hampden Park);
• Shinewater Community Centre,
Shinewater & North Langney);
Milfoil
Drive
(Langney,
and
• St John’s Parish Hall, Mead Road (Meads);
• St Mary’s Church, Church Street, Willingdon (Ratton & Willingdon
Village);
• St Anthony’s Centre, Seaside (St Anthony’s & Langney Point);
• The Haven School, Atlantic Drive (Sovereign); and
• Town Hall, Grove Road (Borough-wide event).
5.19. As with previous consultations, Planning Officers attended meetings with a
number of different groups and organisations giving presentations followed by
question and answer sessions. Presentations were given to the following
organisations:
• 3VA;
• Business Community Group;
• Disability Involvement Group;
• Eastbourne Strategic Partnership;
• Eastbourne & District Chamber of Commerce (Evening Presentation);
• Eastbourne & District Chamber of Commerce (Breakfast Meeting);
32
• Youth Forum; and
• Community Environment Partnership for Eastbourne.
5.20. A letter was sent to key stakeholders and consultees on the LDF mailing list
inviting them to a Stakeholder Event at the Town Hall on 23rd February 2011.
This event, which was attended by 15 delegates representing a range of
public sector, private sector and voluntary organisations was introduced by
the Senior Head of Development & Environment and consisted of a series of
presentations followed by interactive workshop sessions where delegates
were invited to respond to a series of questions.
5.21. In order to engage with the younger population, local schools were offered
the chance to take part in an interactive workshop. Four schools took up this
offer, and Planning Officers attended School Council meetings at St John’s
School, West Rise Junior School, Stafford School and Ocklynge Junior School,
liaising with groups of between 10 and 18 children. During the session,
children were asked to consider the social and environmental issues that
relate to Eastbourne, the pupils were then encouraged to build their ideal
town on a felt fabric model. The different elements of a town that they could
plan included housing, offices, factories, shops, schools, open spaces, hotels,
medical facilities, roads and railways.
Summary of Consultation Responses and Key Findings
5.22. The majority of consultation responses to the consultation exercise were
received
through
the
consultation
portal
on
the
Council’s
website.
Consultation responses were collated under four categories:
• Neighbourhood events;
• Brochures and questionnaires;
• Stakeholders and schools; and
• Consultation portal/Website.
5.23. A total of 225 individual formal representations were received from 78
consultees on the Eastbourne Plan – Proposed Core Strategy Report. In
33
addition, 56 representations were received via the summary brochure or the
on-line questionnaire responses.
5.24. A total of 655 members of the local community attended a series of
neighbourhood
consultation
events
across
the
Borough.
191
different
comments were received at these events which are summarised in the
following appendices.
462 people attended the Sovereign neighbourhood
event.
5.25. Stakeholders also provided representations on supporting documents to the
Core Strategy. 21 representations were received on the Infrastructure
Delivery Plan and 2 representations were received on the Sustainability
Appraisal.
Neighbourhood Events
5.26. Taken in its totality, there was widespread support for the Eastbourne Plan.
The spatial distribution of housing across the Borough received support from
most neighbourhoods, with the notable exceptions of Sovereign and Meads
where there was considerable opposition to the approach set out in Policy B1:
Spatial Development Strategy and Policy D5: Housing
5.27. With
the
exception
of
Policy
D6:
Gypsies,
Travellers
and
Travelling
Showpeople, there was broad support for the proposed policies.
5.28. The neighbourhood profiles and vision were generally well-received. There
were, however, a few notable exceptions particularly in Meads and Sovereign
where there was disagreement over the future housing delivery for their
respective neighbourhoods.
Brochures and Online Questionnaires
5.29. The vision for the Borough was generally supported although concerns were
raised about the deliverability of some aspects. Concerns were also raised
about the challenging local housing targets, which some felt would result in
the over-development of the Borough. There was consequently therefore
34
some opposition to the spatial development strategy, especially in relation to
proposals for 150 additional dwellings in the Sovereign6 neighbourhood.
5.30. The focus on developing on previously developed or ‘brownfield’ land was
strongly supported and there was a desire amongst many to safeguard
existing green open space and residential garden land. The neighbourhood
approach taken in the Core strategy was supported on the basis that it took
account of the different characteristics and issues within each neighbourhood.
However, a clearer explanation of the difference between a “sustainable
neighbourhood” and a “sustainable centre” was required as there was some
confusion as to the meaning of and relationship between these terms.
5.31. Neighbourhood specific comments included support for the regeneration of
the Town Centre, concern over the impact of the planning consent for 119
new dwellings at Kings Drive, concern about the level of development at
Meads and its impact on the historic environment and traffic congestion and
opposition to further development within Sovereign.
5.32. Other more general comments included:
• Concern that the sustainable development policy would result in the
development of wind turbines;
• Questions over the deliverability of employment sites in Sovereign;
• A need for a wider variety of tourist and cultural facilities in the
Borough;
• Support for regeneration of the Town Centre;
• Support for a range of housing types and tenures including more
affordable housing;
• General opposition to a policy for gypsies, travellers and travelling
showpeople;
• Support for enhanced community, sports and health facilities;
• Support for an enhanced and better integrated cycle network across
the Borough;
6
The neighbourhood was subsequently changed to Sovereign Harbour.
35
• A need to safeguard and protect green space, areas of conservation
interest and buildings of historic value; and
• Importance of securing sufficient levels of infrastructure to support
development.
Key Issues Arising from Consultation Exercise
5.33. A large number of individual responses were received relating to the
Sovereign neighbourhood. The principle concerns raised included:
• The level of housing proposed in Sovereign;
• The lack of community facilities and services in Sovereign; and
• The inclusion of Kingsmere within the Sovereign neighbourhood
boundary.
5.34. The concerns of residents in Sovereign have been acknowledged. The 150
dwellings proposed in Sovereign accords with the spatial development
strategy approved by Cabinet on 26th May 2010 (and endorsed by full Council
on 21st July 2010).
5.35. Concern was raised about past failures to deliver on the promises of new
community facilities when there has been a failure to provide facilities
alongside the needs of the growing community in the past.
However the
situation now is one where there is a real opportunity to provide the
community facilities currently lacking and to improve the overall sustainability
and functioning of the Sovereign Neighbourhood.
The Council has formally
stated it’s commitment to delivering community facilities in the Core Strategy
Neighbourhood vision for Sovereign through developer funding from the
comprehensive
development
of
the
remaining
vacant
sites
in
the
Neighbourhood. The mechanisms through which the community facilities will
be delivered are set out in the Infrastructure Delivery Plan (IDP).
5.36. The distribution of these dwellings in Sovereign is an essential component of
the spatial strategy and is underpinned by a robust evidence base. It is
required to ensure that the housing requirements for Eastbourne are fully met
and consequently no change to the overall numbers is proposed. Additional
wording has, however been added to make it clear that the 150 dwellings
proposed should be regarded as a maximum and only in conjunction on the
36
necessary
community
infrastructure
requirements
identified
in
the
Infrastructure Delivery Plan (IDP) being successfully delivered.
5.37. Residents expressed concern about the inclusion of Kingsmere within
Sovereign’s neighbourhood boundary. Having considered these concerns and
given the emphasis that the Government has placed on empowering local
communities, the boundary has been amended to exclude Kingsmere.
Kingsmere will now be incorporated into Neighbourhood 13: St Anthony’s &
Langney Point (whose name will remain the same) and Neighbourhood 14 will
be renamed Sovereign Harbour.
5.38. There is support for sustainable travel proposals and the provision of cycling
routes and this support is welcomed. A Cycling Strategy, is currently being
prepared, which will improve the scope for cycling within the borough.
5.39. There is support for proposals to protect Eastbourne Park and for protecting
the Park from traffic. A Supplementary Planning Document for the protection
and enhancement of Eastbourne Park, is in preparation showing how the
Council is following through on this issue.
5.40. There has been some concern expressed in individual responses and at the
consultation events to the overall level of housing proposed in the Borough
for the period to 2027. Respondents mention current vacant units and unsold
properties (for example in Sovereign) to support a view that there is less
need for additional dwellings. Any current apparent over supply however, is
more likely to be due to uncertainties in the housing market coupled with
localised imbalances in provision compared with needs, and is not a reliable
indicator of the overall need for additional units over the next 15 years.
5.41. The Council has previously resolved to maintain the housing target set in the
South East Plan in order to meet the future need for housing, as it is
considered that this is a realistic and achievable goal for providing a sufficient
supply of local homes. The provision of a sufficient supply of housing is
beneficial to the local economy through supporting job stability, either directly
in the construction and finishing industries, or indirectly by providing
adequate accommodation for people wishing to live, work and raise families
in the area. Residential development also generates the provision of
37
affordable housing which provides homes for the more vulnerable members of
society.
5.42. Support has generally been expressed for the regeneration of the Town
Centre, which is very much welcomed. A change to increase the emphasis
placed on the major retail redevelopment opportunity focused on the Arndale
Centre is proposed. The Council has addressed this issue in more detail
through the preparation of the Town Centre Area Action Plan
5.43. One issue raised in the consultation responses is the lack of reference to the
provision
of
accommodation
and
facilities
for
the
Borough’s
elderly
population. A view was however taken when the Core Strategy was prepared
that it should be seeking to provide for all sections of the population and that
specific age groups should therefore not be singled out. A separate reference
to one type of housing provision is not considered necessary.
5.44. There was some concern that the Core Strategy did not go sufficiently far
enough in terms of its protection of the Borough’s historic built environment.
There was particular concern that there were many important buildings that
were unprotected by listed building status or by virtue of being within a
conservation area. Other comments received suggested a need to ensure that
where new development is proposed, it should be well-designed and
incorporated within historic environments. In order to address these issues, a
new design policy is proposed that will require new development to make a
positive contribution to the overall appearance of an area.
5.45. Several objections were received in relation to the proposed Policy D6:
Gypsies, Travellers and Travelling Showpeople. Whilst the wording of the
Policy has been amended to ensure that the impacts of new sites are taken
into account, the Council considers that the inclusion of a Policy on Gypsies
and Travellers is essential to provide guidelines for dealing with planning
applications that might come forward for sites.
5.46. A series of other minor changes have been made in response to other
comments made. A full breakdown of all representations received, together
with the Council’s formal response and suggested changes to the text is
38
included in The Eastbourne Plan: Proposed Core Strategy 2006-2027
(December 2010): Consultation Report (Appendix 4).
5.47. The key amendments to the Proposed Core Strategy are set out as follows.
5.48. Further information on, and implications of, the Governments ‘Localism’
agenda. This includes proposals for giving communities the right to draw up
Neighbourhood Development Plans.
5.49. A new design policy in the Historic Environment section, aimed at protecting
and enhancing Eastbourne’s built environment. It will expect all development
to be to a high quality and to make a positive contribution to the overall
appearance of the area.
5.50. A specific notation to identify the major development opportunity centred on
an extension to the Arndale centre. This area was already identified as a ‘key
area of change’ but notation upgrades this area as the primary location for
comparison goods in view of its key importance to the regeneration of the
town centre.
5.51. Improved references to the role of cycling are proposed in various parts of
the document, both in relation to the contribution to sustainable transport
and to the benefits for recreational and tourist use, for example in accessing
the South Downs National Park.
5.52. New wording in the Natural Environment section, to explain the relationship
of the Core Strategy with the work which will be undertaken by the South
Downs
National
Park
Authority
Development Framework.
(SDNPA)
in
preparing
its
own
Local
Essentially the Core Strategy will not include
policies or proposal for that part of the South Downs National Park which falls
within the Eastbourne boundary, but policies in the existing Borough Plan,
which protect the landscape of the SDNP (AONB, SSSI), will not be
superseded until the SDNPA is able to have its own new policies in place.
5.53. Finally a new reference to the preparation of the Cultural Development
framework by the Council within the Tourism and Culture section.
39
40
Appendix 1: Specific, General and Other Consultation Bodies
Under Regulation 25 of the Town & Country Planning (Local Development)
(England) (Amended) Regulations 2008, the requirement to consult the public
includes specific and general bodies, as well as consulting those residents and/or
businesses the council considers appropriate.
Specific Consultation Bodies
The specific consultation bodies are listed in the Town and Country Planning
(Local Development) (England) Regulations 2004 (as amended) and relate to
organisations responsible for services and utilities and infrastructure provision.
These are a list of specific bodies who must be consulted by the council when
preparing development plan documents in which they may have an interest. The
specific consultation bodies are:
o
the regional planning body
o
a relevant authority, any part of whose area is in or adjoins the area of the
local council, such as:
o
a council (Wealden District Council)
o
a county council (East Sussex County Council)_
o
a parish council (East Dean and Friston Parish Council, Willingdon and
Jevington Parish Council, Westham Parish Council, Pevensey Parish
Council, Polegate Town Council)
o
a police authority (Sussex Police)
o
The Coal Authority
o
The Environment Agency
o
English Heritage
o
Natural England
o
The Secretary of State for Transport (Department for Transport and Highways
Agency)
o
A regional development agency whose area is in, or adjoins, the area of the
Council (Previously SEEDA)
o
any person to whom the electronic communications code applies by virtue
of a direction given under Section 106 (3)(a) of the Communications Act
2003 (Mobile Operators Association),
o
any person who owns or controls electronic communications apparatus
41
situated in any part of the area of the council (T-Mobile, Telefonica 02 UK,
Orange, Dolphin, Vodafone, BT Cellnet)
o
any of the bodies from the following list who are exercising functions in any
part of the area of the council:
o
primary care trust (East Sussex Downs and Wealden PCT)
o
person to whom a license has been granted under Section 7(2) of the
Gas Act 1986 (Scotia Gas Networks)
o
sewage undertaker (Southern Water)
o
water undertaker (South East Water).
LDF: Statement of Community Involvement
31
General Consultation Bodies
The general consultation bodies are also listed in the regulations. The regulations
identify five types of bodies as general consultation bodies that relate to voluntary
organisations representing certain groups within the community. The general
consultation bodies are:
voluntary bodies some or all of whose activities benefit any part of the council's area
bodies which represent the interests of:
different ethnic or national groups in the council's area
different religious groups in the council's area
disabled people in the council's area
People carrying out business in the council's area.
When preparing the development plan document, the council must consult those
general consultation bodies it considers appropriate.
The Council consulted the following general consultation bodies:
•
Wealden Strategic Partnership
•
Eastbourne Society
•
Eastbourne Age Concern
•
Eastbourne Islamic Cultural Centre
•
Older Peoples Forum
•
Eastbourne & District MENCAP
•
East Sussex Youth Development Service
•
Eastbourne Disability Involvement Group
42
•
Eastbourne & District Mind Association
•
Eastbourne Cultural Communities Network
•
Community Wise
•
The Salvation Army Old Town
•
East Sussex Disability Association
•
Eastbourne Hebrew Congregation
•
Eastbourne Seniors Forum
•
Federation of Small Businesses
•
Eastbourne Blind Society
Other Consultation Bodies
The key principle is that the council should carry out public participation that is
appropriate for the development plan document being produced.
Depending on the plan being produced, it may be appropriate to consult with
other agencies and organisations in addition to those identified as specific or
general consultation bodies.
The Council consulted the following other consultation bodies:
BNP Paribas Real Estate
Raglan Housing Association Ltd.
Sport England South East
Sussex Wildlife Trust
The National Trust
NHS East Sussex Downs and Weald
Southern Counties Housing Ltd.
Conservation Area Advisory Group
Network Rail
East Sussex Learning Partnership
Raglan Housing Association
Eastbourne Citizens Advice Bureau
Planning Inspectorate
BNP Paribas Real Estate
Eastbourne Buses
EDF Energy
The Planning Bureau
Rapleys
Sussex Downs Conservation Board
Homes and Communities Agency
Friends of Hampden Park
Town and Country Housing Group
Bellway Homes
CPRE, Compassion in World Farming
Sussex Biodiversity Record Centre
Ancient Monuments Society
South Downs Society
Commission for Architecture and the Built
DPP
Environment
Anchor Housing Association
Pevensey Road Residents Association
Learning & Skills Council
Sussex Enterprise
Sunbury Farm Residents Association
43
National Housing Federation South East
Sussex Gardens Trust
EAVS
British Transport Police
East Sussex Transport 2000
Old Town Tenants Association
Commission For Architecture & The Built
Eastbourne Wildlife Rescue
Environment
Southern Private Landlords Association
Hastings Borough Council
Eastbourne Arndale Centre
Orbit Housing Association
Highways Agency
Eastbourne College
Network Rail Town Planning
Eastbourne Allotments & Gardens Society
Hastoe Housing Association Limited
Park College Sussex Downs
The Planning Bureau Ltd.
Sussex Police Community Safety Branch
Eastbourne & District Chamber of
East Sussex Drugs and Alcohol Team
Commerce Ltd.
Eastbourne Angling Association
Southern Horizon Housing Ltd
Eastbourne Crime Reduction Coordinator
Eastbourne Cultural Communities Network
Eastbourne Fishermans Club
Eastbourne Natural History & Archaeological
Eastbourne Friends of the Earth
Society
Eastbourne Housing Aid and Legal Centre
Trustees of the Chatsworth Settlement
Enterprise Centre
The Friends Of The Devonshire Park Theatre
Housing 21
Meads Community Association
The Theatres Trust
R.M.A. Eastbourne
Highways Agency
Little Chelsea Residents Forum
Eastbourne Green Party
Eastbourne Community Network
Eastbourne & District Chamber of Commerce
Town Centre Community Forum
Ltd
The Council for British Archaeology
The Victorian Society
The Georgian Group
Lewes District Council
Unison Environmental Sub-Committee
Sussex Wildlife Trust
The Society for the Protection of Ancient
Rodmill Residents Association
Buildings
Town Centre Management Initiative
Eastbourne Rambling Club
The National Trust
Sussex County Playing Fields Association
Eastbourne Hotels Association
DPP
Warden Housing Association
Eastbourne Enterprise HUB
Eastbourne College
Ravenscroft Eastbourne Residents Co.Ltd.
University of Brighton
Stagecoach
James Butcher Housing Association
UK Power Networks
Eastbourne Sports Council
Home Group (South)
Southern Housing Group
Chair Meads Neighbourhood Panel
The RSPB Eastbourne and District Local
Network Rail
44
Group
Highways Agency Network Strategy
Department for Transport
Division
Abbeyfield (Eastbourne) Society Ltd
Npower
National Grid
Seeboard
45
Appendix 2: List of Consultation Supporting Documents
The list below sets out a comprehensive list of the documents (together with their
publication date where available) that have been used to inform this Statement of
Consultation. These documents are all available to view on Eastbourne Borough
Council’s website and provide additional information about the overall levels of
consultation that have taken place over the course of the plan-preparation period.
They include:
•
Statistical Analysis of comments received on the Discussion Paper “Shaping a
Future Together” which feeds into the preparation of the EBC Core Strategy
(February 2006)
•
LDF Core Strategy Preferred Options Report: Consultation Statement
•
LDF Core Strategy Preferred Options: Statement of Consultation and Public
Participation (May 2007)
•
LDF Statement of Community Involvement: Technical Update (July 2009)
•
LDF Core Strategy Consultation Feedback Report: Spatial Development
Options and Sustainable Neighbourhood Assessment (June 2010)
•
The Eastbourne Plan: Proposed Core Strategy 2006-2027 (December 2010):
Consultation Report (September 2011)
46
Appendix 3: Cabinet Report (7th September, 2011)
BODY:
CABINET
DATE:
7th September 2011
SUBJECT:
Proposed Submission Core Strategy
REPORT OF:
Senior Head of Development and Environment
Ward(s):
All
Purpose:
For Members to approve the Proposed Submission in
preparation for formal submission of the Strategy to the
Secretary of State.
Decision type:
Key decision
Contact:
Iona Cameron or Valerie Tupling Planning Policy Manager (Job
Share), Planning Policy Unit, 1 Grove Road, Eastbourne
Tel no: (01323) 415327
E-mail: [email protected]
[email protected]
47
Recommendation:
1. Cabinet recommend to
Strategy document as
publication as a Proposed
the formal statutory
requirements;
Full Council that the Core
amended, is approved for
Submission Core Strategy for
publicity and consultation
2. To delegate authority to the Senior Head of
Development and Environment in consultation with the
Lead Cabinet Member to make minor amendments
before publication; and;
3. That following the end of the consultation period to
delegate to the Senior Head of Development and
Environment in consultation with the LDF Steering
Group, authority to submit the Core Strategy to the
Government.
1.0
Introduction
1.1
The Eastbourne Local Plan or LDF Core Strategy has been shaped over the last 5
years by close consultation with local people and civic groups. The Council has
also worked closely with our neighbours, Wealden District Council, to ensure that
the enormous amount of research that has informed this plan is complimentary
for both of the administrative areas. What has grown out of all that work is a
holistic plan that will shape the future development of Eastbourne for the next 15
years. It is intended as a guide for the community to show where and how the
town will grow and develop in the future. It will also be a guide for decision
makers and developers about what is likely to be acceptable by way of proposed
developments.
1.2
At its heart the Plan sees Eastbourne evolving carefully as a place that protects
its outstanding environmental quality, its historical character and tourism
potential. New housing, shopping and employment developments will be built in
such a way that meets the needs of local people and businesses sensitively
within the existing built up areas. It will be designed in such a way that it is
supported by the necessary infrastructure to create healthy, just and sustainable
communities.
1.3
The main spirit of the Eastbourne Local Plan (LDF:Core Strategy) spatial strategy
is to stimulate regeneration and renewal of the town centre, delivering sufficient
improvements to the provision of community facilities at Sovereign Harbour and
protecting its green heart at Eastbourne Park as well as the areas of outstanding
natural beauty that have been incorporated into the South Downs National Park.
1.4
Therefore the majority housing will take place on land that has already previously
been developed. A modest number of small Greenfield sites have also been
identified as having potential for housing, but these have been assessed as being
of low value and poor quality. Higher residential densities will also be supported
in some of the town’s most sustainable neighbourhoods: Old Town, Meads,
Upperton, Langney and Seaside, subject to the usual design and conservation
policy requirements.
48
1.5
So that people can easily find out and influence what is likely to change in their
area, this Eastbourne Local Plan has divided up the town into 14 neighbourhoods.
A key diagram for each shows the overall vision and indicates the key places of
change likely to occur in each area over the plan period. Each neighbourhood
vision has been based on extensive analysis of local information as well as local
knowledge through neighbourhood consultation events for each area.
2.0
Proposed Submission version
2.1
The Plan has been prepared in accordance with the relevant government
regulations and guidance and has now reached the stage of Proposed
Submission. The Proposed Submission stage now requires a further period of
publicity to enable stakeholders and interested parties an opportunity to make
formal representations based on the ‘soundness’ of the Strategy that will be
considered by an independent Planning Inspector early next year (expected to
start in April 2012).
2.2
The need for the Core Strategy to be ‘sound’ before it can be approved by the
Inspector and adopted by the Council, is a key requirement of the government
regulations. ‘Soundness’ is defined as: ‘justified, effective and consistent with
National Policy”. Justified means that the document must be:
• Founded on robust and credible evidence
• The most appropriate strategy when considered against the reasonable
alternatives.”
2.3
To be effective: Core Strategies must be:
• deliverable;
• flexible; and
• able to be monitored.
2.4
The recently published National Planning Policy Framework (currently also out for
public consultation until 17th October 2011) adds an additional criteria that the
Plan must have been ‘Positively Prepared’. This is defined as being ‘based on a
strategy which seeks to meet objectively assessed development and
infrastructure requirements,.. ‘with the presumption in favour of sustainable
development’.
2.5
The draft National Framework also alters the emphasis for ‘Effective’ to ensure
that the plan is based on effective joint working on cross boundary strategic
priorities.
2.6
As well as incorporating the changes outlined in the previously approved
Consultation report, (See Cabinet minutes dated 13th July 2011), this latest
Proposed Submission version includes the following:
o Updated housing figures following the latest returns on housing delivery,
windfalls and known developments;
o Contingency policies should the housing market not recover as quickly as
49
o
o
o
anticipated and expected housing delivery targets are not being met;
Stronger emphasis on maximizing the opportunities for renewable energy
in new developments;
Clearer picture of Council plans to positively make change happen by way
of new developments in the Town Centre, Sovereign Harbour and the
Devonshire areas by way of changing the neighbourhood visions into
policies and more detailed Infrastructure plans;
Other Policy updates to reflect the recently issued draft National Planning
Policy Framework as well as recommendations made following a ‘technical
health check’ by legal specialists.
3.0
What happens next?
3.1
Once approved by Full Council (14th September) the Proposed Submission
version of the Eastbourne Local Plan (or LDF:Core Strategy) will be published for
interested parties to make formal representations based on the soundness of the
plan to be considered by a Planning Inspector at Planning Examination. After the
12 week consultation period (16th September – 9th December) has ended the
Council will consider and summarise the representations made.
3.2
The legislation allows the Council to then make fairly minor changes to the Plan
before formally publishing the Submission version again for formal consideration
and deliberation by the Planning Inspectorate at Public Examination (expected to
be February 2012).
3.3
It is recommended that Cabinet delegate to the cross party LDF Steering Group
the approval of the final document that is submitted to the government for the
public examination.
4.0
Resource Implications
4.1
The Council has budgeted £143,000 for progressing the Core Strategy through to
its adoption., It is therefore crucially important that the Council is happy with the
Spatial Strategy proposed for consideration by the Planning Inspectorate. The
Public Examination will be an intensive period of work for the team and has been
resourced to take this into account.
4.2
Financial
There are no direct financial implications to the Council of this report. The cost of
the publication and publicity for the Submission document will be met from within
the existing service budget.
4.3
Legal
As stated above, the production of a Local Development Framework which
includes a Core Strategy is a statutory requirement under the Planning and
Compulsory Purchase Act 2004 (as amended in 2008).
4.4
Staff Resources
Officers in the Planning Policy Team will manage the publicity arrangements for
50
the Proposed Submission document, the collection and processing of
representations and the preparation of the necessary documentation for
submitting the Core Strategy.
5.0
Conclusion
5.1
Cabinet are requested to recommend to Full Council that the Proposed
Submission version of the Eastbourne Local Plan be approved as a basis for
publication and a final opportunity for the community to make representations on
its soundness. It is recommended that the LDF Steering Group consider a
summary of the representations made and the need for further changes, before
the final document is submitted to the Secretary of State in February 2012 for
Public Examination later in the year.
Iona Cameron
Planning Policy Manager
Background Papers:
The Background Papers used in compiling this report were as follows:
Planning Policy Statement 12: Local Spatial Planning (CLG, 2008)
Town and Country Planning (Local Development) (England) Regulations 2004 (as
amended)
To inspect or obtain copies of background papers please refer to the contact officer
listed above.
51
Appendix 4: The Eastbourne Plan: Proposed Core Strategy 2006-2027
(December 2010) – Consultation Report.
1
hij
Appendix 4: The Eastbourne Plan: Proposed Core Strategy
2006-2027 (December 2010) – Consultation Report
The Eastbourne Plan:
Proposed Core Strategy 2006-2027
(December 2010)
Consultation Report
This report details the consultation techniques used and the comments received during
the 12-week consultation period from 17th December 2010 to 11th March 2011.
Consultation Techniques
1.0
Introduction
1.1
This report details the techniques used and the responses received during the
12-week consultation period (17th December 2010 to 11th March 2011) on the
Eastbourne Plan (Proposed Core Strategy 2006-2027).
1.2
The Eastbourne Plan seeks to ensure that “By 2027, Eastbourne will be a
premier seaside destination within an enhanced green setting. To meet
everyone’s needs in Eastbourne will be a safe, thriving, healthy and vibrant
community with excellent housing, education and employment choices, actively
responding to the effects of climate change”.
1.3
The aim of the consultation was to give all those who visit, live and work in the
Borough, an opportunity to share their views on what sort of place they would
like Eastbourne to be by 2027 and suggest ways in which the Eastbourne Plan
could be amended to help achieve this.
1.4
The public and stakeholders in Eastbourne were asked to comment on the
overall vision, key spatial objectives, policies and individual neighbourhoods
within the Borough.
1.5
The consultation undertaken was extensive and innovative, reflecting the key
strategic importance of the Eastbourne Plan as the document, which sets out the
overarching spatial strategy for the whole Borough.
1.6
The scale and scope of the consultation exceeded the requirements of the
Council’s adopted Statement of Community Involvement (SCI) and the
requirements of Planning Policy Statement 12 (PPS12): Local Spatial Planning
and therefore reflects the importance that the Council places on engagement
with the people of Eastbourne and the need to gather as much feedback as
possible in order to ensure the policies and options are “sound” and reflect what
the public want to see.
1.7
A total of 225 individual formal representations were received from 78
consultees on the Eastbourne Plan – Proposed Core Strategy Report. In addition,
56 representations were received via the summary brochure or the on-line
questionnaire responses.
1.8
A total of 655 members of the local community attended a series of
neighbourhood consultation events across the Borough. 191 different comments
were received at these events which are summarised in the following
appendices.
1.9
The Council also ran a Stakeholder Event that was attended by 15 stakeholders
from a variety of businesses, organisations and interest groups. A formal
presentation was delivered to Business Community Groups and this was
attended by 6 stakeholders. The Council also ran interactive consultation events
at 4 local primary schools.
Stakeholders also provided representations on supporting documents to the
Core Strategy. 21 representations were received on the Infrastructure Delivery
Plan and 2 representations were received on the Sustainability Appraisal.
1.10
The following sections of the report detail the consultation techniques used to
inform the public of the Eastbourne Plan: Proposed Core Strategy, which
consisted of the following:
•
•
•
•
•
•
•
•
•
•
Letters
Summary brochure, posters and neighbourhood leaflets
Dedicated page on Council’s website
Social networking websites
External media - press releases, radio interview, articles in local newspapers
and magazines
Permanent and roving exhibitions
Neighbourhood events
Presentations
Stakeholder event
Interactive school workshops
2.0
Letters
2.1
Several letters advising of the consultation were sent out to various
organisations, businesses and the general public. These are detailed below:
•
•
•
Letters to stakeholders and consultees on the LDF mailing list informing them
of the consultation events; where the Issues and Options Report could be
viewed and inviting them to a Stakeholder Event at the Town Hall on 23rd
February 2011;
Letters to all those who had attended a consultation event before or had
made representations on previous LDF documents, informing them of the
consultation events;
Letters to the Head teachers of all Eastbourne’s schools with an offer for
Officers to visit the schools to provide an interactive presentation to children;
3.0
Summary Brochure, Posters and Neighbourhood Leaflets
3.1
A summary brochure was produced (5,000 copies) which provided:
•
•
•
•
•
•
•
•
•
3.2
An introduction to the Eastbourne Plan
Details of the Vision for Eastbourne
The Overall Strategy for the Future of Eastbourne
Themes for the Eastbourne Plan
Details on Community-Led Neighbourhoods
A Development Map showing the broad approach to future development
Details about how to Have Your Say in the Future of Eastbourne
Information about the neighbourhood events taking place
A Response Form
This brochure was circulated to neighbourhood groups and local residents’
associations. It was also available at the receptions of civic buildings, libraries
and all of the exhibition venues (a copy of the leaflet is attached in Appendix
A1). A number of local businesses and organisations agreed to display them.
Posters advertising the consultation were displayed on Stagecoach buses, on
notice boards throughout the Borough and in all libraries.
Neighbourhood leaflets were prepared for each of the Borough’s fourteen
neighbourhoods. These summarised the key proposals for each neighbourhood,
setting out the vision and showing a diagram with the proposals for each.
4.0
4.1
Dedicated Page on Council’s Website
A dedicated page was set up on the Council’s website
(http://www.eastbourne.gov.uk/EastbournePlan). It publicised the dates
and venues of exhibitions and all other consultation events (see Appendix A2).
4.2
The website also enabled the Eastbourne Plan and accompanying Sustainability
Appraisal to be viewed and/or downloaded and provided a link to ‘Limehouse’,
the Council’s online consultation portal (http://eastbourneconsult.limehouse.co.uk/portal). This ensured that anyone who had an
interest in the future of the town centre could make a general comment about
the Eastbourne Plan or respond to more specific questions contained within the
report.
5.0
5.1
Social Networking Websites
The Council utilised the social networking sites of ‘Facebook’
(www.facebook.com/EastbourneC) and ‘Twitter’
(www.twitter.com@EastbourneBC. The web pages are shown in Appendix
A3.
6.0
External media - press releases, radio interview, articles in local
newspapers and magazines
6.1
A news release (see Appendix A4) entitled ‘Help piece together the future of
Eastbourne’ was sent to The Herald, The Argus, BBC Sussex, Sovereign Radio,
Sussex Life, BBC South East, Meridian and Heart FM.
6.2
A public notice (see Appendix A4) was placed in ‘The Advertiser’ confirming the
dates of the Issues and Options consultation, advising that the Report was
available for viewing on the Council’s website and detailing the dates and venues
of the exhibitions (copy attached in Appendix A4 of this report).
6.3
The Herald published articles on the Eastbourne Plan and the accompanying
consultation exercise.
6.4
Cllr David Tutt (Leader of the Council) was interviewed by Sovereign Radio,
urging those who visit, live, work or has an interest in the town centre to have
their say on its future.
7.0
Permanent and Roving Exhibitions
7.1
In order to provide opportunities for the public to have maximum involvement in
the consultation process, a series of exhibitions were prepared (see Appendix
A5). An unmanned, permanent exhibition was on display in the Central Library
for the entire 12-week consultation period. A partially manned, roving exhibition
was displayed at the following venues across the town:
• Sovereign Centre, Eastbourne
• Eastbourne Arndale Centre
• Langney Shopping Centre, Eastbourne
• Old Town Library, Eastbourne)
(Details of the dates of the exhibitions are shown in the Public Notice in
Appendix A4).
8.0
8.1
Neighbourhood Events
In addition to the permanent and roving exhibitions, a series of neighbourhood
events took place at the following locations:
• Town Hall, Grove Road (Town Centre and Summerdown & Saffrons
• Elim Church, Hartfield Road (Upperton)
• St Agnes’ Church Hall, Whitley Road (Seaside and Roselands &
Bridgemere)
• Community Wise, Ocklynge Road (Old Town)
• Victoria Baptist Church, Eldon Road (Ocklynge & Rodmill)
• Hampden Park Community Hall, Brodrick Road (Hampden Park_
• Shinewater Community Centre (Langney and Shinewater & North
Langney)
• St John’s Parish Hall, Meads Road (Meads)
• St Mary’s Church, Church Street, Willingdon (Ratton & Willingdon Village)
• St Anthony’s Centre, Seaside (St Anthony’s & Langney Point)
• The Haven School, Atlantic Drive (Sovereign)
• Town Hall (Borough-Wide Event)
9.0
Presentations
9.1
Officers attended meetings of the following groups/organisations and gave a
PowerPoint presentation on the Eastbourne Plan: Proposed Core Strategy 20062027 and held question and answer sessions:
• 3VA
• Disability Involvement Group
• Town Centre Management Initiative
• Eastbourne Strategic Partnership
• Eastbourne & District Chamber of Commerce (Evening Presentation)
• Eastbourne & District Chamber of Commerce (Breakfast Meeting)
• Youth Forum
• Community Environment Partnership for Eastbourne
10.0
10.1
Stakeholder Event
As detailed in paragraph 2.1 of this report, a letter was sent to the key
stakeholders and consultees on the LDF mailing list inviting them to a
Stakeholder Event at the Town Hall on 23rd February 2011. This event was
introduced by the Senior Head of Development & Environment and consisted of
a series of PowerPoint presentations followed by a series of interactive
workshops where delegates were invited to respond to a series of questions.
11.0
11.1
Interactive school workshops
In order to engage with the younger population, local schools were offered the
chance to take part in an interactive workshop. Four schools took up this offer,
and officers attended School Council meetings at St John’s School, West Rise
Junior School, Stafford School and Ocklynge Junior School, liaising with groups
of between 10 and 18 children.
In order to allow them consider social and environmental issues that relate to
Eastbourne, the pupils were first encouraged to build their ideal town on a felt
fabric model. The different elements of a town that they could plan included
housing, offices, factories, shops, schools, open spaces, hotels, medical
facilities, roads and railways.
Appendix A: Copies of Information Referred to and
Methods Used
Contents
A1: Summary Brochure, Posters and Neighbourhood Leaflets
• The Eastbourne Plan Summary Brochure
• General Posters
• Neighbourhood Event Posters
• Neighbourhood Leaflets
A2: Dedicated Page on Council’s Website
A3: Social Networking Websites
• Facebook
• Twitter
A4: External Media
• News Release
• Public Notice
A5: Permanent and Roving Exhibitions
• Permanent Exhibition (Eastbourne Library)
• Roving Exhibition (Various Venues)
• Photograph of Roving Exhibition in the Eastbourne Arndale Centre
A6: Neighbourhood Events
• Neighbourhood Exhibition – Part C (example)
• Neighbourhood Event – Basic Room Layout
• Photographs of Neighbourhood Events
A7: Interactive School Workshops
Appendix A1: Summary Brochure, Posters and
Neighbourhood Leaflets
The Eastbourne Plan Summary Brochure
General Posters
Neighbourhood Event Posters
Neighbourhood 1: Town Centre
Neighbourhood 3: Seaside
Neighbourhood 2: Upperton
Neighbourhood 4: Old Town
Neighbourhood Leaflets
Neighbourhood 5: Ocklynge & Rodmill
Neighbourhood 6:Roselands & Bridgemere
Appendix A2: Dedicated Page on the Council’s
Website
Eastbourne Borough Council – Eastbourne Plan webpage
(www.eastbourne.gov.uk/eastbourneplan)
12
Appendix A3: Social Networking Sites
Facebook (www.facebook.com/EastbourneC)
Twitter (http://twitter.com/EastbourneBC)
13
Appendix A4: External Media –News Release,
Public Notice
News Release
hij
News Release
Date:
January 2011
Released By:
Communications Unit
Photocall
Photo attached
Help Piece Together the Future of
Eastbourne
‘Help piece together the future of your town’ is the message being
promoted to residents in a consultation period asking for feedback and
views on The Eastbourne Plan, a document that sets out the vision for
Eastbourne up to 2027.
Kicking off with an exhibition in Eastbourne Central Library on Monday
10 January, a series of consultation events and exhibitions will be taking
place in neighbourhoods around the town to find out from residents
what they want to see happen to their local area over the next 16 years.
Residents and businesses have the chance to shape the vision for
Eastbourne and comment on a number of issues including housing,
economic growth, tourism and culture, town centre and shopping,
community facilities, transport, employment opportunities and more.
The Eastbourne Plan has been formulated following extensive
neighbourhood engagement during 2009 and now the local community
is being given the chance to have their say on the final document that
will pave the way forward for the future of the town and its
neighbourhoods.
Eastbourne Borough Council Cabinet Member for the scheduled
Environment, Councillor Steve Wallis said “The Eastbourne Plan is a vital
document as it will help realise our aim of making the Borough an even
better place to live, work or visit.
14
“We hope that the local community will actively respond to this
consultation exercise over the next few weeks and work closely with us
to deliver a prosperous future for our town. I believe everyone has a
valuable role to play in helping us achieve this.”
The first neighbourhood consultation events take place next Wednesday
12th January in Langney and Shinewater where residents are invited to
go along and examine the vision for their local area and discuss any
concerns or suggestions with officers.
Events like this will be taking place in each of the 14 Eastbourne
neighbourhoods between now and 21st February and for those who
cannot attend their local event, there are a number of other ways to
give feedback.
There will be a number of exhibitions around the town, opportunities to
leave feedback online, the option to complete a response form by post,
or residents can join a community discussion on the Council’s facebook
and twitter pages at facebook.com/EastbourneC and
twitter.com/EastbourneBC.
Further information about the Eastbourne Plan and details about the
exhibitions and neighbourhood events can be found on the Council’s
website at www.eastbourne.gov.uk/eastbourneplan or by contacting us
directly on 01323 415255.
Ends
Further Information
Notes to Editors:
Media interviews available – contact Emma Wilkinson to arrange
A copy of the summary Eastbourne Plan brochure is attached
Contact:
Emma Wilkinson, E-marketing and Communications Assistant
[email protected] | 01323 415556
15
Public Notice
Eastbourne Borough Council
PLANNING AND COMPULSORY PURCHASE ACT 2004
THE TOWN AND COUNTRY PLANNING (LOCAL DEVELOPMENT)
(ENGLAND) REGULATIONS 2004 (AS AMENDED)
REGULATION 25 – NOTICE OF PUBLICATION OF THE EASTBOURNE
PROPOSED CORE STRATEGY
On 15TH December, 2010, the Council’s Cabinet approved the Eastbourne
Proposed Core Strategy for public consultation.
The Proposed Core Strategy, once adopted, will form part of the Eastbourne
Local Development Framework (LDF). It will set out policies governing future
development of the Town up to 2027.
The Proposed Core Strategy consultation will be carried out over a 12 week
period from 17th December to 11th March, 2011. During this time the document
can be viewed on the Council’s website
(www.eastbourne.gov.uk/EastbournePlan).
A neighbourhood consultation event will be held for the public to become
involved at the following locations:
Shinewater Community Centre,
Milfoil Drive
St Anthony’s Centre, 557a Seaside
Community Wise, Ocklynge Road
The Haven School, Atlantic Drive
Hampden Park Community Centre,
Brodrick Road
Elim Church, Hartfield Road
St John’s Parish Hall, Meads Road
Eastbourne Town Hall
St Agnes Church, Whitley Road
St Mary’s Church, Church Street,
Willingdon
Victoria Baptist Church, Eldon Road
Eastbourne Town Hall
12th January 10am-2pm
14th January 2pm-6pm
17th January 2pm-6pm
22nd January 10am-2pm
25th January 2pm-6pm
28th January 2pm-6pm
31st January 2pm-6pm
3rd February 2pm-6pm
5th February 10am-2pm
11th February 2.30pm-6pm
15th February 2pm-6pm
21st February 2pm-6pm
An exhibition will also be available for public inspection at the following
locations:
Eastbourne Central Library
7th January-18th February
16
Eastbourne Sovereign Centre
Eastbourne Arndale Centre
Congress Theatre
Langney Shopping Centre
Old Town Library, Victoria Drive
20th January 10am-2pm
24th January 9am-5pm
1st February 9am-5pm
9th February 9am-5pm
14th February 9am-5pm
Comments and representations can be made on the document throughout the
consultation period, but should be received by the Council no later than 11th
March, 2011. Those wishing to make comments or representations are
encouraged to use the Council’s website; or alternatively they can be sent to
the following address: Planning Policy, Eastbourne Borough Council, 1 Grove
Road, Eastbourne, BN21 4TW.
For further information about the Proposed Core Strategy or the consultation
process, please contact Planning Policy on 01323 415255
17
Appendix A5: Permanent and Roving Exhibitions
Permanent Exhibition (Eastbourne Library)
18
Roving Exhibition (Various Venues)
19
Photograph of the Roving Exhibition in the Eastbourne Arndale Centre
Roving Exhibition at the Arndale Centre
20
Appendix A6: Neighbourhood Events
Neighbourhood Exhibition – Town Centre Example
21
22
23
Neighbourhood Event – Basic Room Layout
What Happens Next?
Part D/E
Questions
General
Comments
Part D/E
Part C
Part B
Questions
Welcome
Part B
Part A
About You
24
Photographs of the Neighbourhood Events
Neighbourhood 13: St Anthony’s & Langney Point – Neighbourhood Event
Neighbourhood 14: Sovereign – Neighbourhood Event
25
Appendix A7: Interactive School Workshops
26
Appendix B – Schedule of Comments/Responses
Received
Contents
B1: Consultation Responses to the Eastbourne Plan
B2: Neighbourhood Event Responses
B3: Summary of Brochure Responses
B4: Summary of Online Survey Comments
B5: Minutes of Stakeholder Event
B6: Summary of Interactive School Workshops
B7: Statistical Analysis of Responses Received
Note: the Comments on the Social Networking Sites did not raise
any issues that have not been addressed elsewhere
27
Appendix B1: Consultation Responses to the Eastbourne Plan
Whole Document and Foreword
ID
No.
85
Section
Paragraph no.
and subject
Proposed Core
Strategy (1)
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Miss Charlotte
Handscomb
(DPP Planning)
Support the general structure
Support welcomed
No change required
The role of each neighbourhood
in meeting the overall strategic
vision should be more explicitly
emphasised to demonstrate how
the needs of Eastbourne will be
achieved when the individual
areas are taken cumulatively. At
present the document fails to
stress the overarching needs of
the wider community of
Eastbourne Borough, with a
danger that each neighbourhood
will become too inward looking
and non-strategic in its focus.
Agreed. Additional text
should be added to stress the
link between each
neighbourhood and its
neighbours and the overall
strategic vision and spatial
development strategy for the
Borough as a whole.
Section A and B would benefit
from being renamed
Eastbourne's Vision and
Objectives and The Spatial
Strategy. Section B would benefit
from being re-structured to more
overtly state the Borough's core
requirements and how these will
be met through the promotion
and enforcement of Policy B1.
It is not considered that
suggested renaming of
sections would improve the
Plan’s legibility. The
structure of the Plan aims to
guide the user through from
setting the scene to
establishing principles and
developing these into visions
for the Neighbourhoods and
Insert additional paragraph
after 3.1.4 :
Each neighbourhood vision
contributes to the overall
Borough-wide vision. Whilst the
issues and opportunities differ
between neighbourhoods, there
are common themes that exist
throughout the town. The
neighbourhood approach
acknowledges the differences
and commonalties creating a
‘patchwork’ of neighbourhoods
that are intrinsically connected
and which cumulatively seek to
deliver the overall spatial
development strategy
established in Policy B1. It is
recognised that each
neighbourhood does not exist
in isolation and that people
travel into adjoining
neighbourhoods to access
shops, services, open space
and community facilities.
Furthermore, the spatial
28
ID
No.
194
Section
Paragraph no.
and subject
Proposed Core
Strategy (1)
Respondent
J A Williams
Summary of
Representation/Comment
Proposed Response
Recommended Change
Sections C and D, with their
separate neighbourhood visions
and topic based policies, can
then provide the building blocks
that promote and guide the
overall Vision and delivery when
the neighbourhoods are taken
together.
the key policies which will
guide delivery.
development strategy
recognises that some
neighbourhoods are more
suited to certain types of
facilities and development than
others. The visions respect
and complement those of their
adjacent neighbourhoods,
taking a holistic approach but
one which considers the unique
needs of each of the town’s
neighbourhood.
The Plan is wordy and lacks
substance with policy statements
that do not commit the Council.
Developing 240 dwellings a year
will bring in council tax to spend
on services. It would be more
relevant to say how this money
will be spent.
The Core Strategy is a
strategic document, which
sets out the broad
parameters within which
growth can come forward. It
is important that the Core
Strategy has a degree of
flexibility inbuilt to ensure
that it can deal with a variety
of eventualities.
The spatial development
strategy will deliver at least
5,022 dwellings between
2006 and 2027 and at a level
underpinned by a robust and
justifiable evidence base in
order for the plan to
ultimately be found sound by
an independent inspector.
The target of 240 dwellings
No change.
The impact of an oversupply of
housing on property prices leads
to the potential for home owners
to apply to have their council Tax
banding reduced.
Concerned that Sovereign
Harbour is going to lose out.
Predict that in a few years there
will be at least 200 new units
and no community facilities with
No change
29
ID
No.
4
Section
Paragraph no.
and subject
Proposed Core
Strategy (1)
Respondent
Miss Rachel
Bust (Coal
Authority)
Summary of
Representation/Comment
Proposed Response
Sovereign Harbour ranked at the
bottom of the sustainability table
with no chance of rectifying the
position as there will be no
further land available.
per annum is in line with the
figure set in the South East
Plan and was set before the
recent spending cuts
advanced by the
Government. The evidence
base that informed the Core
Strategy comprised of a
number of key documents
including the Housing Market
Assessment prepared by
DTZ, which was published in
February 2009. This
document highlighted the
need for additional housing,
and noted that the shortage
of affordable housing was
particularly acute. The
evidence base refutes the
notion that there is an
“oversupply of housing”.
The lack of certain services
and facilities, and a
deficiency of community
facilities in the
neighbourhood, has been
acknowledged and this is
something that needs to be
addressed.
No specific comments to make
on the document .
Comment noted
Recommended Change
No change
30
ID
No.
7
Section
Paragraph no.
and subject
Proposed Core
Strategy (1)
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr N.R. Marsh
Health and
Safety
Executive
The Health and Safety Executive
does not comment on individual
Local Development Plans.
Comment noted
No change
The Council prepared four
housing spatial development
options as part of the
evidence base to underpin
the Core Strategy. A
sustainability appraisal of
each of these development
options was completed, and
extensive public consultation
carried out throughout the
Borough. This process sought
to ensure that the future
development of the Borough
is undertaken in the most
sustainable manner possible
and in a way that protects
Eastbourne’s natural
environment. Spatial
development option 2 was
assessed as being the most
sustainable option, achieving
a sustainability score of 44.5,
compared to 30.5, 21 and 19
respectively for the other
three spatial development
options
See response to 44 and 194
above.
No change
44
Foreword
Mr Adrian
Peckham
Strongly disagree with the
proposal to build 150 new
residential units in the Sovereign
harbour area. The area is already
densely populated and has
insufficient community and
recreation facilities to cater for
the residents. Sovereign harbour
is overpopulated.
58
Foreword
Mr Bob Watts
Question the commitment to
carrying through improvements
No change
31
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
It is important that the
neighbourhoods proposed
respect and reflect public
perceptions of individual
neighbourhoods. In the case
of the proposed boundary for
Sovereign, there is a clear
concern amongst residents
that the inclusion of
Kingsmere within the
boundary is inappropriate. It
is therefore proposed to
amend the boundary of
Sovereign to exclude
Kingsmere and for Kingsmere
to be added to St Anthony’s
and Langney Point
neighbourhood. The new
neighbourhood will be called
Sovereign Harbour to avoid
confusion with the previous
area and the electoral ward.
See Sovereign Neighbourhood
Section for proposed change to
boundary.
to Sovereign Harbour. Recognise
the competing demands of
developer’s expectations and
satisfying house building targets.
Consider that the Sovereign
Neighbourhood should not
include the Kingsmere estate.
The only thing Sovereign
Harbour and Kingsmere Estate
share is a boundary The
differences between the two
communities cannot be more
starkly illustrated than the widely
different funding position for
community based schemes.
32
Part A: Identifying the Vision and Setting the Objectives
ID
No.
59
60
Section
Paragraph no.
and subject
A Portrait of
Eastbourne
A Portrait of
Eastbourne
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Bob Watts
1.1.6 Concern at failure to
attract commercial or science
tenants to the vacant land at
Sovereign Harbour. Some
incentive is required.
No change
Mr Bob Watts
1.1.7 The retail offer is not
concentrated in the town centre
by volume/value. Commercial
and industrial retail outlets such
as The Crumbles, Hamden Park
and others have attracted trade
away from the town centre which
currently has a greater variety
but diminishing retail offer.
The need for incentives to
attract commercial and
science tenants to Sovereign
Harbour is recognised and
mechanisms to attract
additional inward investment
are currently being explored
to bring forward Business
Development at Sovereign
Harbour.
The paragraph states that the
retail function of the town is
concentrated in the town
centre. It does, however,
acknowledge that there are
other district, local and
neighbourhood centres that
all contribute to the
Borough’s overall retail offer.
Rail journey times between
London and Eastbourne,
coupled with the relatively
poor highway links on the
A22 and A27 have the
potential to be an
impediment to additional
inward investment. The
Council supports proposals
Amend paragraph 1.1.8 to
read:
“Eastbourne is currently served
by the A27, which links the
town to Brighton in the west,
and the A259, which links the
town with Bexhill and Hastings
in the east. The A22 provides
links with Uckfield and London.
1.1.8 The two lane carriageway
A27 and A22 are disincentives to
business investment. The
relatively slow connection to the
fast Brighton/London rail line is a
disincentive to commuter
settlement.
In para. 1.1.7 amend the third
sentence to read:
“The town centre remains the
Borough’s primary shopping
destination. The town centre’s
role is complemented by a
number of important district,
local and neighbourhood
shopping centres, which all
contribute to Eastbourne’s
overall retail offer.”
33
ID
No.
61
Section
Paragraph no.
and subject
A Portrait of
Eastbourne
Respondent
Mr Bob Watts
Summary of
Representation/Comment
Proposed Response
Recommended Change
established in LTP3 for a
reduction in journey times
between Eastbourne and
London Victoria/London
Bridge.
All of these roads are, for the
most part single-carriageway
and consequently journey
times are longer than might be
expected. The town is wellserved by rail, with half-hourly
services to London Victoria.
Other direct rail services
connect the town with
Brighton, Hastings and Ashford
International (where there is
an interchange facility for rail
services to continental Europe).
No change
1.1.9 EBC has not managed to
resolve the joint use of the
promenade by both pedestrians
and cyclists.
The Council is currently
preparing a Cycling Strategy,
which will seek to address
these issues.
1.1.10 The adherence to the
revoked South East Plan target
for 4,800 houses is driving the
objective to cover the remainder
of the development land at
Sovereign Harbour with
apartments.
The 4,800 housing figure that
was established in the
revoked* South East Plan
(which was the same as the
Option 1 figure put forward
by the Council) was informed
by a strong evidence base. It
would be inappropriate and
not in the best interests of
the Borough’s future
prosperity, to argue for a
lower housing figure as
extensive research justifies
the overall housing target for
the period 2006-2026. The
No change
34
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
figure is increased by 222 to
5,022 to ensure that the plan
has a 15-year supply of land
from the point of adoption.
1.1.16 This section should refer
to the challenges faced by
communities/neighbourhoods.
Agreed there is a need for a
comment on the role of the
neighbourhoods.
Delete second sentence of
paragraph 1.1.16 and replace
with:
“Eastbourne’s fourteen
neighbourhoods each have
their individual strengths,
opportunities and identities but
each also faces a variety of
specific challenges. The Core
Strategy seeks to preserve and
enhance each neighbourhood’s
unique identity and help each
grow positively and sustainably
over the course of the plan
period”.
111
A Portrait of
Eastbourne
South Downs
Society
It would be helpful to see a
reference on the South Downs
National Park in economy as well
as under open space. The high
quality landscape within and
adjoining the borough, recently
confirmed as a national park, are
economic assets not just
constraints.
Agreed this would be helpful.
It is recognised that the
South Downs National Park is
an important economic asset
and additional text is
proposed to the relevant
section.
In para. 1.1.6 after United
Kingdom, insert new sentence:
“It is also important to
recognise the important role
that the Borough’s natural
assets can play in encouraging
tourism and benefitting the
local economy”.
109
A Portrait of
Eastbourne
J A Williams
Urgent regeneration of the town
centre is required. To convince
The Town Centre Area Action
Plan (AAP) deals with the
No change
35
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
the major retail groups to make
investment will require a
stronger local economy, in which
jobs can be provided to give
people spending power.
issue of regeneration in a
comprehensive manner
There should be considerable
regeneration in the commercial
sector to provide these jobs.
Pleased to note (1.1.6) that a
'key priority' is the development
of a Science Park in Sovereign
Harbour.
The importance of a Science
Park is recognised and the
Council is currently exploring
mechanisms to attract
additional inward investment
into Sovereign Harbour to
bring forward a Science
Park/Hi-Tech Business
Development.
No change
Eastbourne is isolated on the
south coast with poor access to
the M25, and the main motorway
network. Connections by rail to
London and Europe are poor.
Transport is a major factor that
will restrict commercial
regeneration without targeting
specific industries that do not
have a requirement for staff or
goods to travel.
See response to 60 above.
See response to 60 above.
There is no evidence of a
shortage of properties to buy or
rent as far as local needs are
concerned or evidence provided
for an influx of people wishing to
The housing figure that was
established in the South East
Plan (see above response to
61); The revocation of this
Plan does not eliminate the
No change
36
ID
No.
141
Section
Paragraph no.
and subject
A Portrait of
Eastbourne
Respondent
J McNally
(Bespoke)
Summary of
Representation/Comment
Proposed Response
Recommended Change
move to Eastbourne. Unless
commercial regeneration actually
takes place, there will be no
need to provide new homes on
the scale suggested.
need for local planning
authorities to identify
sufficient land to deliver the
necessary housing. The
Council has therefore decided
to continue with the housing
target set in the South East
Plan.
1.1.1 The emphasis on improving
tourism needs to welcome
visitors such as fitter people
wanting to walk and cycle. Need
better links with the South
Downs way from the station and
a cycle lane along the seafront,
past hotels.
Agree the need for links with
the South Downs and
improvement to general
cycleway improvements.
Amendments are proposed to
Transport section.
See changes proposed to
Transport section
1.1.4 Eastbourne welcomes
students at the University and
language schools. Cycling should
be a key method of transport but
many are put off by the
impression that it is not safe.
1.1.5 A Sustainable Building
Design Supplementary Planning
Document (SPD) is being
prepared. Suggest that new
developments should include
adequate parking for bicycles,
which would add little extra cost
to new developments.
Comment accepted but it is
suggested that a more
appropriate place for dealing
with cycling safety is
paragraph 1.1.9
In paragraph 1.1.9 add the
following sentence after “public
transport use.”, “These will
seek to improve reliability,
perception and safety.”
The Sustainable Building
Design SPD is being prepared
and is scheduled to go out for
a 12-week period of
consultation from September
2011 to December 2011.
Policy D8: Sustainable Travel
also deals with the issue of
providing for the needs of
No change
37
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
cyclists.
1.1.9 Support Eastbourne
becoming a low carbon town and
the intension to encourage more
cycling
Support welcomed
No change
1.1.17 The emphasis on a
neighbourhood approach
removes the joined-up
opportunity to create workable
cycle paths between homes,
schools, shops, workplaces and
train stations.
See responses to comments
in the Transport section
regarding the preparation of
a Cycling Strategy and
additional paragraph
proposed at .
No change
112
Spatial Vision for
Eastbourne
South Downs
Society
Pleased to see reference to
protection, nurture and
enhancement of the Downs
Support welcomed
No change
200
Spatial Vision for
Eastbourne
Miss Charlotte
Handscomb
(DPP Planning)
Support the aims and priorities.
The detail contained within the
supporting text at paragraph
1.2.4 is effective and relevant in
terms of EBC encouraging and
supporting development and the
proactive approach that is
necessary to achieve this.
Consider it should be
emphasised more overtly as a
core commitment to the Borough
Council’s priorities.
Support welcomed and
comment noted. The
Council’s approach is
considered to reflect an
appropriate balance between
the importance of managing
change constructively, whilst
at the same time ensuring
that physical and natural
elements are protected.
No change.
175
Spatial Vision for
Christine
Re Seaside destination -this is
Agreed coastal is a more all-
See changes proposed to
38
ID
No.
Section
Paragraph no.
and subject
Eastbourne
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Purkess
(Eastbourne &
District
Chamber of
Commerce)
the wrong image to set before
the business community and
suggests a bucket and spade
economy. Suggest the word
coastal would be more
appropriate
embracing term however
‘seaside’ is also considered
an important in view of
Eastbourne’s tourism role.
Transport section
re Townscape - there is a lack of
a real vision as to what the town
might be like in 20 years,
particularly the property
landscape. Large houses being
demolished and replaced with
blocks of flats gives a piecemeal
look to the whole town. More
dynamic and purposeful planning
policies are required. There is a
risk of losing stock of high
quality detached housing which
is attractive to high earners and
entrepreneurs, which the town's
economy needs to attract and
retain.
The existing conservation
policies in the Eastbourne
Borough Plan and the
Townscape Guide already
provide guidance on
redevelopment or conversion
of existing properties. Whilst
the retention of older
attractive buildings can be
preferred to replacement,
this is not always practical
and redevelopment can also
have advantages in providing
modern more efficient
dwellings more suited to
present day needs. The
Council wishes to see a mix
of dwellings provided,
including stock at the upper
end of the market, in order to
provide for all population
needs
Suggest an overall policy for how
the Council will deal with the
many properties which are its
It is not considered that this
is the most appropriate
document for inclusion of
In paragraph 1.1.9 add the
following sentence after “public
transport use.”, “These will
seek to improve reliability,
perception and safety.”
39
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
responsibility.
such a policy.
Recommended Change
222
Spatial Vision for
Eastbourne
Mr Barry
Cansfield
Introduce a new second bullet
point as follows: To prioritise and
promote Site SA1 as the
preferred location to
accommodate additional retail
floorspace up to 2016 and
beyond.
It is not considered that it is
appropriate for this to be
identified here. See response
to 220a in the Town Centre
Neighbourhood section.
No change, but see proposed
amendment to para. 3.2.6.
183
Spatial Vision for
Eastbourne
J A Williams
The use of the words 'integrated'
and 'sustainable' is meaningless
unless they are consistently
applied throughout both planning
and execution.
Agree. The Council is
committed to delivering on
the proposals through this
and future strategies and
plans.
No change
166
Spatial Vision for
Eastbourne
Royal Mail
Support the Vision which seeks
to make Eastbourne a premier
seaside destination. Should the
Eastbourne DO come forward for
redevelopment in the future, the
relocation/re-provision of Royal
Mail's existing operations on site
would be required prior to
redevelopment.
No change. See response to
(from town centre section)
62
What are the key
issues affecting
Eastbourne?
Mr Bob Watts
1.3.2 There is a need for larger
affordable family
accommodation, but this is
incompatible with the two bed
holiday apartment development
The Council acknowledges
the importance of ensuring
the relocation/re-provision of
Royal Mail’s existing
operations be identified and
implemented prior to any
possible future
redevelopment of the
Eastbourne DO site. These
issues would be discussed if a
planning application was
submitted.
Housing proposals at
Sovereign Harbour will be
expected to include a mix of
dwellings in accordance with
current policies. and with
No change
40
ID
No.
113
Section
Paragraph no.
and subject
What are the key
issues affecting
Eastbourne?
Respondent
South Downs
Society
Summary of
Representation/Comment
Proposed Response
approved by EBC for Sovereign
Harbour. Affordable housing is
code for social housing,
Proposed Policy D5: Housing
which requires proposals for
housing to “take appropriate
account of the need identified
in the most up-to-date
strategic housing market
assessment with particular
regard to size, type and
tenure of dwellings”.
Affordable housing is defined
in paragraph 27 of PPS3 as
“including social rented and
intermediate housing”.
Agreed. There is also a need
for a general paragraph on
tourism in this section.
Reference to tourism should be
developed to embrace green or
sustainable tourism. It is vital
that the core strategy recognises
the need to conserve the
environmental assets that are at
the heart of the tourism
resource.
Pleased to see reference to the
need to tackle the issue of
accessibility to the Downs.
Support welcomed
Recommended Change
Insert new subsection and
para. After para. 1.1.6
‘Economy’ and before
‘Shopping’:
Tourism
Tourism is a fundamental
element of Eastbourne’s
economy and over 4 million
people visit Eastbourne each
year, attracted by several
kilometres of coastline, a wellpreserved seafront, and the
nearby South Downs National
Park. The town benefits from
its own microclimate, and is
one of the sunniest places in
the UK.
41
ID
No.
143
32
Section
Paragraph no.
and subject
What are the key
issues affecting
Eastbourne?
Spatial Objectives
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
J McNally
(Bespoke)
1.3.4 The town centre would be
better used if access were easier
for cycle paths and with cycle
parking that works.
See responses in the town
Centre and Transport
sections concerning the
preparation of a Cycling
Strategy.
No change
Mr Michael
Wardroper
Delete 2nd sentence of
paragraph 1.3.6 and replace
with: “The private car
dominates vehicular
movements for business and
leisure use within the Borough,
and the Council recognises that
many of these trips could be
made by public transport, cycle
or by walking”.
1.3.6 Pleased at reference to
over-reliance on the private car
but dispute the notion that the
disparate nature of key local
destinations makes the private
car the only effective mode of
travel. Most journeys are less
than 3 miles. What stops people
cycling is the perception of
danger.
A key objective of the Cycling
Strategy is to identify a
network of cycle routes which
link residential areas to
locations such as schools,
leisure centres and business
parks. The text could be
amended to present a more
positive outlook.
Re Key spatial objectives - Most
of the recent blocks of flats in
the Princes Park area are of
unattractive, utility design.
Comment noted. The Council
will continue to seek the best
design solutions for individual
sites.
No change.
1.4.3 The town cannot absorb so
much new housing without
infrastructure. The private car
cannot be magicked away and
car parking facilities should be
improved - visitors, need to park
conveniently and cheaply.
Agree That the Borough
requires new infrastructure to
be able to successfully deliver
the levels of housing
proposed. The Infrastructure
Delivery Plan (IDP) identifies
what infrastructure is
required and the funding
mechanisms available to
achieve them.
No change.
42
ID
No.
63
Section
Paragraph no.
and subject
Spatial Objectives
Respondent
Mr Bob Watts
Summary of
Representation/Comment
Proposed Response
1.4.6 A tourist office needs to be
located on the way into town,
with adequate parking.
This is not an issue for the
Core Strategy but the
comments will be forwarded
to the Tourism Department.
The proposed delivery of
housing to meet the targets
will include some reliance on
windfall sites. The estimate
for the windfall allowance is
based on past trends and is
considered to be realistic and
achievable.
1.4.3 A continuing commitment
to the previous housing target of
5022 units by 2027 without
identifying accurately the source
of land necessary or having a
clear idea of how the target will
be met seems irresponsible. How
much confidence can one have in
windfall development?
1.4.11 Re Sovereign Harbour
and sustainability - decisions are
the best guide to the future and
sustainability has not been at the
forefront of council thinking, This
section is a list of aspirations
without a clear idea of how they
can be achieved.
114
Spatial Objectives
South Downs
Society
Particularly endorse objectives
nos. 1 (Sustainable
Development), 5 (Tourism), 6
Section 1.4 is the starting
point for the Core Strategy
and is intended to provide
high level aspirations which
are then carried through into
more detail in the following
strategy and further LDF
documents. One of the key
elements of the spatial
strategy is to create two
priority locations for new
residential development in
two sustainable centres and
enhancement of these two
centres to make them
sustainable.
Support welcomed
Recommended Change
No change
No change
No change
43
ID
No.
83
Section
Paragraph no.
and subject
Spatial Objectives
Respondent
Mr Ashley Wynn
Summary of
Representation/Comment
Proposed Response
Recommended Change
Agree. The constraints to
development are one of the
key challenges facing
Eastbourne.
No change
The Core Strategy's approach to
neighbourhood areas needs to be
part of an overarching
development approach to the
Borough as a whole.
Additional text is proposed
to assert the link between
each neighbourhood and the
overall strategic vision and
spatial development strategy
for the Borough as a whole.
See new paragraph proposed
after para. 3.1.4 in response to
85 above.
3. The strategy does not show
how a collaborative approach will
work in the wider Borough and
its growth and evolution. It
appears growth will be largely
restricted to infill development
and does not consider the overall
needs and requirements of the
Borough as a whole.
The options for growth are
limited by the tight
constraints to development in
the borough. The strategy is
based on meeting needs
without further encroachment
onto valuable Greenfield
land. This results in some
reliance on windfall
development but this is
based on sound evidence of
deliverability.
No change
4. In some parts of the plan area
This land has been identified
No change
(Community Health), 7 (Green
Space and Biodiversity), 8
(Sustainable Travel) and 9
(Quality of the Built
Environment), which all relate to
the national park.
The tight constraints of the
urban area of Eastbourne mean
challenges in providing the
necessary development to meet
future needs.
44
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
development boundaries have
been positioned without thought
to use of appropriate natural or
man made boundaries. The
development boundary is sited
around the Mill PH site and along
the western boundary of
Larkspur Drive, rather than
taking a line delineated by the
Willingdon and West Langney
Sewer. The existing development
boundary shown within the
current Eastbourne Borough Plan
should be maintained.
in the SHLAA as not suitable
for development due to flood
risk and therefore it is not
therefore appropriate to
include within the boundary
of the built up area.
( see also response to 151 in
Section B)
6. There is an omission from the
overall strategy of the need to
provide adequate
accommodation for the elderly
such as residential care homes.
There is no reference to
sheltered housing or residential
care. Provision of
accommodation for the elderly is
fundamentally different to that of
standard residential
development. There should be
evidence The provision of elderly
accommodation should be of
higher priority than it appears to
have been currently afforded by
this draft .
The Core Strategy aims to
provide a plan and guidance
for the diverse needs of all
sectors of the population
including the elderly. This is
already explained in
paragraph 1.3.8 and it is not
considered that specific
reference needs to be made
to the needs of the elderly.
Recommended Change
No change
45
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
7. Policy D7 sets out the strategy
for the future provision of
community, sport and health
within the Borough but relies on
the cooperation of other
organisations in providing these
facilities, and is too general. A
clearer direction on the type and
level of facilities needed and
where in the Borough these shall
be located is needed.
The delivery of necessary
infrastructure to support the
development proposals in the
Plan are dealt with in the
Infrastructure Delivery Plan.
This identifies who will be
responsible for providing
facilities and how and where
they will be delivered.
No change
Delete Key Spatial Objective 2
and replace with:
“To deliver new housing,
employment and shopping
opportunities by planning
positively and proactively
through an integrated
approach to meet the needs of
all sections of the local
community and the needs of
sustainable growth within
environmental constraints”.
No change
201
Spatial Objectives
Miss Charlotte
Handscomb
(DPP Planning)
Additional wording proposed to
carry forward the intention
specified at para. 1.2.4 and set a
positive contextual tone that can
be carried forward throughout
the rest of the document.
Agreed. The Council is
committed to adopting an
integrated and positive
approach to development but
one in which the needs and
views of local communities
are taken into account in the
decision-making process.
146
Spatial Objectives
J McNally
(Bespoke)
1.4.9 Welcome the key spatial
objective of sustainable travel.
1.4.10 Suggest adding to the key
spatial objective around the
quality of the built environment,
that provision for cycling and
cycle parking should be expected
for every new development.
Whilst the point is
acknowledged, key spatial
objective 9 deals specifically
with the built environment
and reference to cycle
parking is too specific.
46
ID
No.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
184
Section
Paragraph no.
and subject
Spatial Objectives
J A Williams
The Spatial Objectives rely on a
rather hopeful "if you build it,
they will come" approach.
Note particularly Key Spatial
Objective 6: Community Health.
This is reinforced by the
statement (1.4.7) that
"Appropriate levels of
infrastructure will be provided to
meet existing and proposed
developments.”.
The Key Spatial Objectives
are not intended to provide
detailed plans of action. This
is and will be dealt with once
the overall strategy is agreed
and in place. An additional
sentence is proposed to
identify the opportunity to
tackle existing deficiencies in
provision.
In paragraph 1.4.7 add a new
sentence stating:
“Opportunities to address
existing community
infrastructure deficiencies will
also be explored.”
169
Spatial Objectives
Royal Mail
Support the Key Spatial
Objectives
Support welcomed
No change required
Part B: Establishing the Strategy
Policy B1: Spatial Development Strategy and Distribution
ID
No.
115
Section
Paragraph
no. and
subject
Policy B1:
Spatial
Development
Strategy and
Distribution
Para 2.1.3
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
South Downs
Society
The Society welcomes the approach of
favouring brownfield and some poor
quality urban greenfield sites to meet
development needs. References to the
economy should be broadened to include
the important role that green tourism can
make to economic, as well as
environmental, wellbeing.
The Council welcomes the
South Downs Society’s
support. Reference to green
tourism would be better
placed in the supporting text
to the spatial development
strategy under paragraph
2.1.3.
Add the following sentence to
end of paragraph 2.1.3 to read
‘Green tourism also plays an
important role in the Borough’s
economic and environmental
well-being.
47
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
57
Policy B1:
Spatial
Development
Strategy and
Distribution
S J Vine
The representation relates to 7 acres of
land adjacent to Priory Road, within the
Borough of Eastbourne.
The Land in question was
assessed in the Strategic
Housing Land Availability
Assessment (SHLAA), an
important evidence document
for the LDF. The SHLAA
thoroughly assesses all
sources of potential future
housing land supply. The land
was assessed as
undevelopable due to high
fluvial flood risk, biodiversity
importance and potential
impact on the Pevensey
Levels RAMSAR site.
There were opportunities for
stakeholders and the
community to comment on
the spatial development
options (November 2009January 2010), including an
opportunity to comment if
any other options or sources
of land should be considered
for residential development
at this stage. One comment
was received, stating that we
should not rule out
alternative greenfield sites
for residential development
as part of the spatial
No change
When the Council put out for consultation
the Sustainable Neighbourhood
Assessment in November 2009, four
options were put forward for how
Eastbourne’s planning needs should be
met in the coming 15 years, the options
did not contain any reference in this land.
The Scott Wilson (Strategic Flood Risk
Assessment) report, shows no flooding
issues with this land and yet the land was
not referred to anywhere for possible
development. The present consultation for
representations is flawed because the
facts as to the available land within the
Borough of Eastbourne were not properly
and openly communicated to the
electorate. The process has not been dealt
with fairly.
48
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
development strategy. The
evidence prepared to support
the production of the Core
Strategy, including the
SHLAA and Strategic Flood
Risk Assessment are strong
pieces of evidence which
highlight that this land is not
developable or deliverable for
residential development.
78
Policy B1:
Spatial
Development
Strategy and
Distribution
Trustees of the
Chatsworth
Settlement
This policy identifies the quantum of
commercial and residential development
to be delivered, and deals with its spatial
distribution. However, on the basis of the
conclusions reached in respect of
projected housing land supply, no
provision is made for urban extensions.
Such limited greenfield sites as are
contemplated are to be within the existing
urban area (where there are likely to be
various competing demands on land use).
The Planning Inspectorate produced an
advice note entitled "Local Development
Frameworks Examining Development Plan
Documents: Learning from Experience".
Para 21 advises local authorities that
"simply claiming that development needs
will be met within the urban areas and
that the position will be reviewed if
necessary in the future is not likely to be
The only provision made for
Greenfield urban extension
sites is on developable and
deliverable sites. This
accounts for only one site
known as Kings Drive/Cross
Levels Way.
No change
A strong evidence base has
been prepared in support of
the Core Strategy which has
helped to assess the
development potential and
deliverability of land for
housing in the Strategic
Housing Land Availability
Assessment (SHLAA). The
evidence base has
highlighted a number of
development constraints, the
most critical of which on
49
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
acceptable unless there is evidence that
the 'urban areas only' approach is likely to
be realistic.
Greenfield sites is flood risk
and biodiversity. The severity
of these constraints impedes
residential development on a
significant proportion of land
that would be defined as
‘Greenfield urban extensions’.
Where the scale of land needed for
development is such that greenfield
allocations are likely to be required the
strategy should make this clear". SHMAs
and SHLAAs are important for showing
how the Plan will enable housing
development. However, the Council's
published SHLAA work was undertaken on
the basis of current affordable housing
policy. The impact of the proposed
changes to the level of affordable housing
threshold under Policy D5 of the Core
Strategy was not the preferred policy
option in the Preferred Options
Consultation. This may have coloured
some of the respondents to the SHLAA
exercise. The point is that the identified
net units through the SHLAA exercise
cannot be expected to be the same
number that might come forward in a new
policy regime under proposed Core
Strategy Policy D5. This suggests that
either Policy D5 needs reworking or the
plan needs to acknowledge the potential
need for some urban extensions, or both,
depending on the circumstances.
The Evidence Base contains no
Recommended Change
The SHLAA does not
individually determine the
level of housing development
proposed, it is purely an
assessment of the amount of
land available for
development and its
deliverability. As a high
proportion of land in the
Borough is undevelopable
and the deliverability of other
sites due to financial viability
and other constraints is
difficult, the Council will
ultimately need to rely on
windfall development. The
SHLAA looks at the potential
amount of development
potential that could be
achieved through windfall
development.
As the SHLAA is a snap-shot
of land availability at a
50
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
assessment of the likelihood that
redevelopment of existing sites and
existing committed capacity will be able to
deliver the level of floorspace identified.
Whilst that type of assessment is not a
national planning requirement,
certain time, there are other
sites that become available or
are granted planning
permission which can be
accounted for in housing
delivery. The amendments in
emerging local policy do not
fundamentally change the
overall housing requirements,
nor result in the need to
identify undevelopable
housing sites.
It is agreed that
redevelopment of land to
increase residential density is
challenging, but sites have
only been identified for this in
the SHLAA if there is
developer interest or preapplication discussions have
taken place.
Recommended Change
The main issue with regards
the comments made is the
suitability and ‘developability’
of Greenfield land outside of
the built up area boundary. A
high proportion of the land is
not developable, therefore
cannot form part of the
spatial developments
strategy for residential or
51
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
employment land
development.
131
151
Policy B1:
Spatial
Development
Strategy and
Distribution
Policy B1:
Spatial
Development
Strategy and
Distribution
Howard Moore
Mr John
Egerton,
Clinton
Development
Company Ltd
Note that the strategy will deliver 5,022
dwellings and 55,430 m² employment land
between 2006 and 2027. Whilst this
differs from the levels assessed within
SWETS, the need to demonstrate a 15
year housing supply (from date of
adoption) is recognised and is therefore
content with this approach.
An additional 222 net units is
required above the SE Plan
figure of 4,800 dwellings to
2026 to increase the supply
up to the end of the plan
period in 2027.
The focus on development in the town
centre and on brownfield land could result
in fewer car based trips as these areas
tend have better access to sustainable and
public transport infrastructure. This
approach accords with PPG 13 and could
help minimise the impact on the Strategic
Road Network.
Welcome support for the
Council’s focus on brownfield
development and conformity
with national planning policy.
Acknowledge challenges in meeting future
development needs in line with the
strategy vision. The creation of
neighbourhood areas needs to be part of
an overarching development approach to
the Borough as a whole to ensure a coordinated approach rather than one which
potentially results in development which
has no correlation to the adjacent
neighbourhood areas or the aims for the
Borough as a whole.
Welcome support for the
neighbourhood approach. The
connection and interaction
between the 14
neighbourhoods is addressed
in both policy BI1 and
explicitly in BI2: Creating
Sustainable Neighbourhoods.
(See response to 85 and
proposed change, in the
‘Whole Document’ section
No Change
Add the following underlined
text to the end of the first
sentence in Paragraph 2.12:
…land within the existing urban
area (defined by the built up
area boundary).
Add the following text to the
wording of Policy B1: Spatial
Development Strategy
52
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Making use of existing patterns of built
form using the line of constraints, whether
man-made or natural, to act as the
development boundaries is appropriate.
However in some parts of the plan area
development boundaries have been
positioned without thought to this
approach. This is evident in the
Shinewater and North Langney
neighbourhood area whereby the
development boundary is sited around the
Mill PH site and along the western
boundary of Larkspur Drive to limit the
extent of the development in the area,
rather than taking a more natural line
delineated by the Willingdon and West
Langney Sewer which runs along part of
the eastern boundary of Eastbourne Park.
202
Policy B1:
Spatial
Development
Strategy and
Distribution
Miss Charlotte
Handscomb,
DPP Planning
Support carrying forward of housing
supply targets to 2027 in order to
maintain a strategic plan for the Borough.
Identified sources of new housing supply
(i.e. non windfall sites) are dependent on
landowners and developers proceeding
and therefore on favourable market
Proposed Response
Recommended Change
above.)
The spatial development
strategy will deliver at least
5,022 dwellings and 55,430
square metres of employment
land by 2027 within the built
up area boundary, in
accordance with the principles
of sustainable development.
Regarding comments made
on the boundary of
Neighbourhood 9: Shinewater
& North Langney – the
suggested amendment would
include land that has been
identified within Eastbourne
Park. The built up area
boundary has changed in this
area (compared to the built
up area boundary of the
Eastbourne Borough Plan) as
this land is low-lying and
more akin to surrounding
land in Eastbourne Park.
It is accepted that the built
up area boundary needs to
be made clear in the spatial
development strategy section
by adding some additional
explanatory text and by
annotating the built up area
boundary in the key diagram.
Welcome support for the
spatial development strategy.
It is agreed that regular
monitoring of the SHLAA and
housing delivery is required,
to keep under review the
delivery of sites and track
Amend the Key Diagram to
mark out the built up area
boundary which follows the
neighbourhood boundaries
around Eastbourne Park, the
South Downs National Park and
boundary between Mountney
Levels and neighbourhoods 8,
9 and 14.
Revise paragraph 2.1.11 to
replace Annual Monitoring
Report (AMR) with Local
Monitoring Report (LMR).
Add additional paragraph
between existing paras 2.1.2
53
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
conditions and scheme viability. This can
be an issue for redeveloping brownfield
sites and conversion, which form sizeable
parts of potential supply. Annual
monitoring of the SHLAA opportunity sites
and actual housing delivery, and clear
pipeline opportunities is necessary.
Consider it paramount that EBC maintains
commitment to monitoring as specified in
para. 2.1.11.
anticipated windfall housing
delivery. This commitment
stands and paragraph 2.1.11
should be revised to state
Local Monitoring Report
instead of Annual Monitoring
Report, as there is no longer
a statutory requirement to
produce a monitoring report
annually.
The purpose of Policy B1 and how it
relates to other parts of the document that
address similar matters needs to be made
clearer. This is in particular in terms of
how the Sovereign area is appraised and
promoted as a ‘sustainable’ and ‘priority’
location. Sovereign is identified as one of
two sustainable centres, however, within
the subsequent Table 4 it is ranked 12th
out of 14 in terms of its overall
sustainability ranking. The presentation of
this material across different sections of
the Strategy is confusing. The intention of
Policy B1 may be to outline the end state
of Eastbourne in 2027 or to reflect the
supported direction of growth that reflects
current sustainability rankings of specific
areas in the Borough.
Agree that greater clarity is
required in the definition of
‘sustainable centre’ and
support is given to additional
explanatory wording in the
description of Sovereign is as
a ‘priority’ location for new
residential development. The
neighbourhood is a priority
location because the
remaining development sites
are required to meet local
and strategic needs for
Eastbourne and in doing so
will address other issues such
as site access, linkages and
contributions to additional
community infrastructure.
and 2.1.6 to provide greater
explanation on ‘sustainable
centres’. The additional text to
read:
‘The Spatial Development
Strategy identifies two
‘sustainable neighbourhoods in
which housing growth will be
balanced by significant
improvements in the provision
of community services and
facilities. This will allow the
Town Centre to sustain its
projected high level of housing
growth and will improve the
Sovereign neighbourhood by
addressing issues such as site
access, linkages and
contributions to additional
community infrastructure’
Support the allocation of housing at
The Sustainable
Neighbourhood Assessment
Amend the wording of Policy
B1: Spatial Development
54
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Sovereign in view of remaining sites, their
brownfield land status, their suitability for
residential development and how these
can come forward as part of a master
planned approach alongside community
and other uses. In providing 6.5% of the
Borough’s housing new supply, however, it
is not a priority area in terms of the
quantum of development suggested. The
area is a priority for ensuring that its
remaining development sites are brought
forward to meet local and strategic needs
and will address other issues such as
access, linkages and contributions to
community infrastructure. Suggest that
the definition of priority as it relates to
Sovereign should be revisited in the
interest of clarify.
(SNA) confirms that
Sovereign neighbourhood
scores relatively poorly
compared to other
neighbourhoods based on the
criteria outlined in the
assessment and summarised
at the neighbourhood
consultation events. The idea
of creating a ‘sustainable
centre’ means actively
creating a sustainable
neighbourhood by balancing
housing growth with
community services and
facilities that are required.
Greater clarity should be
provided in the supporting
text in an additional
paragraph within the section
‘Spatial Development
Strategy’ to explain this is
more detail.
Strategy from ‘The priority
locations for new…’ to read:
“The priority locations for
balanced housing growth
alongside delivering significant
improvements to the provision
of community facilities and
services and improving
linkages within the
neighbourhoods will be in the
two sustainable centres.”
142
Policy B1:
Spatial
Development
Strategy and
Distribution
Johnston Press
plc
Support the approach of giving priority to
previously developed sites, with a
minimum of 70% of the housing on
brownfield land.
Welcome the support for a
brownfield-led strategy
No Change
185
Policy B1:
Spatial
J A Williams
The context for the spatial vision and
strategic objectives (2.1.1) highlights that
The Core Strategy does not
prescriptively set the mix of
Propose change of wording of
Sovereign neighbourhood
55
ID
No.
Section
Paragraph
no. and
subject
Development
Strategy and
Distribution
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
future development "Meets the needs of
local communities including the necessary
supporting facilities and services". The
spatial development strategy supports this
by adding "by providing homes that not
only meet the needs of the local
community but also attract workers and
their families into the Borough". Query the
requirement for additional two-bedroom
flat development in Sovereign Harbour.
There is no indication of the required
balance between houses and flats.
Providing the wrong types of property in
the wrong places will do nothing for
growth in the longer term.
housing types and sizes
required on development
sites neither in Policy B1 nor
in the Housing Policy D5.
Policy D5: Housing does
however state that regard
should be made to the
Housing Market Assessment
as to need for different
housing types. This highlights
a need for smaller unit
accommodation, but
reinforces the need for a mix
of housing types and larger
family housing or larger sites.
section to ensure infrastructure
is delivered before housing
development commences.
Further text is required at the
end of paragraph 3.15.5:
‘..and that the supporting
infrastructure is delivered
before housing development.’
The original masterplan for Sovereign
Harbour envisaged 2,500 homes with
sustainable facilities. Approximately 3,500
new homes have been built but as yet
there are no cultural, recreational,
sporting facilities or community health
care provision. It is that the facilities
cannot now be provided without additional
homes - rather it should be that additional
homes will not be allowed until the
facilities are provided.
171
Policy B1:
Spatial
Royal Mail
Note the policy to ensure that future
growth is delivered in accordance with the
Accept that greater clarity
should be given to the
requirement that the
additional community
infrastructure required in the
Sovereign neighbourhood will
need to be delivered before
new residential development.
(see responses to this issue
within the neighbourhood
chapter for Sovereign
(Neighbourhood 14).
Welcome support for a
brownfield-led strategy and
No Change
56
ID
No.
Section
Paragraph
no. and
subject
Development
Strategy and
Distribution
Respondent
Summary of
Representation/Comment
Proposed Response
principles of sustainable development and
support the principle of prioritising and
encouraging the redevelopment of
brownfield land.
for higher levels of residential
density within the Town
Centre neighbourhood.
Welcome support for mixed
use development of housing
and employment on key
strategic development sites.
Support the regeneration of Eastbourne
Town Centre, and the identification of
higher residential densities in this location,
and improve the sustainability of
neighbourhoods.
223
Policy B1:
Spatial
Development
Strategy and
Distribution
Mrs S.
Stricksson
Channel 2000
Ltd
Land at Mountney Bridge (20 acres)was
not included in any of the 4 options put
forward as alternative strategies in the
consultation document November 2009,
on the basis that land was classified for
flood risk 3(a). Eastbourne Harbour and
surrounding area is classified in the same
category for flood risk 3(a), but there is a
proposal for more intensive development
of the Harbour, and yet the availability of
20 acres of land falling within the same
flood risk has been ignored.
The SFRA (Scott Wilson Report) shows
further land abutting Priory Road which is
categorised as less likely to flood than the
Harbour, yet this land was not put forward
in any of the options.
The present consultation is not being
properly or fairly conducted as the
electorate have not been informed of this
land which is available for development.
See response to
representation ID 78.
Recommended Change
No change
57
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
33
Housing
Trajectory by
Type 20062027
Mr Michael
Wardroper
Why is so much new housing required
when there are so many properties for
sale and rent? There is already a high
percentage of unemployed people in the
town.
There is a need for new
housing across all areas of
the country. Locally this is
based on the needs and
demands of people who
already live in the Borough,
and those who wish to move
to the Borough. Evidence
prepared for the South East
Plan (which is still credible
evidence) forms and justifies
the basis of the local housing
target of 5,022 new homes
by 2027. Along side new
homes, new employment
land is essential to cater for
increased population growth
and help alleviate existing
unemployment levels.
Evidence prepared locally
based on needs and demands
and population/workforce
projections forms the
justification for targets.
No Change
34
Figure 2:
Eastbourne's
Neighbourhoo
d Diagram
Mr Michael
Wardroper
Regarding the proposed additions of 150+
new units in Sovereign Harbour, the area
is already saturated with housing and does
not have the social amenities that were
initially planned. Also it is essential to
have an additional entry and exit to the
The deliverability of the
community infrastructure
within the Sovereign
neighbourhood is dependent
on the development of
housing led balanced growth.
No Change
58
ID
No.
64
Section
Paragraph
no. and
subject
Table 3:
Breakdown of
Housing
Delivery 2006
- 2027
Respondent
Mr Bob Watts
Summary of
Representation/Comment
Proposed Response
North Harbour - there is only one at
present - to alleviate the traffic and
provide a better evacuation in case of
flood or fire emergency.
This ensures that other
issues
such as the provision of new
community facilities,
improved site access, and
linkages within the
neighbourhood can be
significantly improved.
Additional units for Sovereign Harbour
which will (initially) be holiday
apartments. How will that improve the
sustainability and improve the fragile
community without investment in
community facilities which reflects the
previous development not the present.
Further applications will follow seeking to
re-classify the existing land identified for
employment opportunities.
The Core Strategy does not
set the mix of housing types
and sizes required on
development sites. Policy D5:
Housing does states that
regard should be made to the
Housing Market Assessment
as to need for different
housing types. This highlights
a need for smaller unit
accommodation, but
reinforces the need for a mix
of housing types and larger
family housing or larger sites.
The delivery of community
facilities, employment
provision and improved open
space on the remaining sites
in Sovereign Harbour,
alongside housing will ensure
that housing growth is limited
to 150 units.
Recommended Change
No Change
59
Policy B2: Creating Sustainable Neighbourhoods
ID
No.
93
Section
Paragraph
no. and
subject
Policy B2:
Creating
Sustainable
Neighbourhoo
ds
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mrs Sarah
Harrison
It is important that the amenity of
residents is protected where
development is planned close to
wastewater pumping stations or
treatment facilities.
It would be beneficial to have
some reference to
development proposals
respecting the residential and
environmental amenity of the
existing neighbourhood in
support of maintaining the
sustainability an
attractiveness of the local
area. More detailed reference
to protecting residential
amenity will be provided in
the Development
Management Development
Plan Document (DPD) which
will be prepared following
adoption of the Core
Strategy. It is therefore not
considered necessary to
amend the text further.
Amend Policy B2: Creating
Sustainable Neighbourhoods by
adding an additional bulletpoint stating:
• Protect the residential
and environmental
amenity of existing and
future residents.
Southern Water endeavours to operate
its wastewater and sludge treatment
works efficiently and in accordance with
best practice. However, unpleasant
odours inevitably arise from time to time
as a result of the treatment processes.
Sensitive development must be
adequately separated from wastewater
treatment works, to safeguard amenity.
Suggest an additional bullet point in
policy B2 as follows:
•
Protect the amenity of future
occupants.
This could be reinforced by some
explanatory supporting text:
‘Development proposals in proximity to
existing wastewater facilities will only be
permitted if there is no unacceptable
60
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
impact on the amenity of future
occupants. The distance between the
infrastructure and the development must
be sufficient to allow adequate odour
dispersion.’
132
Policy B2:
Creating
Sustainable
Neighbourhoo
ds
Howard Moore
The provision of services and facilities
within walking distance of local residents
and encouraging sustainable modes of
transport is welcomed.
Welcome the support to
encourage sustainable modes
of transport.
No Change
211
Policy B2:
Creating
Sustainable
Neighbourhoo
ds
Royal Mail
Request amendment to the wording of :
‘They will be required to’ in the Policy to:
‘The Council will seek for proposals to:
Meet the needs of the local community’
No Change
65
Table 4:
Neighbourhoo
d
Sustainability
Ranking
Mr Bob Watts
Neighbourhood 14 Sovereign is shown in
position 12 by virtue of the inclusion
within its boundaries of the Kingsmere
Estate with its many facilities provided by
EBC to its tenants. Kingsmere has never
previously been included with Sovereign
Harbour so its inclusion now I interpret
as a ploy to move Neighbourhood 14
from position 14 to position 12 in the
The strong emphasis on
sustainable communities and
sustainability throughout the
Core Strategy means that all
proposals should adhere to a
set of key sustainability
criteria. Changing the
wording of this would soften
the strong sustainability
approach intended through
this policy.
Exactly the same boundary of
Sovereign neighbourhood
was consulted on with the
public at the ‘Spatial
Development Options’ stage
in November 2009, and has
been consistent throughout
the preparation of the
Council’s Sustainable
See response in Sovereign
Neighbourhood section.
61
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
sustainability stakes.
Neighbourhood Assessment
(SNA). There have however
been a number of comments
at this stage to amend the
boundary to exclude
Kingsmere/Kings Park and an
amendment of this boundary
is proposed.
Recommended Change
Part C: Introducing the Neighbourhoods
ID
No.
89a
133
Section
Paragraph no.
and subject
SECTION C:
Introducing the
Neighbourhoods
SECTION C:
Introducing the
Neighbourhoods
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Graham ArrJones
(East Sussex
County Council)
Welcome and support the Vision
statements for each of the
Neighbourhoods, which include
reference to the role of improved
walking routes, cycling facilities
and public transport have in
achieving the visions.
Support welcomed. It is
envisaged that this
neighbourhood approach can
contribute to the creation of
sustainable communities in
Eastbourne.
No change
Howard Moore
(Highways
Agency)
Support proposals that improve
the viability of more sustainable
travel to, from and within each of
the neighbourhoods. Support
development in more sustainable
neighbourhoods with
complementary sustainable
transport measures. As the Core
Strategy progresses more detail
Support welcomed.
Sustainable travel, especially
accessing services and
facilities by walking and
cycling, is an important part
of a sustainable
neighbourhood, as is the
provision of local housing and
employment opportunities.
No change
62
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
should be provided as to how the
measures will be delivered.
The measures for delivering
the sustainable transport
measures will be outlined in
other policy documents,
including the Cycling Strategy
and East Sussex County
Council’s Local Transport Plan
3.
Localism is a very broad
concept that incorporates
more than just planning
issues. Therefore the Core
Strategy, as part of the Local
Development Framework
(LDF), can only deal with
certain parts of ‘localism’.
The Core Strategy has taken
a neighbourhood approach to
help communities express a
vision for their area and see
how they will be affected in
future. Regaining
responsibilities that currently
reside with the County
Council is something that
would need to be considered
outside of the LDF process.
39
Localism: A
Neighbourhood
Approach
Mr Colin Akers
The start point for Localism must
be to regain some of the
executive powers currently in the
hands of the County Council.
Subsequent sections in this
document refer to Policies that
will require a great deal of
support from the County Council
if nothing changes.
66
Localism: A
Neighbourhood
Approach
Mr Bob Watts
Concern that EBC councillors are
against the concept of localism.
In particular the promotion of a
community council for Sovereign
Harbour.
The Council supports the
concept of localism; however
the devolution of powers and
the creation of community
councils are not issues within
Recommended Change
No change
No change
63
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
the scope of the Core
Strategy. The Government
has recently announced its
intention to allow
communities to prepare
neighbourhood plans and the
residents of Sovereign
Harbour may wish to look
into how this could help them
in their aims. Also see
response to 199 below.
199
Localism: A
Neighbourhood
Approach
Miss Charlotte
Handscomb
(DPP Planning)
The current draft Localism Bill
was published in December
2010. Whilst the Bill is subject to
detailed review and no doubt redrafting, it does and is expected
to retain a strong commitment to
neighbourhood planning. As such
the draft Core Strategy’s
strongly focused neighbourhood
approach is relevant. Consider it
important that the Strategy
ultimately sets out how a
potential neighbourhood plan
must relate to and essentially
comply with the over-arching
strategic policies and vision of
the Core Strategy. That is, to
ultimately meet the needs and
objectives of the Borough as a
whole. We recommend therefore
that each neighbourhood section
The use of a neighbourhood
approach in the Core
Strategy was taken before
the concept of ‘localism’ was
publicly considered by
Central Government.
It is agreed that some
explanation of what will be
expected from potential
neighbourhood plans, as
currently understood, would
be useful and should be
included within the Core
Strategy.
Add paragraphs after para.
3.1.4 in Section C as follows:
“However, neighbourhoods will
have further opportunities to
shape the character of the area
in which they live. The
Localism Bill, published in
December 2010, sets out the
framework and key principles
for a system of neighbourhood
planning in England. It will
introduce a new right for
communities to draw up a
Neighbourhood Development
Plan.”
However, it is considered that
the neighbourhood visions do
already provide a clear
statement about how it will
contribute to Eastbourne, and
“Neighbourhood Plans will be
initiated by the community and
produced by an official
Neighbourhood Forums. They
are about enabling new
64
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
is revisited to include a clear
statement on its role in
contributing to Eastbourne
overall and how this has been
arrived at.
it is felt that there is no need
for further clarification in the
neighbourhood visions.
development and cannot be
used to block development.
Neighbourhood Plans will
become part of the planning
policy against which
applications are assessed and
must comply with the strategic
policies and visions of the Core
Strategy, as well as being in
line with other planning
policies, at both a local and
national level. As part of
neighbourhood planning,
groups of local people will be
given the ability to bring
forward small developments
without the need for planning
permission.”
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Amanda Steer
Town Centre has a lack of
outside space for young people.
Suggest setting aside an area of
beach for young people.
The Town Centre
neighbourhood vision
identifies that there is a lack
of children’s play space in the
neighbourhood and
surrounding area. The Town
Centre Area Action Plan
and/or the Seafront Area
No change
Neighbourhood 1: Town Centre
ID
No.
6b
Section
Paragraph no.
and subject
Neighbourhood 1:
Town Centre
65
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Action Plan will consider the
need for the provision of
facilities for children and
young people in the town
centre and seafront.
148
Neighbourhood 1:
Town Centre
J McNally
(Bespoke)
Welcome the seafront cycle path
and suggest further routes.
There needs to be more and
better cycle parking throughout
the town centre. The seafront
should be opened for cycling.
180a
Neighbourhood 1:
Town Centre
Christine
Purkess
(Chamber of
Commerce)
Support promotion of the town
centre for retail, cultural and
leisure pursuits. Suggest
extending the prime retail area
further towards the railway
station to improve
competitiveness with towns such
as Brighton and Tunbridge Wells.
The secondary retail offer is
widely spread across several
areas. Concentration of these
areas with improved access and
the conversion of less successful
premises to residential is
suggested.
Although the ambition for
improved cycle routes is
identified in the Core
Strategy, the exact location
of the cycle routes will be
identified in the Cycling
Strategy. The provision of
cycle facilities in the Town
Centre is also addressed
through the Town Centre
Area Action Plan.
The Core Strategy sets the
overall vision and direction
that development in the town
will take up to 2027. As part
of this, a vision of the future
of each neighbourhood has
been created. These are not
detailed strategies but
indicate how the
neighbourhood could change
in order to advise policy
decision in other documents
in the Local Development
Framework.
No change
No change
The detailed issues that are
66
ID
No.
84e
Section
Paragraph no.
and subject
Neighbourhood 1:
Town Centre
Respondent
Mr Barry
Cansfield
Summary of
Representation/Comment
Proposed Response
Out of town retail and internet
shopping has had an impact on
the town centre, which is now at
some risk, and there is now the
prospect of another major
supermarket (Morrisons) in
Hampden Park. These stores
benefit from bigger areas and
free parking in comparison with
the town centre.
raised in this representation,
including those that relate to
the extension of the primary
shopping area, the spread
and viability of the secondary
shopping areas, and the
attracting large brands and
independent businesses are
valid points. The future
regeneration and
enhancement of the town
centre will be at the heart of
the strategy and proposals
are to be dealt with in the
Town Centre Area Action
Plan. Once adopted, this is
intended to provide a
framework for major
investment within the town
centre to secure its future.
PRLP own the leasehold interest
of the multi-storey car park off
Junction Road. This site has
longer term development
opportunities and it is considered
that this site and its immediate
environs could reasonably be
identified as an additional ˜Key
Area of Change. The site has
excellent synergy with the
existing town centre and its
redevelopment could contribute
The future of the car park
and any long term potential
for additional development
should be considered in the
context of future parking
requirements to meeting
regeneration needs. It is not
currently identified in the
Town Centre Area Action Plan
as a key development site
and therefore it is not
considered appropriate to
Recommended Change
No change
67
ID
No.
70
197
Section
Paragraph no.
and subject
Summary of
Representation/Comment
Proposed Response
towards the overall long term
vision of enhancing the vitality
and viability of the western end
of the centre.
designate it as a ‘Key Area of
Change’. However, Core
Strategy policies do not rule
out the possibility of future
development, and any future
development proposals will
be judged on their individual
merits.
Support the vision for the town
centre, which seeks to increase
the mix of uses, including
housing, and maintain a diverse
range of services and facilities,
such as health or community
uses within the town centre.
Support welcomed. It is
important to encourage a mix
of uses in the Town Centre to
maintain a high level of
vitality and viability.
No change
Town Centre Vision
The CoOperative
Group (C W S)
Ltd
Neighbourhood 1:
Town Centre
Johnston Press
plc
Support the inclusion of the sites
'Beckett Newspapers' within
Neighbourhood 1 - Town Centre
and its corresponding 'vision'.
The site is potentially suitable for
accommodating a broad range of
uses, either on an individual
basis, or in conjunction with
other sites.
Support welcomed. This area
has been identified in the
Town Centre Area Action Plan
as being a Key Development
Site for the regeneration of
the Town Centre.
No change
Royal Mail
Support the Town Centre Vision,
which seeks to ‘maximise its
economic potential and attract
more shoppers, workers,
residents and visitors’, including
strengthen the retail offer
The identification of a site as
a Residential Opportunity Site
does not preclude any other
development occurring on
this site alongside the
residential development.
No change
Neighbourhood 1:
Town Centre
Respondent
Town Centre Vision
212
Neighbourhood 1:
Town Centre
Town Centre Vision
Recommended Change
68
ID
No.
89b
Section
Paragraph no.
and subject
Neighbourhood 1:
Town Centre
Para 3.2.6
Respondent
Mr Graham ArrJones
(East Sussex
County Council)
Summary of
Representation/Comment
Proposed Response
through new retail development
and delivering new housing
through conversions, infill
development and
redevelopment. Support the
allocation of the Royal Mail site
as a residential opportunity site
in a key area of change.
However, this should not
preclude other suitable Town
Centre uses (such as a
supermarket). The Council
should include within the wording
of the policy that the provision/
re-location of Royal Mail’s
facilities prior to redevelopment
of the site is required.
Other town centre uses will
be considered as part of any
proposed development
Note the ambition to enhance
public transport provision by
improving the integration of the
transport hub and interchanges
around Terminus Road and the
railway station. The current high
The Core Strategy does not
deal with the level of detail
relating to the location of the
bus interchange. This will be
explored through the Town
Centre Area Action Plan and
Recommended Change
The site has been identified
in the Town Centre Area
Action Plan Issues and
Options Report as a ‘Key
Development Site’ and it is
suggested that this site is
suitable for a mix of uses.
The Council recognises the
importance of the Royal Mail
operations in the town and
will continue to work with
Royal Mail to identify possible
alternative sites within the
Borough to carry out their
operations. However, it is not
considered necessary to
amend the Core Strategy
policy to include this because
this detail will be addressed
through the Town Centre
Area Action Plan.
No change
69
ID
No.
220a
Section
Paragraph no.
and subject
Neighbourhood 1:
Town Centre
Respondent
Summary of
Representation/Comment
Proposed Response
level of accessibility to bus
services adjacent to The Arndale
Centre and shopping area of
Terminus Road should not be
diminished and greater emphasis
should be given to improving the
existing bus stop facilities rather
than their relocation.
it is considered that this
paragraph allows enough
flexibility for this to happen.
Mr Barry
Cansfield
Introduce additional sentences at
the end of paragraph 3.2.6 as
follows:
SA1 is earmarked for additional
retail development. Further
details are set out in the Town
Centre Area Action Plan.
The site that is referred to,
known as Key Development
Site 1 in the Town Centre
Area Action Plan, will be
fundamental to encourage
the delivery of the other
sites. As such, it is
recognised that this site
takes a greater importance in
the regeneration of the Town
Centre and therefore it
should be recognised in the
Core Strategy as such.
Therefore, reference will be
made to the site in the
supporting text.
Amend second sentence of
para. 3.2.6 as follows: “The
neighbourhood key diagram
indicates an area identified as a
major retail development
opportunity site. Further
information on this and the
detailed strategy and proposals
for the regeneration of the
Town Centre are set out in the
Town Centre Area Action Plan.”
Steve Carey
Suggest focusing on the issues of
businesses closing and the
parking situation before
providing more retail
opportunities. Instead of
increasing the already seldom
used public transport
Improving the offer in the
Town Centre by providing
more retail opportunities will
enhance attractiveness of
Town Centre and therefore
improve the viability of shop
units that are currently
No change
Para 3.2.6
56
Neighbourhood 1:
Town Centre
Figure 3
Neighbourhood 1:
Town Centre - Key
Diagram
Recommended Change
70
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
concentrate on cycle routes and
removing some of the one way
system.
vacant. This will also be
addressed through the Town
Centre Area Action Plan.
Recommended Change
Public Transport and walking
and cycling are both
important and can
complement each other in
encouraging sustainable
travel. The Core Strategy
does recognise the ambition
to improve cycling facilities,
and the detail will be set out
in the Town Centre Area
Action Plan and also in the
Cycling Strategy.
69
Neighbourhood 1:
Town Centre
Figure 3
Neighbourhood 1:
Town Centre - Key
Diagram
84b
Neighbourhood 1:
Town Centre
Figure 3
Neighbourhood 1:
Town Centre - Key
Diagram
The CoOperative
Group (C W S)
Ltd
The identification of residential
opportunity sites is supported.
Support welcomed. It is
important to identify potential
residential opportunity sites
to give an indication as to
where growth in the
neighbourhood is expected to
occur.
No change
Mr Barry
Cansfield
Recommend that a specific
reference is identified on the
Town Centre Key Diagram
earmarking the site for Retail
Development to reflect the
importance of the site in
delivering the town centre
regeneration objective of the
The site that is referred to,
known as Key Development
Site 1 in the Town Centre
Area Action Plan, is one of a
number of important sites in
the Town Centre that will
make a significant
contribution to the
The site will be identified in the
Town Centre Neighbourhood
Vision key diagram as a ‘Major
retail redevelopment
opportunity’ by a yellow star
with a red border.
71
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Strategy.
regeneration of the Town
Centre.
A site specific designation would
provide a more robust basis for
land assembly, assessing need
and appraising sustainability and
add greater clarity for bringing
forward proposals on the site.
The outline of the proposed site
would provide clarity for bringing
forward greater detail in the
Eastbourne Town Centre Area
Action Plan currently being
developed in the shadow of the
Core Strategy.
Recommended Change
However, it is agreed that
this site will be fundamental
to encourage the delivery of
the other sites. As such, it is
recognised that this site
takes a greater importance in
the regeneration of the Town
Centre and therefore it
should be recognised in the
Core Strategy as such.
It is not considered
appropriate to allocate this
site for retail development,
particularly as there are no
other allocations within the
Core Strategy.
In order to identify the
importance of this site, it will
be identified in the Town
Centre neighbourhood vision
as a ‘Major retail opportunity
site’. Further detail on the
site will be provided through
the Town Centre Area Action
Plan.
220b
Neighbourhood 1:
Town Centre
Mr Barry
Cansfield
Introduce a ‘Strategic Allocation
for Retail Development’
See response to 84b above.
See proposed change for 84b
above.
72
ID
No.
Section
Paragraph no.
and subject
Respondent
Proposed Response
Recommended Change
Propose a ‘Key Area of Change’
annotation on the Town Centre
Key diagram centred on the
multi-storey car park site on
Junction Road.
See response to 84e
No change
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
J McNally
(Bespoke)
The Quality Bus Corridor needs
to be shown to be safe for
cyclists. We need advanced stop
lines at traffic lights. Enys Road
cul-de-sac could be opened up to
cyclists. Other cul-de-sacs should
be opened up to cyclists, e.g.
New Road.
Comment acknowledged. The
Council is committed to
encouraging cycling within
the Borough and is preparing
a Cycling Strategy in
partnership with East Sussex
County Council and local
cycling groups. The
Strategy’s aim is to identify
and develop a network of
cycle routes from origin to
core destinations. It will
provide more detail on the
Alter references to the Quality
Bus Corridor to include
information on cycle
improvements.
annotation on the ‘Town Centre
Key Diagram’ centred on the
area identified in Appendix 2.
Figure 3
Neighbourhood 1:
Town Centre - Key
Diagram
220c
Neighbourhood 1:
Town Centre
Summary of
Representation/Comment
Mr Barry
Cansfield
Figure 3
Neighbourhood 1:
Town Centre - Key
Diagram
Neighbourhood 2: Upperton
ID
No.
150
Section
Paragraph no.
and subject
Neighbourhood 2:
Upperton
73
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
safety measures proposed for
cycle routes, including the
shared cycle lane proposed
as part of the Quality Bus
Corridor.
Neighbourhood 3: Seaside
ID
No.
Section
Paragraph no.
and subject
Neighbourhood 3:
Seaside
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Loriston
Guesthouse
Query when implementation will
take place. Critical of the state
of pavements on St Aubyn's Rd
and untidy bins.
No change.
54
Neighbourhood 3:
Seaside
Miss Mandy
Lloyd
Will any extra parking be
considered for the existing
successful businesses?
55
Neighbourhood 3:
Seaside
Neighbourhood 3:
Seaside
Orion
Documents
Jay McNally
Bespoke
Looks superb, reminds us why
Eastbourne is the place to be.
Note cycle routes. New
developments need to include
The proposals in the Core
Strategy will be implemented
once the it is adopted which
is expected in October 2012.
Issues such as condition of
the pavements and bins will
be passed to the relevant
department.
The Council is currently
producing a Parking Strategy.
Consultants are reviewing the
parking provision within
Eastbourne, with the aim of
providing adequate parking
facilities for all. The Parking
Strategy will be out for
consultation in September
2011.
Support welcomed.
See response to 168 above in
Neighbourhood 13. A
No change.
53
152
No change.
No change.
74
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
provision for cyclists. The
seafront should be opened for
cycling. The Tesco roundabout
and the Seaside area is
dangerous. Signage would help
about crossing points.
Sustainable Building Design
SPD is currently being
written, which will include the
necessity for all new
development to provide
adequate facilities for
cyclists. The SPD will be out
for public consultation in
September/October 2011.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Martin Small
South Downs
Society
Support the intention set out in
the Vision of enhancing access to
the South Downs National Park
while preventing development on
the boundary.
Hope the strategy’s key area of
change in the Goffs includes
improving safety for cyclists.
With many schools nearby,
cycling provision around should
be improved
Support welcomed.
No change.
See response to 168 below in
Neighbourhood 13.
No change.
Summary of
Representation/Comment
Proposed Response
Recommended Change
Neighbourhood 4: Old Town
ID
No.
116
153
Section
Paragraph no.
and subject
Neighbourhood 4:
Old Town
Neighbourhood 4:
Old Town
Jay McNally
Bespoke
Neighbourhood 5: Ocklynge & Rodmill
ID
No.
Section
Paragraph no.
and subject
Respondent
75
ID
No.
48
154
Section
Paragraph no.
and subject
Neighbourhood 5:
Ocklynge & Rodmill
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mrs Janice
Vango
Support aim of promoting the
provision of safer walking and
cycling routes and bus/cycle
corridors. A dropped kerb from
Willingdon Road is preferable and
improvements to the safety of
the DGH roundabout and Cross
Levels Way roundabouts are
required. If Kings Drive is to go
ahead, cycling and walking
infrastructure should be provided
by the developers.
No change.
Neighbourhood 5:
Ocklynge & Rodmill
J McNally
(Bespoke)
Welcome changes to a bus/cycle
corridor if it is safe for cyclists.
Improvements are needed to
Kings Drive crossings and
signage. A cycle filter lane from
Rodmill Drive onto Kings Drive
Support welcomed. The
Eastbourne Plan provides a
strategic overview of the
aims for the Borough. More
in-depth detail about the
changes to cycle routes will
be covered in future
strategies such as the
Development Management
DPD, which provides more
detailed policies to guide the
decision making process for
future planning applications,
and Area Action Plans for
both the Town Centre and
the Seafront. The Council is
also currently working in
partnership with East Sussex
County Council and local
cycling groups to prepare a
Cycling Strategy which will
identify key routes and
networks across the Borough.
Developer contributions will
be sought for new
developments to provide
supporting infrastructure.
Support welcomed.
Improvements to existing
cycle routes such as those in
the vicinity of Kings Drive are
detailed in the Cycling
Strategy, which is currently
No change.
76
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
will increase safety. Developers
should pay for and install
infrastructure as part of a
development.
being jointly produced by
Eastbourne Borough Council,
East Sussex County Council
and local interest groups. A
number of infrastructure
requirements, including cycle
routes, will be delivered
through developer
contributions to ensure
development does not
proceed without the
necessary infrastructure for
the surrounding area. An
Infrastructure Delivery Plan
(IDP) has been prepared and
sets out the infrastructure
requirements in the Borough
and the mechanisms that will
used to secure funding for
them.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
J McNally
(Bespoke)
We welcome proposed cycle
route, especially around Stafford
School. A largely off-road link to
the town centre would be better.
Could railway land be used to
take bikes between station and
Roselands/Bridgemere -
Support welcomed. The
Council welcomes
suggestions for new cycle
routes across the Borough.
These suggestions will be put
forward to the officers
preparing the Cycling
No change.
Neighbourhood 6: Roselands & Bridgemere
ID
No.
155
Section
Paragraph no.
and subject
Neighbourhood 6:
Roselands &
Bridgemere
77
especially if some more monies
come from new housing
development?
Strategy. This document,
prepared in partnership with
East Sussex County Council
and local cycling groups, will
provide more in-depth
information on proposed
cycle routes across the
Borough. The Horsey Sewer
route, linking Langney
Roundabout to the Town
Centre, has been assessed as
the preferred option to link
Roselands to the Town Centre
and was supported by 90%
of respondents during the
consultation.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mrs M Hamilton
(Groves
Builders and
Contractors)
Hampden Park is diverse in
housing type but has a stigma
which is unjustified. The
Hydneye Estate has had a lot of
investment over the years,
revitalising and uplifting the
houses. The Borough should be
proud of it.
Comment acknowledged. The
Council recognises the
diverse range of housing
within Hampden Park. We
welcome and support the
investment in the Hyneye
Estate since its inception.
No change.
Jay McNally
(Bespoke)
We welcome proposed cycle
path. Existing paths needs better
signage, especially the link to
Hampden Park station. There is a
cycle bridge from Sainsbury’s to
Support welcomed. There is a
need to increase awareness
of existing cycle routes
throughout Eastbourne. This
will be addressed in the
No change.
Neighbourhood 7: Hampden Park
ID
No.
97
157
Section
Paragraph no.
and subject
Neighbourhood
7:Hampden Park
Neighbourhood
7:Hampden Park
78
ID
No.
181
Section
Paragraph no.
and subject
Neighbourhood
7:Hampden Park
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Hampden Park station which is
not used as it is not known.
Cycling Strategy being
produced by Eastbourne
Borough Council, East Sussex
County Council and local
cycling groups.
Support welcomed.
No change.
Mrs Sandy
Boyce-Sharpe
(Friends of
Hampden Park)
Welcome the protection of the
playing fields around the
colleges, including Martins field.
Would like to view proposals
when they are finalised. There is
currently discussion over plans to
renovate the BMX area.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
J McNally
(Bespoke)
We welcome the proposed cycle
route.
Support welcomed.
No change.
Jennifer Gane
Definitely like the idea of cycling
routes! There's not enough of
them in Eastbourne
Support welcomed. The
Council recognises the
positive contribution that
cycling can do to reduce
congestion, cut pollution, and
enhance the health and
quality of life of people living
in the Borough. The Council
is planning to increase the
number of cycle routes in
Eastbourne, with the
No change.
Neighbourhood 8: Langney
ID
No.
159
173
Section
Paragraph no.
and subject
Neighbourhood 8:
Langney
Neighbourhood 8:
Langney
79
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
intention of increasing the
proportion of people in the
Borough cycling to work or
for leisure purposes. The
Council is working in
partnership with East Sussex
County Council and local
cycling groups to prepare a
Cycling Strategy for
Eastbourne.
Neighbourhood 9: Shinewater & North Langney
ID
No.
160
Section
Paragraph no.
and subject
Neighbourhood 9:
Shinewater & North
Langney
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
J McNally
(Bespoke)
There are no planned cycle
facilities on the map, though
mentioned in the text. Some
routes and cycle parking would
open up this area. It should be
noted that in areas of
deprivation, cycling improves
employment opportunities
especially for young people or
those with low household
income.
Comment acknowledged. The
Council will promote the
development of a network of
safe walking and cycling
routes, especially where they
link existing residential areas
to employment areas and
offer the potential for modal
shift. This will help provide
cheaper alternative modes of
transport that will benefit all
members of the community,
including younger people and
low income households. The
neighbourhood diagram does
not currently include
potential cycle routes. The
Proposed cycle facilities to be
shown on Figure 11
Neighbourhood 9: Shinewater
& North Langney – Key
Diagram. This will illustrate
potential cycle routes through
the neighbourhood, as
demonstrated in other
neighbourhood diagrams.
80
diagram will be altered to
take this into account if
routes are known.
Neighbourhood 10: Summerdown & Saffrons
ID
No.
117
161
Section
Paragraph no.
and subject
Neighbourhood 10:
Summerdown &
Saffrons
Neighbourhood 10:
Summerdown &
Saffrons
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Martin Small
South Downs
Society
Welcome the aim incorporated in
the Vision of enhancing access to
the national park while
preventing inappropriate
development on the boundary of
the park. Endorse the
recognition in para. 3.11.6 of
opportunities that the park will
provide for the neighbourhood to
benefit from increased tourism.
Cycling is mentioned in text. This
area is currently dangerous for
cyclists and highly residential, so
cycle paths and parking are
needed
Support welcomed.
No change.
East Sussex County Council,
Eastbourne Borough Council
and local cycling groups are
jointly developing a Cycling
Strategy for Eastbourne that
will identify how cycling can
be made a more attractive
option for residents and
visitors.
No change.
Jay McNally
Bespoke
A key element of this is to
identify new, priority cycle
routes that will expand
Eastbourne’s existing cycling
network. The Strategy will
also determine where the
81
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
existing routes can be
improved by the addition or
upgrading of facilities and
infrastructure including the
provision of secure cycle
parking at key locations,
improved signage and
training for cyclists.
The extent to which the
Strategy is implemented will
be dependant on the levels
of funding that are available.
It is anticipated that the
Strategy will be published
towards the end of 2011.
Neighbourhood 11: Meads
ID
No.
118a
Section
Paragraph no.
and subject
Neighbourhood 11:
Meads
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
South Downs
Society
Support the aim set out in the
vision of defending existing
tourist accommodation from
losses and inappropriate
development. Welcome the aim
of enhancing access to the
national park while preventing
inappropriate development on
the park boundary.
Support welcomed.
Protecting existing tourism
accommodation is important
for the tourism industry to
ensure that there are enough
bed spaces for visitors.
Protecting the National Park
boundary and enhancing
access is also considered
No change
82
important for Eastbourne.
163
Neighbourhood 11:
Meads
J McNally
(Bespoke)
There are several areas (e.g.
around the schools) where traffic
could be made safer for cyclists.
Very few children currently cycle.
The seafront should be opened
for cycling.
Whilst the Core Strategy does
support and encourage an
increase in cycle routes and
facilities, the detail regarding
cycle facilities and routes will
be addressed through the
Cycling Strategy. Cycling
issues specific to the Town
Centre will be considered
through the Town Centre
Area Action Plan.
No change
52
Neighbourhood 11:
Meads
Ms Margaret
Lonsdale
I strongly support the proposed
cycle route
Support welcomed.
Encouraging cycling through
the provision of cycle routes
is important in promoting
healthy lifestyles and
reducing reliance on the car.
No change
South Downs
Society
We welcome the recognition in
para. 3.12.7 of the potential for
developing opportunities for
tourism in the national park and
the importance of protecting the
urban edge from development.
Support welcomed. The
National Park complements
the existing tourism offer in
the Town.
No change
Figure 13
Neighbourhood 11:
Meads - Key
Diagram
118b
Neighbourhood 11:
Meads
Para 3.12.7
Neighbourhood 12: Ratton & Willingdon Village
ID
No.
119
Section
Paragraph no.
and subject
Neighbourhood 12:
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Martin Small
Welcome the aim set out in the
Support welcomed.
No change.
83
167
Ratton & Willingdon
Village
South Downs
Society
Neighbourhood 12:
Ratton & Willingdon
Village
Jay McNally
Bespoke
neighbourhood vision of
enhancing access to the national
park and preventing
inappropriate development on
the park boundary
Clarification is needed that the
quality bus corridor includes
cyclists
The quality bus corridor will
provide priority bus
measures, together with
significant benefits to
pedestrian and cyclists.
Specific to cyclists are cycle
crossings and cycle lanes.
No change.
Proposed Response
Recommended Change
East Sussex County Council,
Eastbourne Borough Council
and local cycling groups are
jointly developing a Cycling
Strategy for Eastbourne that
will identify how cycling can
be made a more attractive
option for residents and
visitors.
No change.
Neighbourhood 13: St Anthony’s & Langney Point
ID
No.
168
Section
Paragraph no.
and subject
Neighbourhood
13:St Anthony’s &
Langney Point
Respondent
Summary of
Representation/Comment
Jay McNally
Bespoke
Note the key area of change
around sovereign centre. There
is a cycle path and a
cycle/walking underpass near
here which is not maintained or
signed and hope this will be
incorporated into the scheme.
Welcome the proposed cycle
path to the north of this area.
The short cycle path opposite
LIDL is dangerous
A key element of this is to
identify new, priority cycle
routes that will expand
Eastbourne’s existing cycling
network. The Strategy will
also determine where the
existing routes can be
84
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
improved by the addition or
upgrading of facilities and
infrastructure including the
provision of secure cycle
parking at key locations,
improved signage and
training for cyclists.
174
Neighbourhood
13:St Anthony’s &
Langney Point
Ms Viv Angus
Comments critical of the
development at Regency Park at
the edge of this area. Consider
inadequate spacing and space for
residents and visitors vehicles
and emergency vehicles.
The development at Regency
Park is typical of modern
developments where spacing
is less generous than in the
past in order to achieve
greater efficiency in the use
of land. All new development
is subject to the planning
application process, and each
scheme is assessed on
merits, in relation to its
location and current
standards for development.
No change.
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Sovereign
Harbour
Residents’
Association
Summary of Main Points made in
representations from
respondents :
The concerns are
No change.
Neighbourhood 14: Sovereign
ID
No.
Section
Paragraph no.
and subject
Neighbourhood 14:
Sovereign
• INAPPROPRIATE LEVEL OF
85
ID
No.
Respondent
Summary of
Representation/Comment
Proposed Response
3
Mr Reginald
Russell
8
Mr F McCormick
9
Mr Brian Burke
10
Mr John
Dickinson
HOUSING
Concern over the level of
housing proposed. The housing
densities proposed are in excess
of Government guidance. 150
dwellings is too much for
Sovereign Harbour.
Plan does not meet the
aspirations of the local
community, as reinforced by a
petition containing over 1,550
signatures.
acknowledged but it should
be noted that the proposed
150 dwellings at Sovereign
harbour will be a mix of
dwelling types and not
necessarily flats. This figure
is an indicative estimation of
capacity for the purposes of
assessing viability and is not
an ‘allocation’. All housing
proposals will need to be in
accordance with Proposed
Policy D5: Housing. Policy D5
requires proposals for
housing to “take appropriate
account of the need identified
in the most up-to-date
strategic housing market
assessment with particular
regard to size, type and
tenure of dwellings”.
Concern that there are already a
vast number of homes at
Sovereign Harbour, with scarcely
any community amenities for
existing residents. Building yet
more homes in this area before
the community infrastructure is
in place does not make any
sense.
An analysis of housing
densities shows that several
wards in the town including
Town Centre, Upperton,
Seaside, Old Town, and
Shinewater & Langney are all
more densely populated than
Sovereign. Furthermore,
PPS3 requires land to be used
efficiently and effectively.
Given the significant
11
12
15
Section
Paragraph no.
and subject
Margaret
Stanton
Mary Tobias
17
Mr John and
Isle Sadler
24
Edward &
Patricia McClung
25,
41
Ms Alison
Atwood
18
Guy Brewer
20
M West
23
Mr & Mrs Martell
27
Wendy Hack
28
Ross Jones
Recommended Change
No change
86
ID
No.
Section
Paragraph no.
and subject
Respondent
29
Mr Philip Barnes
30
Sandra
Cheesman
31
Michael
Wardroper
40
Mrs Lynne
Chiswick
42
45
67
68,
80
Mr & Mrs Roger
and Elizabeth
McGregor
Roger Kiernan
Mr Barry Wynn
Mr Bob Watts
75
Mr Ian Weeks
110
Mrs Jan Weeks
Mr Richard
Runnalls
Summary of
Representation/Comment
Proposed Response
Recommended Change
environmental constraints in
Eastbourne it is essential that
suitable housing sites are
developed in an effective and
efficient manner. The Council
recognises the vital need for
residential development to be
accompanied by the
necessary community
facilities.
• CONTRARY TO MOTION
PASSED STIPULATING NO
NEW RESIDENTIAL
DEVELOPMENT
It is stated that there are sites
available for housing
development, which is contrary
to previous agreement that there
would be no further development
in Sovereign Harbour as it is
already over developed for
housing when measured against
the original plan. Play areas,
community centre and a
business park should be
developed before any
consideration of housing.
The proposed policy does not
allow residential development
without appropriate
infrastructure. This will be
guaranteed through any
future planning permissions.
No change
• NOT BASED ON CREDIBLE
EVIDENCE BASE:
The spatial development
strategy was underpinned by
No change
87
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
The evidence on which the
strategy is based is, in part,
neither robust, nor credible.
Having chosen to take a
neighbourhood approach when
conducting the public
consultation, equal weight should
be given to the aspirations of
every neighbourhood in the LDF,
but results from Neighbourhood
14 were discounted. By
eliminating the Neighbourhood
14 results when creating the LDF
Core Spatial Development
Strategy, the very foundations
on which the LDF was built were
totally undermined, leaving it
likely to collapse on examination.
a very extensive consultation
exercise in December 2009.
The spatial development
options proposed were all
assessed and a Sustainability
Appraisal was undertaken.
• CONFORMITY WITH
GOVERNMENT POLICY:
The Plan does not conform to
Government Planning Policy
The Plan will not deliver a
sustainable community, as
defined by Policy B2
The strategy seeks to
improve the Sustainability of
communities and the
achievement will depend on
the detailed implementation
of a number of measures.
The success or otherwise of
these detailed measures will
be monitored regularly
throughout the period to
2027.
No change
The Council is committed to
No change
88
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
creating a sustainable centre
at Sovereign Harbour. There
are already a range of
services and facilities,
including a wide variety of
shops, a superstore, a multiscreen cinema, bars,
restaurants and a yacht club.
However, the Council also
acknowledges that the
neighbourhood suffers from a
lack of some community
facilities and is seeking to
address these key
deficiencies in order to create
a new vibrant sustainable
centre at Sovereign.
The strategy seeks to create
a sustainable centre at
Sovereign which should help
to reduce the need to travel.
The Council uses the adopted
East Sussex County Council
standards on the provision of
parking spaces and this is
currently under review which
may lead to amended
requirements for parking
spaces.
• FLOODING ISSUES
Insufficient attention has been
The Environment Agency has
not raised flooding as an
No change.
89
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
paid to flooding and flood risk
issues.
issue that would prevent the
levels of development
proposed.
• TOURISM ROLE
There has been an insufficient
acknowledgement of Sovereign
Harbour’s role as a tourist
attraction being one of the
largest sheltered marinas in
northern Europe.
Comment noted. The role of
Sovereign Harbour is
important to Eastbourne’s
overall tourism offer.
In para. 3.15.1,
“It is one of the largest
sheltered marinas in northern
Europe and functions as an
important tourist area within
the Borough. It is also home to
a population of approximately
7,000 people”.
• LACK OF COMMUNITY
FACILITIES
There is already an acute lack of
community facilities and there is
a particular need for additional
open space and a community
centre to serve the needs of the
local community.
The need for additional
community facilities in
Sovereign is recognised and
the Council continues to work
towards achieving this. The
spatial strategy of the Core
Strategy acknowledges this
and seeks to create one of
two sustainable centres in the
Borough at Sovereign (the
other being the Town
Centre). The proposed policy
No change
90
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
seeks to build on the existing
facilities, school and medical
centre. In order to facilitate
the creation of this
sustainable centre, a degree
of enabling development is
necessary to deliver the
facilities.
Open spaces and play spaces
are needed and the core
strategy identifies that this
will be provided through
enabling development.
• OVER-RELIANCE ON FLATS
The housing types being
proposed are inappropriate and
there is an over-reliance on flats.
The area is already saturated
with flats and simply does not
have the infrastructure for more
The concerns are
acknowledged but it should
be noted that the proposed
150 dwellings at Sovereign
harbour will be a mix of
dwelling types and not
necessarily flats.
No change
• PUBLIC TRANSPORT ISSUES
The quality of public transport in
Sovereign could be increased
through the provision of
improved bus routes connecting
different parts of the
neighbourhood. Although
The Council is working with
East Sussex County Council
and local bus operators to
increase and enhance the
level and frequency of bus
routes in order to better
connect Sovereign with the
No Change
91
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Sovereign already has a good
cycle network, there are
opportunities to increase
accessibility for cyclists and
improve connections within the
neighbourhood.
Proposed Response
Recommended Change
town centre and Eastbourne
railway station.
Local public transport is very
poor and it is not possible to
return from the town on a bus
after visiting to see an evening
show at the theatre. Would also
like to cycle into the town centre
without having to cycle along the
main road past parked cars and
in heavy traffic.
The Council is working in
partnership with East Sussex
County Council to deliver new
cycle routes in the Borough.
One of the proposed routes,
which is in an advanced state
of design, is the Horsey Cycle
Route.
No change, but see changes
proposed in response to
representations on Policy D8
Sustainable Travel.
• AFFORDABLE HOUSING
Concern over the proposed plans
to increase the already high
number of houses in Sovereign
Harbour. Appreciate the need for
affordable housing, but impact
on the current residences must
be considered, along with their
requirements for improvements
and sustainability in this
community.
The need for affordable
housing throughout
Eastbourne is particularly
acute and the number of
affordable housing
completions has consistently
fallen below the annualised
affordable housing target of
75 affordable dwellings per
annum established in the
current Borough Plan. It is
therefore imperative that the
Borough significantly
No change
92
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
increases the delivery of
affordable housing over the
course of the Core Strategy
period up to 2027 and all
areas of the Borough are
required to contribute to this
overall target.
• INCLUSION OF KINGSMERE
Concern about the inclusion of
Kingsmere into the same
neighbourhood as Sovereign
Harbour. Kingsmere and
Sovereign Harbour are poorly
related and bear little similarity.
It is important that the
neighbourhoods proposed
reflect public perceptions of
individual neighbourhoods. In
the case of the proposed
boundary for Sovereign,
there is a concern amongst
residents about the inclusion
of Kingsmere within the
boundary. It is therefore
proposed to amend the
boundary of Sovereign and
for Kingsmere to be added to
St Anthony’s and Langney
Point neighbourhood. The
new neighbourhood will be
called Sovereign Harbour to
avoid confusion with the
previous area and the
electoral ward.
Amend neighbourhood
boundary on the proposals map
to form a new Sovereign
Harbour neighbourhood and
include Kingsmere within St
Anthony’s and Langney Point
neighbourhood.
The Council is committed to
adopting a neighbourhood
approach to future
development in Eastbourne.
93
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
It is important that the
neighbourhoods proposed
reflect public perceptions of
individual neighbourhoods. It
is therefore proposed to
amend the boundary of
Sovereign and for Kingsmere
to be added to St Anthony’s
and Langney Point
neighbourhood. The new
neighbourhood will be called
Sovereign Harbour to avoid
confusion with the previous
area and the electoral ward.
The change in the boundary
to form the new Sovereign
Harbour neighbourhood does
not change its position in the
sustainability ranking of
neighbourhoods.
10
Neighbourhood 14:
Sovereign
Mr John
Dickinson
The absence of safe green play
zones causes community unrest
with children invading private
areas to use for safe play. Local
owners suffer from damage to
planting and potential vehicle
damage from items of play.
It is accepted that play
spaces are needed and the
core strategy identifies that
this will be provided through
enabling development
No change
1.3.6 Concern that the proposed
intent to restrict spaces to
typically one parking per unit will
The strategy seeks to create
a sustainable centre at
Sovereign which should help
No change
94
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
further increase on street
parking which has become an
increasing headache for
emergency vehicle access.
to reduce the need to travel.
The Council uses the adopted
East Sussex County Council
standards on the provision of
parking spaces and this is
currently under review which
may lead to amended
requirements for parking
spaces.
The strategy seeks to
improve the Sustainability of
communities and the
achievement will depend on
the detailed implementation
of a number of measures.
The success or otherwise of
these detailed measures will
be monitored regularly
throughout the period to
2027.
The Council is failing to deliver
sustainable communities and
high standards of design and
sustainable construction, and has
also failed in reducing the growth
in car-based travel and the need
to travel by promoting
alternative travel choices
including walking, cycling and
public transport.
Recommended Change
No change
Propose a non traffic route from
the harbour to the town centre
with secure cycle parking on the
edge of the town. There is space
for dual zone sharing safely
between pedestrians and
cyclists.
See response to
representations on cycling in
the Transport section.
No change
3.15.8 Concern at lack of
progress on the Science park and
community facilities
Concern noted. The
development of the science
park is a long term ambition
of the Council of achieving a
No change
95
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
quality development on the
site.
16
26
Neighbourhood 14:
Sovereign
Neighbourhood 14:
Sovereign
Mr Malcolm
Rasala
Mr Robert
Monks
3.15.9 The quality of public
transport in Sovereign could be
increased through the provision
of improved bus routes
connecting different parts of the
neighbourhood and there are
opportunities to increase
accessibility for cyclists.
(See response to general
points made above)
No change
SHRA do not represent possibly
the vast majority of residents at
Sovereign Harbour. Welcome
more development in Sovereign
Harbour North including more
shops and cafes. More homes will
create a more dynamic
community. Propose. Sovereign
Harbour North is an ideal
location for developing a high
tech/internet ideas/ start-up
park attracting talent to
Eastbourne and an ideal way to
turn the Harbour Area into the
Soho / Miami Beach of the south
coast.
(See response to general
points made above and ID
No. 203 below) It is agreed
there are already a range of
services and facilities and this
should be made clear, along
with the acknowledgement
that the neighbourhood
suffers from lack of some
community facilities and
these key deficiencies will be
addressed in order to create
a vibrant sustainable centre
at Sovereign, including
bringing forward the
employment sites.
Delete the final sentence of
paragraph 3.15.2 and replace
with a new sentence at the
beginning of para. 3.15.4
stating:
Generally in favour of the
proposals but would like to see
more detail added to protect the
area from over development.
The key areas of change are
broad locations where
development is proposed.
The precise detail and
“Sovereign benefits from a
wide range of services and
facilities including a large
superstore, retail park, multiscreen cinema, restaurants,
bars, cafes and a yacht club.
The neighbourhood does,
however, suffer from a lack of
certain types of facilities….
96
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
The key areas for change need to
more fully explained.
location of development is
yet to be decided. Master
planning work is currently
being undertaken and will be
publicly available shortly.
Local public transport is very
poor and it is not possible to
return from the town on a bus
after visiting to see an evening
show at the theatre. Would also
like to cycle into the town centre
without having to cycle along the
main road past parked cars and
in heavy traffic.
30
Neighbourhood 14:
Sovereign
Michael
Wardroper
Generally agree with the plans
for the North Harbour but with
the following comments: 1.
Emphasis should be placed on
providing the long overdue
infrastructure needed, such as
play areas, community centre
and much better public transport
Recommended Change
The Council is currently
working in partnership with
East Sussex County Council
and local bus operators to
deliver better, more frequent
and reliable services across
the Borough and beyond. In
addition, the Council is
currently developing a
Cycling Strategy in
partnership with East Sussex
County Council. One of the
routes is along the Horsey
Cycle Route provides a
continuous cycle route that
links Eastbourne railway
station with Langney
roundabout.
(See response to general
points above). The Council
has prepared an
Infrastructure Delivery Plan
(IDP) and this will accompany
the Core Strategy outlining
the key areas of
infrastructure needed across
No change
97
ID
No.
86
Section
Paragraph no.
and subject
Neighbourhood 14:
Sovereign
Respondent
Mr Jonathan
Stoddart
(Premier
Marinas)
Summary of
Representation/Comment
Proposed Response
Recommended Change
facilities before any further
residential development is
undertaken.
the Borough and the
mechanisms that will be
implemented to secure
funding for them.
2. An additional access road for
the North Harbour is needed
from Pevensey Bay Road which
would benefit those living on
Pacific Drive and provide an
alternative route for emergency
services.
The existing access road is
sufficient and has additional
capacity in it to cater for
additional development.
However, all new proposals
will be assessed carefully and
additional access roads may
be required if it is deemed
necessary.
No change
3. Assume that the designated
open space/play areas will be
appropriately landscaped. This
should be extended to include
the road verges and trees to
provide a more pleasant
environment.
Adequate landscaping and
provision of open spaces will
be an integral part of any
new development.
The third bullet point of the
Sovereign Vision will be deleted
and replaced with:
“Increasing the amount of
appropriately landscaped,
usable open space and the
number of children’s play
areas”.
Support the intention to focus
development at Sovereign
Harbour, but have concerns with
impact on the operations
associated with the Marina.
Although recognising the
importance of the Waterfront
area at Sovereign Harbour as a
The value of the Marina is
recognised as playing an
important role in
Eastbourne’s overall tourism
offer. It provides a unique
waterfront setting and a
variety of bars and
restaurants in an attractive
Add additional bullet point to
Sovereign harbour vision to
state:
“Enhance the importance of the
Marina for tourism through
appropriate measures including
the provisional of additional
berths”.
98
ID
No.
203
Section
Paragraph no.
and subject
Neighbourhood 14:
Sovereign
Respondent
Miss Charlotte
Handscomb
(DPP Planning)
Summary of
Representation/Comment
Proposed Response
leisure and tourist centre, there
is little reference to the marina
and its operations such as boat
storage and car parking. Such
land uses are integral to the
successful and efficient
operations of the Marina. The
Proposed Core Strategy does not
fully take into account the needs
and requirements of the role of
the Marina in the wider
community and facilities and
employment that it provides. The
proposals for the Sovereign area
should be reconsidered in order
to ensure that sufficient land is
safeguarded for uses associated
with the Marina operations. Seek
clarity as to the where new
housing development will be
located.
environment that benefits
residents and visitors to the
area. It also provides the
focus for a number of
marina-based activities and is
a valuable asset to the
Borough.
Content with the Key Diagram
for Sovereign, but disagree with
the statement that the
neighbourhood suffers from a
lack of services and facilities and
the low sustainability ranking for
the area within Table 4.
Sovereign Harbour has a breadth
and depth of services and
facilities including: a primary
school; doctors' surgery (soon to
The sustainability ranking of
the neighbourhoods has been
carried out on a consistent
basis throughout the Borough
so as identify which areas are
the most in need of additional
facilities. Sovereign has been
assessed low in sustainability
in Table 4 due to the lack of
community facilities, usable
open space and children’s
Recommended Change
No change
99
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
be replaced by a new purpose
built medical centre); dentists; a
range of small offices and shops;
leisure facilities and attractions;
the beach which provides an
extensive stretch of public open
space; and employment
opportunities arising from these
directly. The area is also served
by local buses. Drainage and
flood issues are managed
through existing flood defences.
It would benefit from a
community hall and grassed
open space and other
infrastructure which is being
addressed within a master plan
for the remaining development
sites. Sovereign neighbourhood's
ranking of 12th place out of 14 is
misrepresentative and
inconsistent, failing to take
account of the facilities offered
here, or the lack of facilities in
other neighbourhoods, some of
which rely on facilities in
adjoining neighbourhoods.
play areas, limited access to
public transport and lack of
local employment
opportunities, all of which the
Plan seeks to tackle.
Within the Sovereign Vision at
page 61 and the supporting text
on page 62, the allocated
employment land is referred to
as a Science Park. However
Agree that there should be
consistency.
Recommended Change
Amend references to ‘Science
Park’ to ‘Business Park (B1
Office)’.
100
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
within Policy D2: Economy and
the supporting text to that on
page 70 it is referred to as B1
(a) office use. Suggest that
reference to general B1 park is
the most appropriate and most
readily deliverable for
Eastbourne. This wording also
allows for flexibility in the future
marketing of the site, and
occupancy.
170
Neighbourhood 14:
Sovereign
J McNally
(Bespoke)
The current cycle path through
the marina stops and starts and
is on pavements and is not
useable. Hope that better cycle
paths and parking will be
included in development.
It is anticipated that the
proposed new development
at Sovereign Harbour will
facilitate the completion of
these important cycle routes.
No change
179
Neighbourhood 14:
Sovereign
Christine
Purkess
(Eastbourne &
District
Chamber of
Commerce)
Have serious concerns regarding
proposals for additional
residential development
(including affordable housing).
Affordable housing is likely to
include flats, but the Harbour is
already over developed with
them, many of which are
currently available for sale or
rent. This is having an affect on
property values in the harbour,
which have dropped significantly
in comparison to the rest of
Eastbourne. It is difficult to
(See response to general
comments above). The
proposal to include 150
additional dwellings is
necessary not only to deliver
the necessary new dwellings
required between 2006 and
2027, but also to help
facilitate the deliver of vital
community infrastructure
needs identified at Sovereign
Harbour.
The potential effect of
development proposals on
No change
101
ID
No.
242
Section
Paragraph no.
and subject
Neighbourhood 14:
Sovereign
Respondent
Michael Morland
Summary of
Representation/Comment
Proposed Response
attract quality staff to the town if
property residual values are not
attractive. Agree there is great
need for community facilities.
The statement that more
residential development will
provide a community
infrastructure makes no sense at
all.
property values is not a valid
planning concern. There is an
acute need for additional
affordable housing
throughout the Borough and
sufficient affordable housing
has not been delivered in
recent years. It is therefore
essential that all parts of the
Borough provide affordable
housing to help meet this
need.
The lack of community
infrastructure has been
recognised and this was one
of the key reasons proposed
policy does not allow
residential development
without appropriate
infrastructure. This will be
guaranteed through future
planning permissions
Concern that the proposal is
contrary to a “formal declaration”
that no new residential would be
built in Sovereign Harbour due to
complete neglect of the provision
of “social infrastructure” since
the inception of development.
Concern raised that the
Sovereign Harbour Residents’
Association has not been
sufficiently engaged by the
Council in the overall
consultation process.
The Sovereign Harbour
Residents Association has
been engaged and has
provided a valuable input into
the Eastbourne Plan
throughout the consultation
process. At a wider level, the
spatial development strategy
was underpinned by a very
extensive consultation and
Recommended Change
No change
No change
102
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
the Council recognise the
important role that the SHRA
and other local community
organisations can play in
Concern raised about the Topic
papers which were formulated 4
years ago and are out-of-date.
Some of the topic papers are
a few years old. However
where necessary and to
ensure a robust and up-todate evidence base, these
have been or are in the
process of being updated.
No change
Concerns are raised about the
ability of sea defences to cope
with the threat of flooding given
Sovereign Harbour’s position
within a flood plain. It is
Eastbourne Borough Council’s
responsibility to assure all
residents that they will be
protected.
The Environment Agency has
not raised flooding as an
issue that would prevent the
levels of development
proposed in the Eastbourne
Plan. Eastbourne Borough
Council has submitted its
Sequential and Exception
Test to the Environment
Agency as required by advice
contained within PPS25:
Development & Flood Risk.
No change
The Council recognises that
there is a deficiency in
certain types of community
facilities. The Eastbourne
Plan seeks to create one of
two sustainable centres at
Sovereign (Harbour). The
No change
Objection to Housing led
development. The Council
proposes a further 150 dwellings
in order to support the social
infrastructure provisions. This is
unacceptable.
No change
103
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
proposed policy builds on
existing facilities and
identifies additional
community facilities such as a
community centre, additional
open space and children’s
play facilities, which will be
provided through enabling
development
Concern that the Eastbourne
Plan only plans up to 15 years. It
should plan up to 25 years
The Council has a
requirement to identify
sufficient development land
for 15 years from the point of
adoption. Following adoption,
the Council will continue to
monitor and review the plan
over its lifetime.
No change
Identify the true value of
Sovereign Harbour as a principle
tourist hub which will positively
aid investment.
Comment noted. The hotel
and accommodation study
said there was no interest in
providing a hotel there, but
did think there was a possible
market for additional high
quality holiday apartments.
See change made on page 90
of Consultation Report in
response to several
respondents.
The value of Sovereign
Harbour is recognised as
playing an important role in
Eastbourne’s overall tourism
offer. It provides a unique
waterfront setting and a
See change made on page 98
of the Consultation Report in
response to Respondent ID no:
86.
104
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
variety of bars and
restaurants in an attractive
environment that benefits
residents and visitors to the
area. It also provides the
focus for a number of
marina-based activities and is
a valuable asset to the
Borough.
Part D: Delivering the Strategy
Policy D1: Sustainable Development
ID
No.
90
101
Section
Paragraph no.
and subject
D1: Sustainable
Development
D1: Sustainable
Development
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Graham ArrJones
East Sussex
County Council
Strongly agree that new
development must ensure good
connections to public transport,
community facilities and services
through good walking and cycle
routes
Suggest some reference to the
transport impact on CO2 over a
buildings lifetime is taken into
account when policy is finalised
Support welcomed.
No change.
The transport impact on CO2
over a buildings lifetime is
extremely difficult
information to collate. The
Core Strategy Policy and the
Sustainable Design SPD are
No change.
Derek Coffee
Campaign for
Better
Transport
105
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
126
D1: Sustainable
Development
Hannah Mears
Environment
Agency
Support the commitment to
sustainable development
throughout the Core Strategy,
and particularly the measures set
out in this policy
72
D1: Sustainable
Development
The CoOperative
Group
The policy requires that nonresidential development achieves
a 15% reduction in residual CO2
emissions and where this is not
possible a specified payment is
required to a Carbon Buyout
Fund. The policy should
incorporate the flexibility for
justification to be provided where
this is not viable, to ensure that
the policy requirements do not
prohibit development.
204
D1: Sustainable
Development
DPP
Achieving a 15% reduction in
CO2 after building regulations is
now obsolete as B regs require a
44% reduction. Query over the
effectiveness of a Carbon Buyout
Proposed Response
advocating measures to
reduce the use of the car,
and to encourage greener
forms of transport such as
walking and cycling, in order
to reduce CO2 emissions.
Support Welcomed. It is
important not only to set the
CSH Level 4 Standard, but to
re-iterate in the policy text,
the importance of saving
water.
This requirement will be
removed from Policy D1, as
an analysis of the
implications of the policy
renders its implementation
extremely difficult, in terms
of ensuring compliance with
the 15% target. CSH Level 4
has been set, in line with the
Building Regulations
requirements for residual
CO2 reduction, to set a
realistic and implementable
target.
See response to 72 above.
The Environment Agency has
shown support for the
inclusion of the water
reduction target wording, in
Recommended Change
No change.
In Policy D1: Sustainable
Development, remove
“Residential and nonresidential should either:
Achieve a 15% reduction in
residual CO2 emissions after
Building Regulations Part L
compliance has been
demonstrated; or be subject to
a payment into a Carbon
Buyout Fund, charged at £100
per tonne of CO2 per building
emitted over a 30 year period
(or one-off payment of £3000
per tonne of CO2 per
building).’
See change proposed in
response to 72 above.
106
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Fund. References to waste and
water reduction are covered in
CSH and BREEAM, so
recommend this reference be
deleted.
order to highlight the
importance water saving in
the Borough, as Eastbourne
is in an area of water stress.
With regards to waste
reduction, it is a key ambition
of the Council’s to reduce
waste, so for the same
reason, it is felt important to
emphasise this.
Sustainability underpins
current Government thinking.
Planning Policy Statement 1:
Delivering Sustainable
Development focuses on
delivering sustainable
development through the
planning system, to ensure
that resources are used
carefully and to plan for now
and for future generations. It
is a European requirement
under the Strategic
Environmental Assessment
Directive and Sustainability
Assessment Guidance to
assess all policies and plans
to ensure that they are
sustainable. It is important to
address these issues on a
local level.
The wording changes are
generally minor and do not
188
D1: Sustainable
Development
J A Williams
Comment on section on
Sustainable Development
regarding its relevance.
196
D1: Sustainable
Development
Mr D Read
Request word changes to policy:
– ‘Utilise sustainable construction
Recommended Change
No change.
See change proposed in
response to 72 above.
107
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
techniques;’
– ‘Be easily accessible to all
users;
- ‘Ensure good connections to
public transport , community
facilities and services; and
– ‘Reduce the opportunities for
crime and the fear of crime.’
improve the clarity of the
policy and are therefore not
agreed. The inclusion of a
caveat about viability and
feasibility is unnecessary as
such considerations would
always be part of the
assessment process. The
Council is producing a
Sustainable Building Design
SPD, where the more
intricate issues of sustainable
development will be
addressed.
(See also response to 72
above).
Also propose the insertion of the
words ‘where viable and
feasible,’ in relation to
sustainable building design
features.
Recommended Change
Policy D2: Economy
ID
No.
13
Section
Paragraph
no. and
subject
Policy D2:
Economy
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Wayne
Godden
Eastbourne's population has grown
substantially over the last 20 years,
largely by means of adding huge
housing association estates to the area.
What substantial commerce the town
had left in the 80's has since moved
away from this area, leaving a larger
working population than Eastbourne
can sustain. Huge volumes of road and
rail traffic leave and return to this town
The Council jointly
commissioned with East
Sussex County Council and
Wealden District Council a
Transport Assessment
(SWETS Study) which looked
at the transport implications
of the proposed level of
housing and economic growth
in both Eastbourne and South
No Change
108
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
on a daily basis. The key to "Business
Development" is transport
infrastructure and the lack of it for
Eastbourne.
Wealden to influence and
justify the policy approach.
The study comprehensively
assessed and reviewed all
transport routes into and out
of Eastbourne and concluded
that no major infrastructural
improvements were required
in terms of new roads within
the Borough, but significant
investment was required just
outside the Borough’s
boundary in South Wealden,
in particular it highlighted the
requirement to deliver the
Folkington link A27 road.
The demographic profile, with
a higher than national
average elderly population is
fully acknowledged. However,
the Council is keen to
encourage younger
generations and families to
either stay or live in the town
to improve the vibrancy of
the Borough and provide a
valuable local economic
workforce.
Birdseye, AXA PPP, countless
pharmaceutical companies and others
have relocated because of poor
transport links. This leave Eastbourne
with a continuous insurgence of ageing
population who add little to the towns
growth or development, Eastbourne's
retail experience were far superior 2025 years ago, with far greater variation
than it is now.
102
Policy D2:
Economy
Mr. Derrick
Coffee
East Sussex
B1 (a) office use at Sovereign Harbour
will create a demand for transport.
Sustainable transport links will have to
All new development will
create a certain level of
demand for new transport.
Recommended Change
No change
109
ID
No.
205
Section
Paragraph
no. and
subject
Policy D2:
Economy
Respondent
Summary of
Representation/Comment
Proposed Response
Transport 2000
be defined at an early stage. We believe
that the town centre is preferable as a
location and note that currently there is
vacant office space.
The need to improve
sustainable transport links
within the Sovereign
neighbourhood is addressed
in the Sovereign
neighbourhood section. This
states the need for
‘enhancing the provision of
cycle and walking routes to
improve connections within
the neighbourhood and to
other parts of the town’.
The development of new
office space is supported
within the Core Strategy and
will be detailed in the
emerging Town Centre Area
Action Plan (AAP).
Miss Charlotte
Handscomb (DPP
Planning)
Support this policy’s focus on enhancing
and supporting the economic prosperity
of Eastbourne and the general support
of local jobs. The language used
throughout the Core Strategy must be
consistent, and the allocated
employment land within Sovereign
Harbour should be referred to
consistently as for use class B1 which
can be appropriately located alongside
existing residential properties and in
order to provide flexibility of occupancy
across the Use Class B1 sub-categories.
It is agreed that there should
be a consistent approach
used throughout the Core
Strategy as to the allocation
of the Sovereign Harbour site
for B1 business use. It is
agreed that new business
space in the Town Centre
should be referred to first in
‘Policy D2: Economy’ to
support the sequential
approach to locating office
development in the core and
Recommended Change
(See response to 203 above.)
Change order of bullet-points 5
and 6 in ‘Policy D2: Economy’
to read as follows:
• Supporting the development
land within the town centre
for new B1(a) office use
through the Town Centre
Area Action Plan (AAP);
• Supporting the development
of B1 (a) office use at
Sovereign Harbour.
110
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Sovereign Harbour is most
appropriately marketed for general high
quality office space. The town centre as
a location for offices should be listed
first within the bullet points within
Policy D2, before reference to
Sovereign Harbour.
most sustainable location.
For consistency the use of
‘allocation’ should be
removed and land be defined
as being ‘supported’ for
development.
The potential for EBC to establish time
limited special development zones or
special planning orders in appropriate
circumstances should therefore be
explored for inclusion in the Strategy.
176
Policy D2:
Economy
Christine
Purkess,
Chamber of
Commerce
There is too much concentration on the
existing economic sectors and
insufficient aspiration and ambition with
regard to a changing economy,
infrastructure development and
attraction of new and different
industries which would provide higher
skill and higher wage opportunities.
Science Park gives the wrong image
and should be renamed; Technology,
Innovation or even Business Park are
all far more suitable titles than
‘science’.
There is too much reliance being put on
the possible development of a science
Recommended Change
The Council is not at this
stage considering special
development zones or special
planning orders for reference
within the Core Strategy.
It is recognised that
significant investment will be
required in order to deliver
viable office accommodation
at this location, and
improvements will need to be
made to infrastructure within
the neighbourhood in order
to support the new
development.
The delivery of new office
accommodation at Sovereign
harbour is one of the
Council’s key corporate aims
and objectives. The policy
itself does not specifically
No Change
See change proposed in
response to 203 above.
111
ID
No.
180b
Section
Paragraph
no. and
subject
Policy D2:
Economy
Para 4.2.15
189
Policy D2:
Economy
Paras 4.2.2,
4.2.4, 4.2.5
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
park; more thought needs to be given
to attracting different skills to the
areas. Is Sovereign Harbour the right
location (congestion, lack of transport
infrastructure) as it conflicts with the
identification of Eastbourne/Hailsham
triangle for strategic growth?
refer to a science park, but in
fact to ‘supporting the
development of B1 (a) office
use at Sovereign Harbour.’
Christine
Purkess,
Chamber of
Commerce
Support the allocation of land in the
Town Centre for new office
development.
Support Welcomed.
No Change
J A Williams
The Economy section highlights (para.
4.2.2) that business creation and
inward migration of businesses has
been low and compounds this (para.
4.2.4) with the Employment Land
Review, which identified issues with the
location of Eastbourne in relation to
This relates to the evidence
base which underpins the
planning policy decisions that
have been made in the
formulation of the policy on
the economy. It is recognised
that the Eastbourne-Hailsham
No Change
The Borough generally has
limited choices as to the
location of future business
and employment land due to
its tight urban confinement
and environmental
constraints on Greenfield
sites. It is therefore
important to maximise the
potential in existing industrial
estates, and to support new
developments at Sovereign
Harbour and within the Town
Centre.
112
ID
No.
Section
Paragraph
no. and
subject
Respondent
Para 4.2.6
134
Policy D2:
Economy
Howard Moore
Summary of
Representation/Comment
Proposed Response
potential markets, such as the
disadvantages posed by exiting road
and rail links as well as a 'lack of
dynamism' in the local economy. Since
the ELR in 2008, the Strategic Flood
Risk Assessment (4.2.5) has clarified
the areas at risk of flooding, which has
meant that a large amount of
previously allocated employment land is
no longer viable for development.
Triangle Economic Blueprint
Report and its objectives are
generally aspirational and
greater weight should
therefore be afforded to the
Council’s LDF evidence base.
The policy recommendations
are based on this evidence
base, most notably the
Employment Land Review.
Some previously identified employment
sites are considered to be of poor
quality and/or viability, or are in
locations where residential use is more
appropriate. The prospects of growth
through commercial development
appear limited.
The Council appreciates that
the delivery of new
employment land within the
Borough will be challenging,
therefore is looking at ways
of funding and improving the
development viability of sites.
Note that there is no reference to
transport within this section. Would
look for the transport impacts from the
proposed 23,000 m² intensification of
the Birch Road Industrial Estate to be
mitigated by sustainable transport
measures to reduce generation of
private car trips.
The transport implications of
the proposed strategy
including the level of
residential and employment
growth and their locations
have been assessed in the
South Wealden and
Eastbourne Transport Study
(SWETS). This identified the
need for small scale
improvements to the
transport network. These are
detailed in the accompanying
Recommended Change
No Change
113
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Infrastructure Delivery Plan
(IDP).
The transport section of the
Core Strategy ‘Policy D8:
Sustainable Travel’ provides
detail on the ways in which
new development should
promote sustainable modes
of travel. This would be
expected for any applications
for new intensified
development within existing
industrial estates.
214
Policy D2:
Economy
Royal Mail
Support the aim of encouraging job
growth and economic prosperity and
the approach to maximising the use of
existing employment sites, through
redevelopment and increased density of
existing industrial estates, and the
upgrading of the existing stock. Support
the last bullet point in Policy D2, which
provides flexibility to allow employment
sites to come forward for
redevelopment should they no longer
be viable or suitable for employment
use.
Support welcomed
No Change
241
Policy D2:
Economy
Wealden District
Council
Welcome the proposed allocation of
employment opportunity sites and note
that the plan shows 4 employment
Support welcomed. Further
testing of the financial
viability of the employment
Revisions are being made to
the Policy on the Economy in
terms of the sites that are
114
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
opportunity locations, providing a total
of 57,750 sq m of new employment
space.
sites has been undertaken
resulting in previously
identified sites not being
viable for redevelopment. A
revision to the policy will be
required to identify new land
for redevelopment and this is
being undertaken during the
general revisions to the Core
Strategy.
identified to meet the
requirement in the spatial
development strategy. This
work will be undertaken during
the same time period when
general revisions will be made
to the Core Strategy. The
proposed changes include the
deletion of Highfield North
Industrial Estate as an area of
densification and the proposed
inclusion of:
Welcome the provision of employment
opportunity sites to provide local
employment and support the ambitions
regarding employment and the focus on
'attracting higher skilled types of
employment and 'creating a new
economic image for Eastbourne''
Further testing of the viability and
deliverability of the employment
opportunity sites and evidence to
support this including the policy
consideration of a wider range of
possible employment uses e.g. relating
to high tech or innovation being
appropriate on the identified (science
park) sites.
Greater explanation of the reduction in
the supply of employment land is
required from the original ELR report to
more closely align with the Strategy
now proposed.
The justification for a reduced
requirement of employment
land compared to the original
Employment Land Review
recommendations is provided
in the ELR Addendum 2010.
It is based on the latest
workforce projections and the
fact that a step-change in
economic growth, anticipated
by consultants who
undertook the original ELR, is
now considered
undeliverable.
(i)
densification of land
within Brampton Road
Industrial Estate;
(ii) densification of sites
within Hammonds Drive
Industrial Estate; and
(iii) Town Centre
redevelopment
opportunities.
Policy D3: Tourism & Culture
115
ID
No.
Section
Paragraph no.
and subject
Policy
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Ian King
Support the Plan as a frame
work for the future. There is an
urgent need for an iconic building
to provide a nationally known
Eastbourne landmark that would
'announce' Eastbourne - as the
place you must visit - Suggest
achieving this by the
redevelopment of the Wish
Tower restaurant and
surrounding site to produce a
striking contemporary building
containing uses of attraction to
tourism and local business. This
would complement the heritage
of good architecture from the
18th/19th century that today
makes Eastbourne so unique.
Support welcomed. The
redevelopment of the Wish
Tower restaurant to provide a
facility which will be an
attraction for visitors and
enhance the character and
appearance of this part of the
seafront is current Council
policy and this is included in
the last bullet point of the
policy. A Planning Advice
Note was produced in 2009
to provide further guidance
on this but current economic
conditions have not been
favourable for progress on
this however.
No change
108
Policy and para.
4.3.1
Miss Rose
Freeman,
The Theatres
Trust
Support Policy D3 and note Key
Spatial Objective 6 for
Community Health which will
ensure adequate provision of
cultural facilities. Pleased to see
support for cultural and tourism
attractions.
Support welcomed.
No change
103
Para 4.3.5
Mr Derrick
Coffee
East Sussex
Transport 2000
The South Downs National Park
(SDNP) will be a valuable visitor
and recreation asset. To help
protect and to enhance this and
other areas of high landscape
and ecological value, suggest
Agree that sustainable
transport is important and
this will be promoted
throughout Eastbourne by
policy D8. A change is
proposed to para. 4.3.5 in
No change, but see change to
paragraph proposed in
response to 123 in the
Sustainable Transport section.
Comments will also be passed
on to SDNPA.
14A
116
ID
No.
120
79
Section
Paragraph no.
and subject
Para 4.3.5
Respondent
South Downs
Society
Mr Mark
Dickman
Summary of
Representation/Comment
Proposed Response
that development and promotion
of sustainable transport should
be a high priority. Consistency
in tourist guides in promoting
sustainable access is essential
and currently lacking. Liaison
with SDNPA is essential.
the Sustainable Travel
section. The SDNPA will be
producing their own Core
Strategy which is where the
transport needs specific to
the Park will be dealt with,
and there will be close liaison
between the two authorities
on its production. These
comments will be passed on
to SDNPA.
Support welcomed
Reference to the recent
designation of the national park,
is welcome, as is the
commitment to protect the park
against development and the
recognition in this respect of the
Borough Councils key role as
landowner. Also welcome the
policy which recognises the value
of the national park as a visitor
and recreation asset, and the
commitment to work with the
National Park Authority.
Policy D3 puts emphasis on
provision for the tourist:
accommodation & entertainment,
but overlooks enriching the lives
of those residing & working in
the town. Eastbourne has
excellent venues for performance
& some brilliant individual events
(e.g. Airbourne/Tennis week) but
The Council is currently
developing a Cultural
Development Framework
which will address many of
the points made and which
will aim to draw together the
activities of the various local
cultural groups. It would be
helpful to include reference to
Recommended Change
No change, but see change to
paragraph proposed in
response to 123 in the
Sustainable Transport section,
and response to 103 above.
Insert new paragraph 4.3.10 to
read: “A Cultural Development
Framework is being (has
been1)prepared focusing on
how the Council can continue
to support the many groups,
clubs, societies, organisations
and companies that deliver
cultural activity, in its widest
117
ID
No.
177
Section
Paragraph no.
and subject
Respondent
Christine
Purkess
Chamber of
Commerce
Summary of
Representation/Comment
Proposed Response
Recommended Change
it lacks a professional approach
in terms of town-wide arts
planning & strategy. The council
should actively support local
cultural groups and residents
should be actively encouraged to
get involved in arts/culture. More
investment needed into the
theatres and the bandstand.
There should be an emphasis on
delivering high quality arts
projects, such as more highquality music making, rather
than "entertainment".
this in the Strategy. Policy D3
supports the retention and
enhancement of existing
cultural facilities and resists
changes which would lead to
any downgrading, and also
supports new cultural
facilities. The Town Centre
Area Action Plan and the
proposed Seafront Area
Action Plan will be able to
provide more detail on future
land uses and policies for the
benefit of the town’s
residents as well as visitors.
sense, in Eastbourne. The
framework covers issues such
as Young People; Sport &
Leisure; Events and animation
of public spaces; Cultural
Industries and providing a
support network for artists,
creative practitioners and those
working in related cultural
services such as sports,
leisure, hospitality, learning
and enterprise.”
The production of a Seafront
Area Action plan should include
the sea, as there is considerable
scope for waterborne activities.
Eastbourne has virtually nothing
to offer.
Agreed. The Seafront Area
Action Plan will consider with
all elements of the seafront
including the need and scope
for capitalising on the
immense asset provided by
the sea itself both for passive
and active recreation.
No change
More must be offered to
encourage the day visitor to both
the town and the surrounding
area (including the National
Park) and create greater
sustainability to the tourism
industry. One area for possible
The need for additional
activities for the day visitor is
accepted but is outside the
scope of the Core Strategy.
Future proposals for
Eastbourne Park including the
potential for a visitor centre
No change
1
(The Cultural Framework will
be published for review during
May and June )
118
ID
No.
190
Section
Paragraph no.
and subject
Section 4.3
Respondent
Mr J A Williams
Summary of
Representation/Comment
Proposed Response
Recommended Change
promotion is the history of the
town. The bronze age settlement
in the Eastbourne Park area may
offer a starting point with scope
to recreate the various stages of
Eastbourne’s development such
as at the Jorvik Centre in York.
to promote the area, will be
dealt with in the Eastbourne
Park Supplementary Planning
document which will be
published for public
consultation later this year.
There is a huge cultural resource
but inadequate awareness / PR /
publicity of the town itself.
Suggest a section on how to
raise the profile to differing
audiences.
Lack of comment on how to get
more visitors to Eastbourne
outside the peak summer
months.
See response to rep 79
above.
See proposed addition on the
Cultural Strategy proposed in
response to 79 above.
The Core Strategy is
concerned with land use and
spatial planning rather than
promotion. The aim is to
make provision for the
retention of important asset
and encouragement of new
facilities which will enhance
what is currently provided.
No change but comments will
be forwarded to the Councils
Tourism Department.
Policy D4: Shopping
ID
No.
91
Section
Paragraph no.
and subject
D4: Shopping
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Graham ArrJones
East Sussex
County Council
Pleased to note that new retail
development at existing out-ofcentre sites will be supported
only if they are accessible by a
Support welcomed.
No change.
119
73
D4: Shopping
The CoOperative
Group
84f
84g
D4: Shopping
Barry Cansfield
206
D4: Shopping
DPP
147
D4: Shopping
Johnston Press
195
D4: Shopping
Angela Boas
choice of transport means
The policy should include the
flexibility to allow the subdivision
or change of use of larger units
where appropriate, to ensure
that sites do not remain vacant.
Recommend amendment to
policy: a new bullet point:
Promoting Site SA1 for additional
retail floorspace. Plus an
additional sentence at the end of
paragraph 4.4.2: Priority will be
given to Site SA1 to
accommodate the necessary
additional retail floorspace to
strengthen Eastbourne Town
Centre role as a leading subregional shopping destination.
Support the allocation of
Sovereign Harbour as a District
Shopping Centre. The role of the
Waterfront as the core focus for
small retail units, cafes, bars and
restaurants should be
emphasised.
Support the aspiration to
enhance the role of the Town
Centre and ensure provision of a
wide range of shops to serve the
local community.
At present Brighton or Tunbridge
Wells are preferred locations for
shopping but if the retail
The Shopping Assessment,
carried out in 2010
recommended that larger
retail units, specifically in the
primary shopping frontages,
should be protected from
sub-division or change of
use.
The Council commissioned a
Shopping Assessment in
2010, carried out by
specialist retail consultants.
The policy wording has been
recommended and evidenced
by them; therefore no policy
wording changes are
justified.
No change.
Support welcomed.
No change.
Support welcomed.
No change.
The Town Centre Area Action
Plan (AAP), aims to improve
the retail offer within
No change.
No change.
120
opportunities improved in
Eastbourne, would stay here.
191
D4: Shopping
J A Williams
135
D4: Shopping
Howard Moore
138
D4: Shopping
Mr D Read
The section fails to focus on what
attracts retailers to invest in the
Town Centres and how
Eastbourne will provide the
conditions to cause the multiple
retailers to want to invest.
Support policy. Development of
the Town Centre and enhancing
local shopping facilities could
reduce the need for long distance
trips which have an impact on
the Strategic Road Network.
Suggest reconsideration of retail
policies to develop a coherent
strategy to reverse the decline of
local shopping centres. Local
centres offer convenience to
shoppers; allow shopping trips to
be made by environmentally
Eastbourne, making the town
a major retail shopping
destination. This will be
achieved through
improvements to key
character areas of the town,
specifically though public
realm improvements and
making the separate key
areas of the town centre
better connected and
interlinked. This in turn will
make the Town Centre more
attractive to retailers, which
will result in a better retail
offer to Eastbourne residents
and visitors alike.
See response to 195 above.
No change.
Support welcomed.
No change.
Paragraph 10 of PPS4:
Planning for Sustainable
Economic Growth seeks to
“promote the vitality and
viability of town and other
centres as important places
for communities”. The
No change.
121
240
D4: Shopping
Wealden District
Council
friendly means, such as on foot,
by cycle or bus, and reduce long
car journeys and congestion.
importance of Local Centres
is recognised, and will be
protected within the retail
hierarchy.
Welcome the increased provision
of retail space within the town
centre New employment
opportunities will arise through
this and through the proposed
cultural and tourism opportunity
sites. More emphasis could be
given to the wider employment
opportunities that these will
provide and their contribution to
the local and wider economy.
Support Welcomed.
No change.
Policy D5: Housing
ID
No.
6a
Section
Paragraph
no. and
subject
Policy D5:
Housing
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Amanda Steer
Query how windfall numbers are worked
out. It said 0 spaces available but 24
windfall expected in St Anthony’s and
Langney Point and yet only a few windfall
expected in Sovereign Harbour. I thought
perhaps those figures had been reversed
as surely empty properties are always
occurring in Sovereign Harbour?
Windfall development
consists of sites and
properties that come forward
for residential development
which were not identified for
development through
planning policy. Bringing back
into use empty residential
properties do not count
towards housing supply, as
they already are technically
No Change
122
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
residential units (just not
occupied). Only if they are
redeveloped for a net gain in
residential units (i.e. Convert
1 empty house into 2 flats)
can they count towards net
housing units.
Windfall units are low in
Sovereign Harbour because
land for development can be
identified in that
neighbourhood, and the
existing housing stock is
unlikely to be redeveloped or
converted into smaller units.
They are higher in other
neighbourhoods such at St
Anthony’s because housing
units are generally older,
some on larger plots which
can be redeveloped,
intensified or converted into
smaller units.
If the BT block near ESK is going to
become housing, could it include
balconies on the outside so that residents
can sit out and chat to their neighbours?
Also ensure communal areas are kept in
good condition and that there is a
residents association. All these things are
The Council is committed to
ensuring that residential
development is built to a high
standard and that flats have
the required amount of
open/amenity space including
balconies and communal
No change
123
ID
No.
43
Section
Paragraph
no. and
subject
Policy D5:
Housing
Respondent
P Page
Summary of
Representation/Comment
Proposed Response
necessary to stop high rise blocks
becoming isolating slum type blocks.
open space. This ensures that
the development is
aesthetical pleasing and
promotes a good quality of
life.
The Moy Avenue site has
been identified in the SHLAA
as having residential
potential, but no decision has
been made as to the type or
form of development, nor has
the site been granted
planning permission.
The Eastbourne Plan appears to be a very
sensible set of proposals, clearly written
after a lot of thought. Hope that in the
current light of the recession and the lack
of money available to councils,
businesses and residents it is still
possible to put the plans into action.
Support welcomed. The Core
Strategy is a long term plan
up to 2027, therefore is likely
to be affected by periods of
recession and economic
growth. However, the
deliverability of the policies
has been justified by a
comprehensive evidence
base.
There needs to be more of a link made
between the proposals for housing
development and provision of school
places. A sensible solution is to work with
East Sussex CC in developing a 4-11
school on the site of the Dental Practise
Board in the Summerdown and Saffrons
neighbourhood. This would then in turn
prevent threat to Longland Road Park as
Recommended Change
No Change
The delivery of new housing
will be supported by a raft of
social infrastructure including
new primary and secondary
school provision. With
regards to primary school
places there is an identified
124
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
a site.
need for new schools within
the short term and the
Council is working closely
with East Sussex County
Council to secure this. The
western side of the Borough
requires extra provision and
discussions are currently
taking place to secure extra
provision within the next 5
years to cater for a local
increase in the number of
children of school age. The
supporting Infrastructure
Delivery Plan provides more
detail on the infrastructure
requirements of new
development and the
provision of new educational
facilities across the Borough.
Recommended Change
The Council is committed to
safeguarding its existing
designated areas of open
space including playing fields
and there are no plans to
develop them within the
timeframe of the Core
Strategy.
74
Policy D5:
Housing
The CoOperative
The policy sets out an affordable housing
provision requirement in High Value and
The policy and supporting
text should refer to only two
Amend Policy D5: Housing so
the final sentence of the fifth
125
ID
No.
77
Section
Paragraph
no. and
subject
Policy D5:
Housing
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Group (C W S)
Ltd
Medium Value Areas, but paragraph 4.5.8
refers to two Market Value Areas and the
table identifies High Value and Low Value
Neighbourhoods. Presume this is a typing
error and the policy and supporting text
and table should refer to the same
Market Value Areas.
market value areas. These
are ‘High Value Areas’ where
40% affordable housing will
be sought and ‘Low Value
Areas’ where 30% affordable
housing will be sought.
paragraph reads:
‘In developments within
neighbourhoods in Low Value
Areas, 30% affordable housing
will be sought on all sites.
Trustees of the
Chatsworth
Settlement
Object to policy because the
overwhelming majority of it refers to
affordable housing provision. It is
suggested that either the balance of this
policy is significantly readdressed or
there is a separate policy dealing with the
aims as far as affordable housing delivery
is concerned. The policy ignores the
qualitative aspects of the housing supply.
The proposed approach represents a very
significant departure from the existing
Borough Plan and it is essential that the
implications of the policy are taken into
account .
The policy relates to both
general housing and
affordable housing. It is
accepted that the policy deals
primarily with affordable
housing which is afforded
more wording as it requires
more detail, but it also refers
to the type of market housing
sought in line with the
Strategic Housing Market
Assessment. There is some
cross-over with Policy ‘B2:
Spatial Development Strategy
and Distribution’, but only in
relation to the first few
sentences of the policy which
set the context for the policy
in terms of overall housing
numbers.
No Change
The Core Strategy argues there is no
need to identify any urban extension
housing sites within the Plan, on the
basis that the assessment of capacity
both from commitments and from sites
identified in the SHLAA appraisal, mean
that more than 5 years supply is
identifiable. The implications of a
significant proposed change in the
The qualitative aspects of
development, including such
things as design and impact
126
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
threshold from affordable housing, from
15 dwellings as it currently stands, to
seeking affordable contribution from
schemes where there is a net gain of a
single dwelling, suggest a reduction in
the supply of unidentified (unallocated)
sites for housing.
on residential amenity will be
covered in the Development
Management DPD which will
be prepared following the
adoption of the Core
Strategy.
The most reliable form of affordable
housing delivery is through the allocation
of larger residential or mixed-use sites,
with specific and identifiable affordable
housing thresholds.
The evidence base needs to demonstrate
that the change in the proposed
affordable housing threshold from 15
units to 1 unit, will deliver housing at a
sufficient rate, that a rolling 5-year
supply can be demonstrated. The present
threshold for affordable housing, has had
a significantly adverse impact on the
supply of affordable housing in the
Borough, but are not convinced that the
solution lies in amendment to the
threshold in the way contemplated.
Concern about the proposed introduction
of different proportional requirements for
Recommended Change
The considerable change in
the affordable housing policy
is recognised. The new policy
is justified, following
recommendations from the
Financial Viability of
Affordable Housing study.
The proposed affordable
housing policy is the starting
point for detailed discussions
with developers as to the
viability of development on
each individual site. The
policy is not intended to stop
or hinder residential
development, but to provide
contributions to affordable
housing where appropriate
and viable.
A large proportion of
greenfield sites, currently
outside the development
boundary are not considered
suitable for development for
127
ID
No.
156
Section
Paragraph
no. and
subject
Policy D5:
Housing
Respondent
Mr John
Egerton,
Clinton
Development
Company Ltd
Summary of
Representation/Comment
Proposed Response
affordable housing as between medium
and high value areas. The overall aim to
introduce flexibility is welcomed.
However, the need to address the
proportion of affordable housing to be
provided in housing schemes is often as
much a reflection of changes in economic
circumstances and in particular the state
of the property market. The ability to
make a case on the basis of viability is
important therefore and would prefer
that policy flexibility be retained in that
respect. It is unlikely that a 10%
difference in the amount of affordable
housing sought will have anything like
the impact that the proposed reduction in
threshold will have as far as the overall
affordable housing supply.
housing due to environmental
constraints including flood
risk and biodiversity. The
issue is that greenfield sites
are regarded as not
developable rather than
being ‘not required’.
Support welcomed for
increased flexibility in the
affordable housing policy, but
would highlight that the split
in affordable housing
percentages for different
neighbourhoods in the
Borough is justified in the
LDF evidence base.
There appears to be an omission from
the overall strategy of the need to
provide adequate accommodation for the
elderly such as residential care homes.
The provision of accommodation for the
elderly is fundamentally different to that
of standard residential development and
should be regarded as such in the plan.
This should outline the need, the target
provision and the location of such
development. This is particularly
important in light of Eastbourne’s ageing
population, with a high proportion of the
It is recognised that the
needs of the elderly
population are important
however the Core Strategy
has been prepared as a
strategy which encompasses
the needs of all sectors of the
population and it is not
considered appropriate to
single out one specific age
group or type of housing.
Recommended Change
No change.
128
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
The affordable housing part
of the housing policy is
justified following the
recommendations of the
‘Financial Viability of
Affordable Housing
Assessment’ evidence
document. It is accepted that
different site characteristics
within each Value Market
Area, may impact on the
ability to deliver the proposed
quota of affordable housing.
Flexibility of the policy is
therefore allowed following
the cascade approach
outlined in the supporting
text. This is reasonable, and
allows site specific issues to
be addressed and not prevent
residential development
taking place.
The policy and supporting
text should refer to only two
market value areas. These
are ‘High Value Areas’ where
40% affordable housing will
Policy D5: Housing should be
amended so the final sentence
of the fifth paragraph reads:
‘In developments within
neighbourhoods in Low Value
Areas, 30% affordable housing
will be sought on all sites.
population 75 years or older and the
county area of East Sussex having the
highest proportion of very elderly persons
than any other county in the UK.
207
Policy D5:
Housing
Miss Charlotte
Handscomb
(DPP Planning)
Note that Sovereign Harbour is identified
within Figure 17 as being within a High
Value Market Area, and will be subject to
the imposition of a 40% affordable
housing target. The supporting text
allows for other considerations to be
taken into account that may affect
delivery of affordable housing (i.e.
development viability). However, the
imposition of a higher affordable housing
target as a starting point is unhelpful.
There may be marked differentials in
existing property values and site
(re)development costs within a specific
area, including those categorised
uniformly as High Value. The recent drop
and stagnation in values has occurred
when build costs have increased and
could increase further.
High Value areas may have become so by
virtue of high build costs that have been
required to reclaim brownfield sites and
create a high quality environment. This is
the case at Sovereign Harbour, where
high build costs and additional
infrastructure costs prevail, resulting in
higher sale prices. Policy D5 refers to
129
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
other areas as Medium Value Areas,
whereas Figure 17 and the related Table
refer to them as Low Value Market Areas.
The language used should be consistent.
be sought and ‘Low Value
Areas’ where 30% affordable
housing will be sought.
Recommended Change
198
Policy D5:
Housing
Johnston Press
plc
Support the acknowledgement (at para.
4.5.5) that the Council’s affordable
housing requirement will be applied in a
flexible manner, on a site by site basis.
This acknowledgement is
amplified in the bullet points
following.
No Change
192
Policy D5:
Housing
J A Williams
The housing section is based on the false
premise that a larger number of new
dwellings are required. It will be
interesting to see how the 40%
affordable housing in high value areas
will be implemented in the 150 units in
Sovereign Harbour.
The local housing target is
supported by evidence which
underpinned the original
South East Plan housing
allocation for the Borough,
which still remains credible.
In creating and maintaining
sustainable neighbourhoods
and communities, the
provision of affordable
housing on site as part of
new residential development
is crucial. The off-site
provision off affordable is the
last and least preferred
option is the supporting text
of the housing policy (para.
4.5.7).
No Change
215
Policy D5:
Housing
Royal Mail
Note the need to provide an appropriate
supply of high quality housing to cater for
the whole community, including high
Although the policy does
allow a certain amount of
flexibility, it is still intended
No Change
130
ID
No.
238
Section
Paragraph
no. and
subject
Policy D5:
Housing
Respondent
Wealden
District Council
Summary of
Representation/Comment
Proposed Response
quality affordable housing. Support the
flexible approach within Policy D5
regarding the provision of on site
affordable housing for low value
neighbourhoods, i.e. it does not apply a
specific percentage of affordable housing
sought for low value neighbourhoods.
Request that Policy D5 explicitly states
that low value neighbourhood sites will
be assessed on a site by site basis taking
into consideration the viability and
feasibility of providing affordable
housing.
that the starting point for
developments within the Low
Value Market Areas will be
30%. The flexibility allows
site specific circumstances to
be taken account for in the
assessment of financial
viability. Paragraph 4.5.7
details the cascade
mechanisms that will be used
if financial viability is an issue
for the specific development.
Support the approach on affordable
housing within the neighbourhoods, the
requirements for contributions from all
development over 1 unit towards
affordable housing provision, the
40%/30% split between high value and
low/medium value neighbourhoods
respectively, and the 30/70 tenure spilt
in relation to affordable housing
development. This accords with the
findings of the joint Housing Market
Assessment, and provides the
opportunity to provide affordable housing
across the neighbourhoods. Note and
support the desire to prioritise affordable
housing provision, where opportunities
arise, in those neighbourhoods where
there is little development opportunity.
Support welcomed for the
level of housing development
proposed over the plan
period and the revised policy
for affordable housing.
It is accepted that the
anticipated level of windfall
housing delivery is high in
some neighbourhoods, but
this is based on further
opportunities for
redevelopment and
conversion of properties
within each area, for which it
was not possible to identify in
the SHLAA. Planning
applications are currently
Recommended Change
Add an additional sentence to
paragraph 2.1.9 so that it
reads as follows:
“The Core Strategy establishes
the framework within which the
required level of housing
provision and the broad
locational strategy is set. In
considering the opportunities
for development, the Council
has undertaken a
comprehensive Strategic
Housing Land Availability
Assessment, to
assess the capacity of the
neighbourhoods within the
town and consider different
131
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Appreciate the considerable work
undertaken on SHLAA, and viability
assessments to evidence the provision
and deliverability of housing to meet the
5,022 figure to 2027, but remain
concerned about the considerable
reliance on windfalls.
The windfalls allowance represents more
than 39% of the total housing provision,
with provision in 6 of the 14
neighbourhoods being considerably more
than this (one neighbourhood - St
Anthony's and Langney point - is wholly
dependent on housing development
through windfalls).
Greater reference is required within the
Strategy to the Strategic Housing Land
Availability Assessment (SHLAA) viability
testing work to support the reliance on
windfall development in the
delivery of housing.
243
Policy D5:
Housing
Michael Morland
Policy D5 inflicts a rigid demand that will
turn away many investors especially as it
is directed essentially at the High Value
Areas. The policy states that the
affordable housing will be
indistinguishable from other forms of
development on the site whereas the
reality is different.
Proposed Response
Recommended Change
coming forward for
redevelopments and
conversions within these
neighbourhoods, supporting
the allocation of windfall
delivery within the Core
Strategy.
options for accommodating
growth. This work was
informed by more detailed
work on the financial viability
of development sites. The
following table provides the
level of housing growth
expected within each
neighbourhood including the
anticipated rate of windfall
development.
Reference to the Strategic
Housing Land Availability
Assessment (SHLAA) and the
viability study which
underpinned the assessment
of sites would be better
placed in Section B of the
Eastbourne Plan, Policy B1:
Spatial Development Strategy
and Distribution which
discusses the overall housing
target for the Borough.
The affordable housing part
of the housing policy is
justified following the
recommendations of the
‘Financial Viability of
Affordable Housing
Assessment’ evidence
document. It is accepted that
different site characteristics
No change.
132
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
within each Value Market
Area, may impact on the
ability to deliver the proposed
quota of affordable housing.
Flexibility of the policy is
therefore allowed following
the cascade approach
outlined in the supporting
text. This is reasonable, and
allows site specific issues to
be addressed and not prevent
residential development
taking place.
The statement that affordable
housing ‘should be
indistinguishable from other
forms of development on the
site’ is to ensure that housing
developments are suitably
mixed, not segregated. and
ensures the creation of
balanced sustainable
communities. It ensures that
affordable housing can be
designed in the same way
and same quality as market
housing.
Policy D6: Gypsies, Travellers and Travelling Showpeople
133
ID
No.
121
Section
Paragraph no.
and subject
Policy
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
The South
Downs Society
Welcome the recognition that
any potential sites for travellers
must be assessed against
landscape criteria and suitably
mitigated and screened.
Support welcomed
Support the penultimate bullet
point regarding the criteria used
for assessing the suitability of
sites: availability of utility
services. It is important that
development is co-ordinated with
provision of infrastructure. This
helps to ensure that
unsatisfactory levels of service
such as sewer flooding or poor
water pressure are prevented.
Concern was raised about the
impact that gypsies and
travellers could have on the local
community
Support welcomed
In Policy D6, add additional
text in the first sentence after
“Showpeople” stating “ensuring
that there is no unacceptable
impact on the settled
community”.
No change
94
Policy
Mrs Sarah
Harrison
Southern Water
244
Policy D6: Gypsies
and Travellers
Michael Morland
Comment noted
Policy D6 has already been
amended to refer to
recognition of the impact of
gypsies and travellers on the
settled community following
comments made at LDF
Steering Group Meeting (13th
June 2011).
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr. Derrick
Coffee
There are references here to
healthy lifestyles. It would be
It is recognised that there are
often links between policies,
In fourth paragraph of Policy
D7: Community Sport and
Policy D7: Community, Sports and Health
ID
No.
104
Section
Paragraph no.
and subject
Policy D7:
Community, Sport
134
ID
No.
Section
Paragraph no.
and subject
and Health
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
(East Sussex
Transport 2000)
helpful to have an explicit cross
reference to policy D8 which
demonstrates a recognition of
the potential contribution of
walking and cycling, and
reduction in car dependency to
improved health, both physical
and mental. Suggest in fourth
paragraph of policy, ‘cycling’ is
inserted after ‘walking’.
particularly creating healthy
community via Policy D7:
Community Sports and
Health and encouraging
walking and cycling through
Policy D8: Sustainable Travel.
However, it is considered that
linking these ideas would
create a very complicated
document and it would be
difficult to identify all
connections without the
document becoming full of
distracting notes and
comments. Therefore it is not
considered advantageous to
explicitly cross reference
policies.
Health, insert the word ‘cycling’
so that policy reads “…in
locations that are easily
accessible by walking, cycling
or by the use of public
transport.”
In order to increase the
recognition of the
contribution of cycling to
accessibility and reducing car
dependency, Policy D7 will be
amended to include reference
to cycling in terms of
accessing community, sports
and health facilities.
122
Policy D7:
Community, Sport
and Health
South Downs
Society
There appears to be no
recognition in this Policy of the
role that access to the national
park might play.
It is recognised that the
South Downs National Park
offers a wide range of
recreational opportunities for
Add a sentence to the end of
para. 4.7.4 as follows: “The
South Downs National Park is
also an important resource on
135
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
the town that can help to
promote healthy lifestyles.
Therefore, it is considered
that a specific reference to
the South Downs National
Park would be appropriate.
the town’s doorstep that
provides a wide range of
recreational opportunities.”
208
Policy D7:
Community, Sport
and Health
Miss Charlotte
Handscomb
(DPP Planning)
Support as it will require
contributions towards new
facilities where a gap in provision
exists. Reference made to the
Council's updated Infrastructure
Delivery Plan supported as it will
ensure funds are allocated
effectively, to where the required
benefit is needed.
Support welcomed. The
Infrastructure Delivery Plan
identifies the locations where
gaps in provision exist, and
this will be updated regularly
to ensure that it reflects the
current situation.
No change
209
Policy D7:
Community, Sport
and Health
Mr John Egerton
(Clinton
Development
Company Ltd)
The strategy set out in Policy D7
is dependent on the co-operation
of other organisations in
providing facilities. It is vague on
how this strategy will be fulfilled,
and does not appear to consider
where facilities are most needed
and what type of facilities are
lacking in the Borough. There is
a shortfall in suitable elderly care
accommodation and an increased
need for further health care
facilities. The spatial approach of
the strategy has not fully
considered how it will effectively
deliver the health care and
The delivery of facilities will
be dependent on the cooperation of other
organisations. Health facilities
will be provided by the
appropriate health care
organisations in locations
where they have identified a
need.
It is likely that additional
community and sports
facilities will be provided as
part of new development,
and therefore the developers
will build, or contribute
towards the cost through
See response to 83 in the ‘Part
A’ section.
136
ID
No.
193
Section
Paragraph no.
and subject
Policy D7:
Community, Sport
and Health
Respondent
Summary of
Representation/Comment
Proposed Response
elderly accommodation provision
within the Borough.
developer contributions. The
Infrastructure Delivery Plan
identifies where these
facilities are most needed
and what types of facilities
are lacking in the Borough,
and this will be regularly
updated to ensure that it
reflects the current situation.
J A Williams
The section highlights the
inadequate situation at
Sovereign Harbour. Communities
can only be genuinely
sustainable if all residents have
full access to all of the
community, sports and health
facilities that they need and for
most Sovereign Harbour
residents none of the facilities
are within the acceptable norms.
The ambition of the Core
Strategy is to increase the
sustainability of each
neighbourhood, and as part
of this provide the services
and facilities, including
community infrastructure,
that are currently missing
across all parts of the town.
Comments regarding
community facilities in
Sovereign neighbourhood are
considered within the
Sovereign neighbourhood
section.
No change
Mr Graham ArrJones
(East Sussex
County Council)
Would like a more specific
reference to financial
contributions for education by
changing the text to read
'community, including
education'.
It is recognised that financial
contributions from new
development towards
education is important in
ensuring that provision is
adequate to meet local
Amend the second sentence in
paragraph 4.7.14 as follows:
“In order to cater for increased
demand and to help meet
standards of provision, new
residential development should
Para 4.7.1
87a
Policy D7:
Community, Sport
and Health
Para 4.7.14
Recommended Change
137
ID
No.
87d
Section
Paragraph no.
and subject
Policy D7:
Community, Sport
and Health
Para 4.7.18
Respondent
Mr Graham ArrJones
(East Sussex
County Council)
Summary of
Representation/Comment
Currently Highfield and Hampden
Park schools are being consulted
on for amalgamation. The
current wording of the policy
would appear to suggest that
there would be a presumption
opposing the loss of such a
facility even though any merger
would have the aim of improving
the educational service provided
by these facilities. The current
policy may prevent the capital
value of old redundant
community facilities being
recycled into new improved
community services at an
alternative location. Therefore
would suggest policy should
acknowledge that possibility
particularly at a time of
restricted resources to invest in
capital projects for both District
and County Councils.
Proposed Response
Recommended Change
needs. Therefore, it is
considered that a specific
reference to education under
this paragraph would be
appropriate.
make a contribution towards
the provision of community
(including education), sports
and health facilities through
developer contributions to
meet the needs of the
development and the wider
community.”
Policy D7 is intended to
protect community facilities
from loss unless there is
evidence that the facility is
no longer needed or where
the facility would be replaced
by alternative and improved
provision in the Borough. It is
not accepted that the policy
prevents redundant facilities
being recycled. Paragraph
4.7.18 further amplifies this.
In the case of school facilities
the education authority would
need to show firstly that
there was a net benefit in the
closure of one school (as in
the case referred to), and
secondly that there was no
need for an alternative
community facility for which
the redundant building could
be used or that there would
be a resulting community
No Change
138
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
gain such as the increased
community use of the new
(or consolidated) provision.
Policy D8: Sustainable Travel
ID
No.
46
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Iain Brogden
Need a move away from "bus
route" strategy and start thinking
clever about cleaner forms of
transport. Buses take up a large
amount of road space and cause
congestion and pollution and the
modern private car is less
polluting per head. Better
provision should be made for
cycling and in Ratton/Willingdon
there is currently no utility
cycling provision. Cycle routes
need to be designed so as to be
safe and linked to local facilities
in order to be attractive and
therefore used. Routes should
also be continuous so cyclists do
not have to dismount. Poor road
surfacing adversely affects
cyclists and causes injuries.
Prioritising maintenance work
based on the safety of vulnerable
road users is proposed. There is
In order to reduce the
reliance on the car and
encourage sustainable travel,
a variety of forms of
transport will need to be
promoted, including walking,
cycling and public transport.
Buses are just one of these
many forms of transport and
they can play an important
role in modal shift but only if
the service is quick and
reliable. The provision of bus
routes, especially on heavily
used bus routes and close to
busy junctions, help to
achieve this.
No change
The Core Strategy recognises
the importance of cycling and
aims to increase the
provision of cycle routes and
facilities in the town. Policy
139
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
a need to consider the routes
from each neighbourhood into
the most popular destinations
such as schools, surgeries, parks
and town centre.
D8 recognises that there is a
lack of continuous cycle
routes and more routes are
needed to connect areas and
facilities, such as shops and
educational facilities.
Recommended Change
The respondent makes many
detailed points on improving
cycling provision. These
matters of detail will be
addressed in the preparation
of the Eastbourne Cycling
Strategy, which will also
consider the best routes from
each neighbourhood to the
most popular destinations.
The implementation of cycle
routes and road maintenance
is the responsibility of East
Sussex County Council and
Eastbourne Borough Council
will work closely with them to
ensure that the most
appropriate cycle
infrastructure are
implemented.
Detailed comments on cycling
will be forwarded to the
officers preparing the cycling
strategy.
140
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
47
Policy D8:
Sustainable Travel
Mr A. B. Moody
There is a lack of cycle lanes
throughout Eastbourne.
The Core Strategy, and
particularly Policy D8:
Sustainable Travel and Policy
D7: Community Sports and
Health, is very supportive of
cycling in order to reduce the
amount of traffic on the road
and encourage healthier
lifestyles.
See also response to 46
above.
No change
50
Policy D8:
Sustainable Travel
Mr John
Cordner
Please make cycle routes a
major part of the 'Eastbourne
Plan'. Any new building of homes
should have cycle routes on all
the roads that have to be built
with them and importantly have
existing routes being linked
together, rather than stand alone
routes as these don't work in
encouraging people out of their
cars.
The Core Strategy sets out
the ambitions for improving
cycle routes and facilities in
the town. The detail
regarding the provision of
new cycle routes and linking
these to existing ones will be
addressed through the
Cycling Strategy.
No change
51
Policy D8:
Sustainable Travel
Angela Boas
Support the improvement of
shops and proposed cycle routes.
Would like to cycle so cars can
be left at home but constantly
come across areas where there
are no cycle paths and have to
use paths or busy and dangerous
Support welcomed. Cycling is
an important part of
sustainable travel and
encouraging people out of
their cars for short trips. The
detail regarding the locations
of cycle routes will be
No change
141
ID
No.
82
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Respondent
Felicity Goodson
Summary of
Representation/Comment
Proposed Response
roads. The prospect of cycling
from the Sovereign Harbour to
Holywell in one stretch would be
welcome.
If the retail opportunities
improved in Eastbourne, could
stay in our home town instead of
travelling to Brighton or
Tunbridge Wells for decent
shopping.
addressed through the
Cycling Strategy.
Support the building of a
comprehensive cycle network
with clearly marked crossings,
shared paths and priority over
cars at road crossings.
Good cycle routes can make
neighbourhoods more
sustainable by providing
better access to services and
facilities.
With the Towner development in
Old Town section 106 monies
should be used to clear parking
on the Goffs and install a shared
cycle and footpath into the town.
92a
Policy D8:
Sustainable Travel
Mr Graham ArrJones
Strongly support this Policy
which accords with the LTP3 high
Recommended Change
The Town Centre
neighbourhood vision
identifies the need to
strengthen the retail offer in
the Town Centre in order to
compete with other centres,
and the detail regarding how
this will be achieved will be
set out in the Town Centre
Area Action Plan.
No change
However, the Core Strategy
cannot provide specific detail
on locations of all cycle
routes and road demarcation.
Responsibility for speed limits
and quality of the road
surface lies with the County
Council.
Support welcomed. It is
important that the Core
No change
142
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
(East Sussex
County Council)
level objective, to 'provide
sustainable transport
opportunities to enhance social
inclusion', and the Specific
Transport Objective to 'improve
strategic and local connectivity of
communities to facilitate
economic and spatial growth
through the LDF process'.
Strategy is in conformity with
other strategy and policy
document such as the Local
Transport Plan.
Recommended Change
98a
Policy D8:
Sustainable Travel
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Suggest first sentence in first
para. is changed to: ‘Sustainable
travel will be promoted through a
variety of measures aimed at
reducing the need to travel,
reducing reliance on the private
car (especially for short trips)
and providing incentives to use
alternative modes’.
Whilst the intension of this is
appreciated, the Core
Strategy is a strategic
planning document that
cannot deal with the
arrangement of incentives for
people to use sustainable
travel methods other than
the provision of appropriate
infrastructure. Therefore it is
not considered appropriate to
make reference to these
incentives within the Core
Strategy.
No change
98b
Policy D8:
Sustainable Travel
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
In the second sentence, suggest
it is slightly amended by
replacing ‘promoted’ by
‘supported’, which is stronger as
it implies that there are
incentives over and above, say,
a publicity campaign.
It is considered that shaping
the pattern of development
and influencing land uses is a
form of incentive for
sustainable travel and it
would be appropriate to
replace the work ‘promoted’
with ‘supported’
Replace the word ‘promoted’ in
the second sentence of the first
paragraph in Policy D8:
Sustainable Travel with the
word ‘supported’.
143
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
98c
Policy D8:
Sustainable Travel
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Add a further sentence to para.
3: ‘Approved Travel Plans will be
monitored for implementation
and take-up to ensure effective
outcomes’. Experience has
shown that existence of a Travel
Plan is no guarantee that it will
be implemented, even when it
has been a condition of planning
consent.
The monitoring of travel
plans is the responsibility of
East Sussex County Council.
Therefore it is considered
inappropriate to make
reference to a responsibility
that does not lie with
Eastbourne Borough Council.
No change
98d
Policy D8:
Sustainable Travel
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Fourth paragraph: after
'especially' could the sentence be
slightly amended to '...where
they link residential areas to
employment areas, schools and
colleges, and other significant
'traffic objectives', and where
they offer the potential for modal
shift.
Agreed in part. The phrasing
‘significant traffic objectives’
is not considered to be
appropriate because it is not
obvious what the term refers
to. However, creating cycle
routes to schools is important
and the policy should refer to
this. Therefore, the policy
wording will be amended to
reflect the desire to promote
cycle routes that link
residential areas to education
establishments.
Amend first sentence of fourth
paragraph in Policy D8 as
follows: “The development of a
network of safe walking and
cycling routes will be
promoted, especially where
they link existing residential
areas to employment areas and
educational establishments,
and offer the potential for
modal shift.”
123
Policy D8:
Sustainable Travel
South Downs
Society
There is positive reference here
to the importance of developing
a network of safe walking and
cycling routes. There should be
specific, positive mention of
access to the national park.
Agreed. It would be useful to
identify the South Downs as
being easily accessible by
walking and cycling.
Extend sentence in para. 4.3.5
as follows: “The recent
designation of the South
Downs National Park provides
the opportunity for increased
promotion of the attractions of
However, it is considered that
144
ID
No.
130
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Respondent
Howard Moore
(Highways
Agency)
Summary of
Representation/Comment
Although there are no trunk
roads in Eastbourne Borough, it
may be that the cumulative
effect of development in the
borough could have an impact on
the A259 to the east, the A27 to
the north and west and more
specifically the Cophall
roundabout and A27/A2270
junction. Stress on the A27 is
expected to increase throughout
the plan period, particularly
during the peak periods. It is
therefore important that, the
Core Strategy policies promote
sustainable development with
the view to making the Borough
more self-contained to help
reduce the impact of LDF
development on the road
network. It is important for the
Core Strategy to demonstrate
that the proposed LDF
development is deliverable in
transport terms. There should be
clear linkages between the Core
Strategy and the associated
Proposed Response
Recommended Change
this would be most
appropriate in the Tourism
and Culture chapter
the part of the Downs which
falls within the Borough, and
these should be easily
accessible through walking and
cycling”.
One of the main ambitions of
Policy D8: Sustainable Travel
to reduce the need for people
of Eastbourne to travel, and
where possible, the policy
encourages short trips to be
made by walking or cycling,
and others by public
transport. In this respect, the
policy does aim to make the
town more self-contained by
providing local services and
facilities within each
neighbourhood.
No change
The SWETS evidence has
indicated that the transport
impact of housing
development in Eastbourne
can be mitigated through a
package of transport
measures. Para 4.8.12
provides direct links between
the recommendations in
SWETS and the Core
Strategy.
145
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
SWETS based supporting
evidence.
136
Policy D8:
Sustainable Travel
Howard Moore
(Highways
Agency)
Policy D8 comprises a number of
measures that could reduce the
reliance on the private car to,
from and within Eastbourne
Borough. Measures such as the
quality bus corridors should be
explained in more detail.
Agreed. Further explanation
regarding delivery of the
Quality Bus Corridors through
the Bus Quality Partnership
will be included, as outlined
in Rep ID 92j
See Rep ID 92j
139
Policy D8:
Sustainable Travel
Mr D Read
Strongly support policy D8. The
policy demonstrates a strategy
for transport that puts
sustainability issues first.
Delighted to see that promoting
road building has been deleted
and other solutions are to be
followed but question
deliverability.
The encouragement of
sustainable travel,
particularly cycling, is a key
ambition of the Core
Strategy, and this will be
followed up by a Cycling
Strategy that will address
issues such as the provision
of cycle routes, facilities and
infrastructure.
No change
It should be explicitly stated that
former road schemes are now
abandoned. Alarmed that key
diagram showed some feint
dotted lines through Eastbourne
Park indicating road proposals,
but these were not mentioned in
the written text.
Although most of the
Eastbourne Park road links
will be rescinded, East
Sussex County Council has
confirmed that the
development of the St
Anthony’s Link section is still
an identified road scheme.
The existing Key Diagram
does not show dotted lines
that indicate road building
146
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
through Eastbourne Park, but
this will need to be updated
to show the St Anthony’s
Link.
140
Policy D8:
Sustainable Travel
J McNally
(Bespoke)
Building 5000 homes will add to
congestion in the town unless a
clear commitment is made to
creating cycle paths. This is an
opportunity to create an
infrastructure to make
Eastbourne a town where cycling
is normal. Suggests detailed for
how this will achieved. Concern
that the emphasis on
neighbourhoods detracts from
the bigger picture for cycling
throughout the town.
Core Strategy ambition is to
reduce reliance on cars by
improving opportunities for
people to travel by
sustainable means, such as
cycling, and support for this
commitment is welcomed. It
is also recognised that cycling
can play an important part in
creating healthier
communities. Details
regarding the provision of
cycle routes and
infrastructure will be
considered through the
Cycling Strategy and also
future planning policy
documents such as the
Development Management
DPD.
No change
The neighbourhood approach
taken to the Core Strategy
does not mean that wider
issues are not addressed.
Section C of the Core
Strategy provides
neighbourhood visions in
147
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
order that communities can
see how their neighbourhood
might develop in the future,
and these are based upon the
policies in Section D, which
topic-based policies that
apply borough wide. These
visions re not prepared in
isolation or exclusive of the
overall borough wide
strategy.
149
Policy D8:
Sustainable Travel
J McNally
(Bespoke)
Need major cycle routes across
Eastbourne, linking all major
workplaces, schools, shopping
areas and railway stations to
encourage utility cycling. Also
linking of South Downs Way,
seafront, railway stations and the
Cuckoo Trail, to encourage
recreational and tourist cycling.
Suggest how better provision for
cycling could be made.
It is agreed that in every
neighbourhood there are
opportunities for
improvements to be made to
cycle infrastructure, and it is
envisaged that these will be
identified through the Cycling
Strategy.
The Core Strategy sets the
ambition to improve cycle
facilities and get more people
using their bicycles instead of
their cars, particularly for
short trips.
No change
The Cycling Strategy will
address the detail regarding
the provision of cycle routes,
facilities and other cycling
infrastructure, especially
those that link trip
148
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
generators. The safety of
cyclists will also be taken into
consideration in the
implementation of Quality
Bus Corridors.
182
Policy D8:
Sustainable Travel
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Incentives are needed to
encourage people to use more
sustainable patterns of travelling
including reducing traffic speed
limits, re-allocating road space
and controlling the volume and
cost of parking to reduce
attractiveness of private
motorised traffic.
Whilst spatial planning is
about more than just land
use issues, the Core Strategy
is limited in how it can affect
other standards and
situations. Managing land
uses, particularly with regard
to new development, is an
important part of the Core
Strategy and is one way that
that travel methods can be
influenced. It is difficult to
influence land uses in already
established areas and
therefore policies need to
concentrate on new
development in order to
encourage sustainable
transport.
No change
It is accepted that measures
in support of sustainable
modes in new developments
need to be supported by
measures in existing urban
areas, and these will be
addressed through other
149
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
policy documents and
strategies such as the Cycling
Strategy.
210
Policy D8:
Sustainable Travel
Miss Charlotte
Handscomb
(DPP Planning)
Support the promotion of
alternative sustainable transport
choices, however, the
requirement of a Travel Plan for
residential developments of five
dwellings or greater or nonresidential floorspace of 500sqm
or greater is excessive and
inappropriate. Developments of
this size and even larger are
unlikely to result in the need for
promotional based Travel Plans
where they already benefit from
a choice of transport options or
where a range of on-site facilities
are proposed to meet wider
sustainability (BREEAM) ratings.
The third paragraph of Policy D8
and para. 4.8.15 should be
amended.
It is recognised that the
threshold for Travel Plan as
identified in the Proposed
Core Strategy is excessive,
as there is unlikely to be
significant transport
implications for a
development of five
dwellings, and the nonresidential threshold does not
take into account the travel
demands of individual
developments.
East Sussex County Council
have published a document
called ‘Guidance on Travel
Plans for New Developments’,
which contains information
on how Travel Plans are
expected to be secured as
part of the planning process
and the way they are
monitored and enforced.
Therefore the policy should
be amended to require Travel
Plans for developments that
are within the thresholds set
out in the County’s guidance.
Amend the second sentence of
the third paragraph in Policy
D8 as follows: “Travel Plans
will therefore be required for
development that is expected
to create a significant number
of additional trips in line with
East Sussex County Council’s
‘Guidance on Travel Plans for
New Developments’.”
Amend second sentence of
para. 4.8.15 as follows: “The
thresholds at which these will
be required has been set in
East Sussex County Council’s
‘Guidance on Travel Plans for
New Developments’.”
150
ID
No.
218
219
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Policy D8:
Sustainable Travel
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
P Page
Agree we need to cut down on
use of the car but the current cut
in subsidies to councils and bus
companies makes this difficult.
Local bus services are run on
a commercial basis by
Stagecoach, and the Core
Strategy cannot define which
routes should be run.
However, the Core Strategy
aims to make bus travel
more attractive by improving
facilities and integration with
other modes, which it is
hoped will result in more
people are using buses,
meaning that more routes
will become viable for
Stagecoach to run.
No change
Mr John
Hurwood
(Member of
local committee
CPRE)
The present bus arrangement in
Terminus Road does not
encourage bus use, or rail/bus
transfer, and is detrimental to
the shopping use of the section
of Terminus Road from the
station to the pedestrian section.
Would prefer to see greater
emphasis on the development of
a purpose made bus terminal
close to the station.
The Core Strategy recognises
the importance of
connectivity between buses
and trains as a way to
encourage sustainable travel.
No change
Improvements the quality
and range of public transport
provision in the Town Centre
are identified in the Town
Centre neighbourhood vision,
and in Policy D8: Sustainable
Travel. The improvement or
relocation of the bus
interchange in Terminus Road
will be addressed through the
Town Centre Area Action
151
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Plan.
92j
Policy D8:
Sustainable Travel
Policy D8
92b
Policy D8:
Sustainable Travel
Para 4.8.2
92c
Policy D8:
Sustainable Travel
Mr Graham ArrJones
(East Sussex
County Council)
Recommend reference within
Policy to the work underway to
establish a Bus Quality
Partnership for Eastbourne which
will work on a range of initiatives
to make bus travel within the
area a more attractive
proposition, and improve
accessibility to the town centre
and trip attractors such as the
hospital.
Agreed. Making reference to
the establishment of a Bus
Quality Partnership will
indicate how the quality of
the bus service will be
improved, which would have
the result of increasing bus
patronage and encouraging
people out of their cars.
Add sentence after the first
sentence of para. 4.8.13 as
follows: “Work is underway to
establish a Bus Quality
Partnership for Eastbourne,
which will work a range of
initiatives to make bus travel
more attractive and improve
accessibility to the town centre
and major trip attractors such
as the hospital”.
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the ambition to reduce
the percentage of people
travelling to work by private car
from 63% (2001). Is there a
target figure for reducing this by
2026?
Support welcomed.
Eastbourne Borough Council
has not set a target for
reducing the percentage of
people travelling to work by
private car. However,
through the Environment
Strategy, Eastbourne
Borough Council does have a
target to reduce carbon
emissions by 40% by 2020
and 80% by 2080. It is
considered that it would be
helpful to include this target
in the Core Strategy.
Add sentence after the final
sentence of para. 4.8.2 as
follows: “It will also help to
achieve the target set in the
Environment Strategy to
reduce carbon emissions by
40% by 2020 and 80% by
2080.”
Mr Graham ArrJones
(East Sussex
How has the list of the locations
where traffic will be relieved (by
encouraging sustainable travel)
The list comprises junctions
that exceed an 80% capacity
average over AM/PM peaks
No change
152
ID
No.
Section
Paragraph no.
and subject
Para 4.8.3
Respondent
Summary of
Representation/Comment
Proposed Response
County Council)
been compiled? It does not align
with any list identified within the
South Wealden and Eastbourne
Transport Study (SWETS)?
during the base year 2009,
as identified in Appendix 6 of
the SWETS study.
Recommended Change
It was included in order to
provide an indicative list of
junctions in the town that
could be improved if levels of
traffic are reduced through
encouraging sustainable
travel.
98e
Policy D8:
Sustainable Travel
Para 4.8.3
92e
Policy D8:
Sustainable Travel
Para 4.8.5
98f
Policy D8:
Sustainable Travel
Para 4.8.5
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
The 'encouragement of
sustainable travel in Eastbourne'
won't in itself lead to traffic
reduction. Rather 'an increased
proportion of trips made by
sustainable modes' will help to
achieve that desired result.
Agreed. Although it is only a
slight wording change, it is
considered that it could be
made clearer that reducing
the reliance on the private
car by providing desirable
sustainable travel
alternatives can have a
positive effect on the levels
of traffic and congestion.
Amend the first sentence of
paragraph 4.8.3 as follows:
“Increasing the proportion of
trips made by sustainable
modes of travel in Eastbourne
will help to reduce the levels of
traffic across town and relieve
congestion at the following
locations:”
Mr Graham ArrJones
(East Sussex
County Council)
Note the reference to LTP3.
Comment noted. It is
important that the Core
Strategy is in conformity to
other local strategies and
plans.
No change
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Looking at major schemes 'to
meet transport demands' has
been the principle at the heart of
a failure to stem the huge rise in
This paragraph outlines what
is said in the Local Transport
Plan 3 and how it might
affect Eastbourne. As this
No change
153
ID
No.
92f
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Para 4.8.6
92g
Policy D8:
Sustainable Travel
Para 4.8.8
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
car dependency. Major schemes
has almost always meant major
road projects which increase car
dependency. 'Meeting transport
challenges with appropriate
measures' might be a better
phrase and would capture all
possibilities.
wording is directly related to
the Local Transport Plan, it is
not considered appropriate to
change the wording.
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the reference to the
need to locate new development
in close proximity (800 metres)
to services and facilities, and
reference to the accessibility
standard for bus stops of 5
minute walk or 400 metres.
Support welcomed. The
provision of accessible
services and facilities is an
important aspect of a
sustainable neighbourhood,
as well as helping to reduce
car dependency.
No change
Mr Graham ArrJones
(East Sussex
County Council)
Pleased to see reference to the
Eastbourne Cycling Strategy,
which is currently under
development. Would like to see
reference to the need to consider
wider links into the south
Wealden area including
Willingdon/Polegate, Hailsham
and the Stone Cross, Westham
and Pevensey area and provide
localised links to enable access
to the wider National Cycle
Network (NCN) route towards
Bexhill/Hastings and the NCN
Route 21 via Polegate and the
Cuckoo Trail to Hailsham/
Agreed. Eastbourne is not an
isolated community and
many people from south
Wealden use Eastbourne’s
services, which contributes to
the number of cars entering
the town. This could be
reduced by improving
connectivity via cycling
between Eastbourne and
surrounding areas. Therefore
it is considered appropriate
that specific reference be
made to this in the Core
Strategy.
Add sentence after the second
sentence of para. 4.8.8 as
follows: “Improving cycle links
into the south Wealden area
including Willingdon/Polegate,
Hailsham and the Stone Cross,
Westham and Pevensey, is also
considered important in helping
to reduce the number of cars
travelling into the town and
neighbourhoods should have
direct access to the wider
National Cycle Network (NCN)
route towards Bexhill/Hastings
and the NCN Route 21 via
Polegate and the Cuckoo Trail
154
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Heathfield.
92h
Policy D8:
Sustainable Travel
Para 4.8.10
92i
Policy D8:
Sustainable Travel
Para 4.8.11
98g
Policy D8:
Sustainable Travel
Para 4.8.11
Recommended Change
to Hailsham/Heathfield.”
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the support for
schemes that encourage more
people to walk and cycle, such as
pedestrian and cycle network
improvements, route promotion,
junction design, road space
allocation and speed
management.
Support welcomed. The
encouragement of walking
and cycling can contribute
towards modal shift and
reduce the town’s reliance on
the car, thus reducing
congestion and pollution.
No change
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the support for the
development of high quality,
attractive and convenient bus
and rail services with a good
range of facilities such as
shelters and Real Time
Passenger Information (RTPI).
Support welcomed.
No change
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
While it is a valid aim of
providing non-car alternatives,
that social equity objectives can
be achieved through their
provision and enhancement, the
beneficiaries of a high quality
sustainable transport offer come
from all walks of life and socioeconomic backgrounds. An aim
has to be to attract car drivers
out of their cars for at least some
of their journeys.
It is considered that the aim
of attract drivers out of their
cars for at least some of their
journeys is adequately
identified throughout the rest
of this policy chapter (see
paras 4.8.3, 4.8.6, 4.8.7,
4.8.9, 4.8.10, 4.8.14.
4.8.16). Whilst it is
recognised that a high quality
sustainable transport affects
people from all socioeconomic backgrounds, it is
considered important to
No change
155
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
specifically identify that
improving public transport
can have positive effects in
reducing social exclusion.
92d
Policy D8:
Sustainable Travel
Para 4.8.12
98h
Policy D8:
Sustainable Travel
Para 4.8.12
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the reference to
SWETS and the description of the
package of transport
interventions needed to mitigate
the transport impacts of future
housing development. In
addition to the larger scale
transport interventions,
recommend reference to walking
and cycling network
improvements, to encourage
short journeys of less than 5km
to be undertaken using these
modes.
Improvements to walking and
cycling facilities and networks
can make a significant
difference in reducing the
number of shorter journeys
made by car.
However, paragraph 4.8.12
deals specifically with public
transport, and the topic of
replacing short car trips with
walking and cycling is
referenced in paragraph
4.8.7. This paragraph could
be strengthened with
reference made to increasing
effectiveness through
improvements in walking and
cycling networks.
Amend the second sentence of
paragraph 4.8.7 as follows:
“Improvements to the walking
and cycling network will help to
increase the proportion of all
journeys made on foot or by
cycle, which can have
significant personal health
benefits as well as helping to
reduce pollution”
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
South Wealden Transport Study,
(SWETS) 2010 envisages a mode
share of 10% for alternatives to
the private car. This seems a
rather unambitious aspiration.
The South Coast Multi-modal
Study (SoCoMMS, 2002) showed
a figure of 31% as the proportion
of journeys to work in
The percentages quoted don't
relate to the same thing. The
estimates in SWETS of
growth in highways demand
(2009-2027) resulting from
development were about
+38%, but this can be
reduced by 10% with the
implementation of other
No change
156
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Eastbourne made by non-car
modes.
demand management
initiatives. This is the 10%
referred to in the question,
and does not in any way
represent an assumption
about the total proportion of
person trips by non-car
modes. The 10% assumption
is considered to be an
ambitious aspiration in this
context.
The prospects for switching to
sustainable modes can only have
been helped by the rescinding of
the Eastbourne Park road
proposals.
92k
Policy D8:
Sustainable Travel
Para 4.8.14
Mr Graham ArrJones
(East Sussex
County Council)
Note the aspiration to explore,
the potential for a railway station
at North Langney on the site of
the former halt at Stone Cross.
Whilst located outside of the
Recommended Change
Para 4.8.7 identifies short
trips as those that can most
easily be made by
sustainable travel methods,
and the provision of walking
and cycling facilities will help
to encourage these travel
methods.
The majority of the
Eastbourne Park road links
have been rescinded,
however East Sussex County
Council is to retain the St
Anthony’s Link section.
It is considered that
reference to a potential
Parkway station at Polegate
would not be appropriate
because it is significantly
No change
157
ID
No.
98i
Section
Paragraph no.
and subject
Policy D8:
Sustainable Travel
Para 4.8.14
Respondent
Mr. Derrick
Coffee
(East Sussex
Transport 2000)
Summary of
Representation/Comment
Proposed Response
Borough boundary, would also
welcome reference to a potential
Parkway station to the west of
Polegate, as identified in the East
Sussex Local Enterprise
Partnership bid submitted to
Government last year, which
could reduce pressure on the
roads and improve connections
between Eastbourne, Hailsham
and the surrounding areas to
London.
outside of the Borough and is
not considered to make a
significant additional impact
on reducing the amount of
traffic travelling into
Eastbourne than the existing
Polegate station.
A station at Stone Cross has
been an aspiration of many
policy documents from
Eastbourne Borough Council,
Wealden District Council and
East Sussex County Council for
over 20 years. It was an option
identified in the first Multi-Modal
Transport Study ('Access to
Hastings', Steer Davies Gleave,
November, 2000). The station
features as an aspiration in the
ESCC LTP1 (p119) and in LTP3
(draft; pp54, 139). The intention
of the council to 'explore the
potential of a station' may be
well intentioned, but the case
has already been made and
mechanisms exist for its
provision.
The development of a station
at Stone Cross & North
Langney has for a long time
been an ambition for
Eastbourne Borough Council.
It is also referenced in other
policy documents and
strategies, including the Local
Transport Plan and it is
important that policy
documents such as LTP3 and
the Core Strategy are
consistent.
Recommended Change
No change
The implementation of a
station at Stone Cross is not
purely the responsibility of
Eastbourne Borough Council,
and therefore the intension to
explore the potential for a
158
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
station at this site is a
declaration of support for
working with other bodies to
try to make this happen.
However, in order to start the
process it will take action
from another body.
92l
Policy D8:
Sustainable Travel
Para 4.8.15
92m
Policy D8:
Sustainable Travel
Para 4.8.17
92n
Policy D8:
Sustainable Travel
Para 4.8.18
Mr Graham ArrJones
(East Sussex
County Council)
Welcome the requirement for
travel plans for residential and
non-residential development
within certain thresholds.
Support welcomed. Travel
plans are important in
reducing the need to travel
by car. The thresholds have
been amended to be in line
with the County Council’s
‘Guidance on Travel Plans for
New Developments’.
No change
Mr Graham ArrJones
(East Sussex
County Council)
Welcome reference to the need
for all new development to
contribute to improving
accessibility via LSAIC scheme
Support welcomed. It is
important that development
contributes to local
accessibility issues.
No change
Mr Graham ArrJones
(East Sussex
County Council)
Welcome reference to the need
for new development to comply
with ESCC parking standards and
to have regard to the emerging
borough-wide parking strategy.
Support welcomed. It is
important that development
provides an appropriate
amount of parking depending
on local circumstances.
No change
Policy D9: Natural Environment
159
ID
No.
19
Section
Paragraph no.
and subject
Policy D9: Natural
Environment
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Martin Small
South Downs
Joint Committee
Suggested wording for inclusion
in your CS ; perhaps it could slot
in after paragraph 1.1.17 with its
own sub-heading.
Agreed. A new section and
wording would be helpful for
clarification purposes, that
the Core Strategy informs
people of the role of the
National Park Authority in the
planning process. The
wording would be better
placed after para. 1.1.13
‘Open spaces’.
Insert new wording after
paragraph 1.1.13 Section A
(not Policy D9): From 1 April
2011, the South Downs
National Park Authority became
the local planning authority for
the South Downs National
Park, including the area within
Eastbourne Borough Council.
As a consequence of this
fundamental change, the
National Park has been
excluded from the area to
which this Core Strategy
applies. However, because of
the relationship with the urban,
the National Park has been
shown on the key diagram and
is referred to in the text. The
South Downs National Park
Authority will prepare a Local
Development Framework for
the National Park, with the core
strategy expected to be
adopted in 2014. In the
meantime, the policy
framework for the National
Park will continue to be
provided by national planning
policy and the relevant saved
policies of the Eastbourne
Borough Local Plan. The
Borough Council and National
160
ID
No.
Section
Paragraph no.
and subject
Respondent
49
Policy D9: Natural
Environment
Mr J Hurwood
105
Policy D9: Natural
Environment
Mr Derrick
Coffee
Campaign for
Better
Transport
127
Policy D9
Hannah Mears
(Environment
Agency)
Summary of
Representation/Comment
Concern over the phrase
‘enhance access to The South
Downs National Park’, and
potential for any more Car Parks
or Visitor Centres on The Downs.
Prefer to see a positive
statement that the boundary
area with the National Park
would be treated
sympathetically.
Suggest amendment to second
sentence on the advantages of
experiencing green spaces by
walking or cycling. On second
bullet, suggest adding ‘or
degradation’ after
‘fragmentation’.
Information included on the
implementation of a Green
Network Plan, and some
additions to the bullet points to
cover conservation of river
Proposed Response
A full explanation of the role
of the National Park Authority
in preserving the South
Downs in Eastbourne will be
provided. See response and
proposed change to 19
above.
Whilst the suggestion would
increase the explanation of
the benefits of cycling and
walking it is considered that
this level of detail is not
appropriate in the core
strategy. As all development
is subject to consideration of
adverse impact or
‘degradation’ , it would not
be appropriate to specify it
here.
The policy wording should be
amended to include the
additions. Accept the useful
information regarding the
Green Infrastructure Plan-
Recommended Change
Park Authority will work closely
together on cross-boundary
planning (and other) issues in
recognition of the important
relationship between the town
and the Downs.
No change, but see proposed
change to 19 above.
No change.
Sustainability Objectives:
Addition to conservation and
enhancement of wildlife bullet
points:
• Producing Biodiversity
161
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
basins and the importance of
conservation of some species
and the restriction of others.
which will be written in the
summer of 2011.
Recommended Change
Action Plans to identify
measures to preserve
and enhance the
geology, habitats and
space of importance to
Eastbourne, ensuring
the conservation of
important protected
species, and the
restriction of invasive
species.
•
178
Policy D9: Natural
Environment
Christine
Purkess
(Eastbourne &
District
Chamber of
Commerce)
The National Park content is
minimal. The Council owns 4000
acres of Downland and it appears
to be virtually ignored. There
needs to be policies for farming,
downland buildings, downland
tourism etc.
The South Downs National
Park Authority is preparing its
own separate Local
Development Framework.
Please refer to Section A
(para. 1.1.18) for a full
explanation of the roll of the
National Park Authority in
preserving the South Downs
in Eastbourne. The principle
aim is to conserve the South
Downs, which will mean that
little or no development will
be considered here- as in
previously years when the
To conserve and
enhance the Borough’s
river basins, to provide
essential wildlife
habitats.
No change.
162
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
area has been designated as
an Area of Outstanding
Natural Beauty.
Policy D10: Historic Environment
ID
No.
14B
Section
Paragraph no.
and subject
Para 4.10.3
Conservation Areas
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Ian King
It's not clear if the attractive
streets of Grove Road and South
Street are designated as
conservation areas. These areas
include the attractive residential
areas of York Road, Calverley
Road, Hyde Road and Camden
Road. The incorporation of this
area into a conservation area
would help enhance/protect the
area for the future.
Grove Road is not located
within a designated
conservation area, whereas
South Street forms part of
the Town Centre and
Seafront Conservation Area.
Proposals to incorporate
Grove Road, York Road,
Calverley Road, Hyde Road
and Camden Road in the
existing Conservation Area
fall outside the scope of the
Core Strategy. Decisions
relating to the widening of
conservation area boundaries
can only be made as part of a
‘conservation area boundary
review’, which the council is
currently undertaking as part
of a rolling programme for all
of its 12 Conservation Areas.
The review of the Town
Centre and Seafront
Conservation Area is due to
No change.
163
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
take place in September
2012.
106
172
4.10.5
D10
D10
Mr. Derrick
Coffee
Mrs Sue
Burlumi
It would be useful to have a
policy that acknowledged the
presence of buildings outside
Conservation Areas, which are
valued by the public. The
principle is acknowledged in
4.10.5 but perhaps it needs a
formal policy as part of D10.
Policy D10 acknowledges the
principle set out in 4.10.5
where it states that ‘All
significant heritage assets
will be protected and
enhanced, where
practicable’. Buildings of
local interest fall under the
umbrella term of ‘heritage
assets’.
Would like to see something that
acknowledges that preserving
and enhancing the character,
setting and appearance of the
area does not necessarily mean
that new buildings must be
replicas of original buildings, and
that modern designs can sit next
to historic buildings and enhance
them as long as they are well
designed.
We acknowledge that new
builds of a modern and high
quality design that sit well
within the location, respect
important views and reflect
the context of the area
through appropriate massing
and materials etc. can
enhance historic/sensitive
areas.
Amend Policy D10 by including
the following words;
Under PPS 5, there is a
presumption in favour of
protection of all heritage assets
from inappropriate change,
both designated (Listed
Buildings, Conservation Areas)
and non-designated (Buildings
of Local Interest, Areas of High
Townscape Value).
Amend Policy D10 by including
the following words:
The Council understands that
to achieve a high quality
environment it must ensure
that new development makes a
positive contribution to the
appearance of our townscape
and urban heritage. Design and
layout should take account of
context, i.e. neighbouring
buildings as well as the
surrounding area. New
development can be modern or
based on historic forms but
must respect, preserve or
enhance local character. It is
164
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
vital that design goes beyond
the focus of the individual
development and also takes
account of sense of place,
safety and security.
DESIGN POLICY
Eastbourne’s built
environment should be of
an exemplary standard. It
will be protected and
enhanced and development
will be expected to:
1. seek exemplary
standards of design and
architecture that respects
the borough’s unique
characteristics;
2. apply national and
regional policies in respect
of design, landscape
townscape and historic
heritage;
3. ensure that the layout
and design of development
contributes to local
distinctiveness and sense of
place, is appropriate and
sympathetic to its setting in
terms of scale, height,
165
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
massing and density, and
its relationship to adjoining
buildings and landscape
features;
4. ensure that new
development makes a
positive contribution to the
overall appearance of the
area including the use of
good quality materials,
reusing existing materials
where appropriate, and
seeking to achieve a high
standard of finish;
5. promote local
understanding of good
innovative and imaginative
design;
6. ensure new development
is accessible to all and
designed to minimise crime
and anti-social behaviour
without diminishing the
high quality of the overall
appearance.
Policy D11: Eastbourne Park
166
ID
No.
107
128
Section
Paragraph no.
and subject
Policy D11:
Eastbourne Park
Policy D11:
Eastbourne Park
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr Derek Coffee
East Sussex
Transport 2000
(Campaign for
Better
Transport)
Welcome the rescinding of
proposals for a road network
across Eastbourne Park. The
area lends itself very well to
access from the adjacent urban
areas by sustainable modes.
Suggest that vehicular access is
restricted, but with adequate
dedicated provision for disabled
residents.
Support welcomed. It would
be helpful to add a comment
on the suitability of
Eastbourne Park for cycling.
Add sentence at the end of
paragraph 4.11.4 stating that:
“The location of Eastbourne
Park provides excellent
potential for accessing it by
sustainable modes such as
walking and cycling”.
Ms Hannah
Mears
(Environment
Agency Planning
Liaison)
Pleased that you recognise the
important role of Eastbourne
Park as a flood storage area and
natural habitat. Recommended
two changes to improve the
effectiveness of this policy.
Accepted
Add the following text at the
end of the second paragraph in
Policy D11:
“In order to maintain the
effectiveness of Eastbourne
Park as an essential flood
storage area, and in the
interests of mitigating flood
risk, the existing flood storage
system will be periodically
reviewed and updated as
required”.
Re Design and Maintenance as a
Flood Storage Area : Need to
review the existing design and
maintenance arrangements for
the flood storage areas of
Eastbourne Park in order to
maintain their effectiveness as
EA is particularly concerned with
their state of maintenance.
Recommend the following
criterion is added to Policy D11:
The existing flood storage
system within the park will be
periodically reviewed and
updated as required and a
These comments will be
taken on board and included
within the Eastbourne Park
SPD. 2011.
No change
167
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
maintenance plan prepared and
implemented. Reason: To
maintain the effectiveness of
Eastbourne Park as essential
flood storage and in the interests
of mitigating flood risk.
Non-native invasive
species Paragraph
4.11.6
It is particularly important that in
the light of the proposal to
designate Eastbourne Park as a
Local Nature Reserve, the Core
Strategy should recognise the
threat that invasive non-native
species pose to areas of high
biodiversity.
Accepted. It would be helpful
to include reference to
invasive species in the text
In the 1st sentence of
paragraph 4.11.6, add the
following text after “(LNR)”:
“Invasive non-native species
pose a significant threat to
areas of high biodiversity and
methods should be used to
prevent the introduction of new
non-native species and control
any that are already present”.
Delete “This together with” at
the start of the second
sentence of paragraph 4.11.6.
Renewable Energy,
Paragraph 4.11.7
While wind turbines are ruled out
in Eastbourne Park, care should
also be taken to avoid
obstruction to watercourses to
allow for fish passage and retain
ecological connectivity. Some
hydropower technologies for
example obstruct watercourses
and can be extremely damaging
to fish populations.
Recommend that Policy D11 is
amended accordingly.
Accepted. Comments will also
be taken on board in the
preparation of the Eastbourne
park SPD
Add the following text at after
the text in the second bullet
point in Policy D11:
“Taking care to ensure that
new installations do not cause
obstructions to watercourses or
have an unacceptable effect on
the local fauna”.
168
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
76
Policy D11:
Eastbourne Park
Trustees of the
Chatsworth
Settlement
The Trustees are one of the
three main landowners within
Eastbourne Park and have an
important role in helping to
deliver the objectives of the Core
Strategy policy.
Comment noted
No change
Support welcomed
No change
Comment accepted.
Amended wording to improve
clarity is proposed.
In paragraph 4.11.2, in the
first paragraph delete “further”
and replace with
“inappropriate.
Paragraph 4.11.2
Paragraph 4.11.4
This policy is supported, as is the
acknowledgement at 4.11.1 that
the primary role of the park is as
a flood storage area to protect
the town.
It is proposed that the park "is
protected from encroachment
from further development", but
this is inconsistent with the
purpose of the policy which is to
encourage appropriate leisure
and recreational uses. Suggest
that this sentence is amended to
refer to "inappropriate"
development.
Agree that the park is an underutilised resource for leisure and
recreational uses and more could
be done within it to improve the
social and economic wellbeing of
the local community. It is
anticipated that the intention to
designate an NNR within the
park will be progressed through
These comments will be used
to inform the Eastbourne
Park SPD, which is scheduled
to go out for a period of
consultation between
September and December
2011
No change
169
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
the work on the Eastbourne Park
Supplementary Planning
Document.
Paragraph 4.11.7
Note reference to playing fields
and allotment potential but much
of the park is marshland which
would be difficult or impossible
to drain to provide playing
surfaces. Need to investigate
ground conditions.
Support the acknowledgement
that the park "provides a unique
opportunity to generate
renewable energy for the
Borough and to help it become
more self-sufficient in terms of
its overall energy requirements",
but disappointed that wind
turbines are expressly excluded.
This is the only area within the
Borough where wind turbines
are ruled out, and is inconsistent
with the identification of the park
as providing a unique
opportunity for renewable
energy, in line with the findings
of the renewable energy
potential study undertaken by
AECOM, which concluded that
the park was probably the only
location where a large-scale wind
Proposed Response
Comments will be taken into
account in the preparation of
the Eastbourne Park SPD
The issue of developing
sustainable energy
infrastructure in Eastbourne
Park is a sensitive matter in
view of the potential impact
on an area of undeveloped
green open space which is
highly visible from many
parts of the town. Although
the AECOM identified
Eastbourne Park as suitable
for wind turbines this
potential must be tempered
by considerations of the
visual and environmental
impact of large scale wind
turbines and how they would
fit with the proposals for
utilising the ecological,
archaeological and leisure
potential of the Park. Despite
the undoubted potential for
wind power generation it is
considered that this would
Recommended Change
No change
No change.
170
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
Proposed Response
turbine might be acceptable. The
Estate is currently investigating
the potential for wind energy
within the fringes of the park.
Changes in the feed-in tariff
legislation mean that wind
energy is more likely to be viable
than solar farms within the park
area.
conflict with the Councils
stated ambitions for
conserving and enhancing
Eastbourne Park.
Recommended Change
Section E: Implementing the Strategy
Policy E1: Infrastructure Delivery
ID
No.
96
Section
Paragraph
no. and
subject
Policy E1:
Infrastructure
Delivery and
para. 5.1.8
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Mrs Sarah
Harrison,
Southern
Water
Support the part of policy E1 which reads:
‘The council will work closely with utility
companies to ensure that the necessary
infrastructure to support future housing and
employment development is available or will
be provided alongside new development.
The delivery of infrastructure will be phased
to take into account the timing of new
development and availability of funding’.
Also support the reference, in policy E1, to
Eastbourne’s Infrastructure Delivery Plan
(IDP), subject to changes to the IDP which
are the subject of representations.
The entire ‘essential’ and
‘priority’ infrastructure
within the Core Strategy
is not listed as it would
be repeating information
contained in the
Infrastructure Delivery
Plan, which provides the
detail on such issues.
The enhancement of the
Waste Water Treatment
Works (WWTW) is only
one of several pieces of
priority infrastructure
It is agreed that two changes
should be made to
paragraph 5.1.8 so that the
paragraph should read:
‘Other infrastructure
requirements, such as water,
gas and electricity supply,
will be funded and provided
by utility companies and new
development. The provision
of such infrastructure would
be considered at a Boroughwide level and beyond,
171
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
(a) Southern Water is investigating options
for providing additional wastewater
treatment capacity to accommodate new
development in both Eastbourne Borough
and Wealden District. One option is to
expand Eastbourne wastewater treatment
works, which is currently operating close to
capacity. The Core Strategy should explicitly
recognise the need for additional
wastewater treatment capacity in order to
serve the development proposed within it,
and neighbouring Wealden District.
Recognition could be achieved through a
paragraph in the supporting text.
(b) Support Policy E1 which recognises the
need for adequate utility infrastructure to be
provided in time to serve the proposed
developments. This helps to ensure that a
high level of service is maintained to both
new and existing customers, and that
unsatisfactory levels of service such as
sewer flooding are prevented. OfWat, the
water industry’s economic regulator, takes
the view that enhancements required to the
local sewerage system as a result of new
development should be paid for by the
development. This ensures that the cost is
passed to those who directly benefit from it.
The planning authority should facilitate
connection at the nearest point of adequate
Proposed Response
Recommended Change
required to deliver the
spatial development
strategy and should
therefore not be singled
out in the infrastructure
chapter.
taking into consideration the
overall level of growth
proposed.’
It is agreed that
additional text should be
added to paragraph
5.1.8 to explain that
infrastructure
requirements such as
water, gas and electricity
supply, will be funded
and provided by utility
companies and the new
development. It is also
agreed that additional
text should be added to
paragraph 5.1.8 to
explain that some
infrastructure would be
considered at a Boroughwide level and beyond,
taking into consideration
the overall level of
growth proposed. This
takes account of the fact
that the consideration of
solutions to the future
172
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
capacity in planning policies to help prevent
overloading of sewers.
Propose that the first sentence of paragraph
5.1.8 is amended to emphasize that some
infrastructure must be paid for by the
development in addition to the relevant
agencies. For example: Other infrastructure
requirements, such as water, gas and
electricity supply, will be funded and
provided by utility companies and the
development.
provision of sewerage
infrastructure are taken
at a cross-boundary
level, considering growth
in both Eastbourne and
South Wealden.
Recommended Change
137
Policy E1:
Infrastructure
Delivery
Howard Moore
Infrastructure is detailed in both Policy E1
and the accompanying Infrastructure
Delivery Plan (IDP). Infrastructure planning
for the Core Strategy should accord with
Paragraphs 4.8 and 4.12 of PPS 12. Whilst
generally satisfied with the content of Policy
E1 and the IDP it is recommended that
accompanying infrastructure required to
deliver the quality bus corridors is identified
including timescales and sources of funding.
This is of particular interest to the HA as the
Eastbourne and Hailsham / Polegate corridor
has the potential to reduce the impact of
LDF development on the A27.
The Council will be
working closely with East
Sussex County Council to
ensure the content of the
Infrastructure Delivery
Plan (IDP) supporting the
Submission Version of
the Core Strategy is as
accurate as possible.
This includes as much
detail as possible on the
delivery of Quality Bus
Corridors as identified in
the IDP.
No Change
216
Policy E1:
Infrastructure
Delivery
Royal Mail
Support the principle of ensuring that the
necessary infrastructure to support future
housing and employment development is
available or will be provided alongside new
development. Support the production of an
Support Welcomed.
Add an additional sentence
to the end of paragraph
5.1.7 to read as follows:
As the Council is moving
forward with the
Community
‘The developer contributions
173
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
IDP, which is regularly updated to reflect
changing economic and other circumstances
and streams of funding if and when they
become available.
Infrastructure Levy (CIL)
and will begin working on
preparing the CIL
charging schedule, it
would be relevant to
include text relating to
the three tests identified
in Regulation 122 of the
Community
Infrastructure Levy (CIL)
in the supporting text to
the policy:
A planning obligation
may only constitute a
reason for granting
planning permission for
the development if the
obligation is:
collected must: be necessary
to make the development
acceptable in planning
terms; be directly related to
the development; and fairly
and reasonably related in
scale and kind to the
development.’
With regards to developer contributions
towards infrastructure, it is important that
the policy considers the viability and
deliverability of developments when
assessing how new infrastructure is to be
delivered and funded. Agree with the
approach to determining the level of
contributions on a site by site basis, taking
into consideration the size, neighbourhood
priorities and the impact on infrastructure
provision in the surrounding area. Request
that any contributions sought shall comply
with the five tests set out in within
government guidance (Circular 05/05) and
the Community Infrastructure Levy
Regulations 2010.
(a) necessary to make
the development
acceptable in planning
terms;
(b) directly related to the
development; and
(c) fairly and reasonably
related in scale and kind
to the development.
It would not be wise for
the wording to replicate
Regulation 122 exactly
174
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
as the regulation may
change during the
planning period of the
Core Strategy.
87b
Policy E1:
Infrastructure
Delivery
Para 5.1.6
87c
Policy E1:
Infrastructure
Delivery
Para 5.1.7
Mr Graham
Arr-Jones
(East Sussex
County
Council)
Would like a more specific reference to the
priority given to education infrastructure
provision by changing the text to read
'Community facilities, including education'
The term ‘community
facilities and services’ in
paragraph 5.1.6 is
sufficient and does not
exclude educational
facilities. Education
facilities are specifically
mentioned in paragraph
5.17.
No Change
Mr Graham
Arr-Jones
(East Sussex
County
Council)
The Children’s Services (CSD) Department
queries the validity of this statement 'the
level of contribution will be determined on a
site by site basis', particularly if it refers to
the kind of 'tariff' approach set out in
Appendix D of the IDP. The overall level of
contributions needed to meet infrastructure
costs should be determined strategically at
a borough-wide level and this in turn will
determine the level of CIL levied on
individual developments.
The level of contribution
will be determined on a
site by site basis, but the
Community
Infrastructure Levy (CIL)
will be the starting point
for developer
contributions based on
Borough-wide
infrastructure needs.
Other site specific
developer contributions
may be required and
secured through planning
obligations.
See proposed changes to
Infrastructure Delivery Plan.
The Council accept that
175
ID
No.
239
Section
Paragraph
no. and
subject
Policy E1:
Infrastructure
Delivery
Respondent
Wealden
District Council
Summary of Representation/Comment
Request that specific and clear reference be
made in the final Strategy to the need for all
growth to contribute as appropriate to any
cross boundary infrastructure requirements
and alignment with Wealden’s Core Strategy
- particularly those interventions and
improvements identified in our joint South
Wealden and Eastbourne Transport Study
(SWETS).
The specific inclusion and reference to
contributions being sought from all housing
growth to address cross boundary
infrastructure needs - particularly SWETS
interventions, and also where relevant the
servicing of employment land - within the
Infrastructure Delivery Plan/ Core Strategy.
Proposed Response
the IDP will need to be
amended to remove the
references to the current
level of contributions
required through new
development, as these
will considerably change
through the CIL
approach.
These issues will be
resolved through the
general revisions made
to the Infrastructure
Delivery Plan.
The supporting
Infrastructure Delivery
Plan discusses in detail
all of the cross-boundary
infrastructure issues and
requirements for
Eastbourne and the
South Wealden area.
It is accepted that the
supporting text should
make it clear that
developer contributions
will be sought to address
cross-boundary
infrastructure needs as
well.
Recommended Change
Clarification that developer
contributions will be sought
to address cross-boundary
infrastructure needs will be
made in the general
revisions to the IDP.
Add an additional sentence
after the first sentence of
paragraph 5.1.7 of the Core
Strategy to state:
“Developer contributions will
also be sought to address
cross-boundary
infrastructure needs for
Eastbourne and South
Wealden.”
176
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Infrastructure Delivery Plan
ID
No.
IDP1
Section
Paragraph
no. and
subject
Figure 9,
Eastbourne
Infrastructure
Priorities (p
42)
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Sarah Harrison,
Southern Water
Would like to see amendment of
Infrastructure Priority 6 as follows:
o In the left-hand column, the current text
could be clarified by reading: ‘Southern
Water has secured consent to increase
the discharge capacity of Eastbourne
Wastewater Treatment Works’. And an
additional sentence could be added
reading: ‘A feasibility study to
investigate options for providing
additional treatment capacity to
accommodate new development in
Eastbourne and the south of Wealden
District is being carried out by Southern
Water. One option would be to increase
the capacity of the WTW. This would
require an extension of the underground
box to accommodate additional plant
and equipment.’
o In the right-hand column, the addition of
the words ‘and beyond’ after ‘in The
Borough’. As described at paragraph
8.56 of the IDP, a high level of housing
Accept the representation
as the most up-to-date
information; therefore the
IDP should be amended
accordingly.
Amend the Infrastructure
Priority section of IDP so that
Figure 9 – Eastbourne
Infrastructure Priorities (IP)
2010-2014, IP6 ‘Increased
Capacity of Wastewater
Treatment Works’ so that it
reads as follows:
Infrastructure
Requirement (Left
column)
Southern Water has secured
consent to increase the
discharge capacity of
Eastbourne Wastewater
Treatment Works. A
feasibility study to investigate
options for providing
additional treatment capacity
to accommodate new
development in Eastbourne
and the South of Wealden
177
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
is proposed in South Wealden and as a
result Southern Water will be
considering the Eastbourne/Hailsham
areas in combination to determine the
optimal solution.
IDP2
Appendix D:
Developer
Contributions
, D4 Water
(p58)
Sarah Harrison,
Southern Water
Row D4 of the table should read ‘Water
and wastewater’.
Amend the text in the box below this to
read:
“Local infrastructure (e.g. underground
sewage pipes): New developments will be
required to connect to the nearest point of
adequate capacity. This is likely to require
off-site infrastructure and will add to the
cost of the development.”
Recommended Change
District is being carried out
by Southern Water.
Explanation (Right
column)
Provision of an
additional/extended sewage
plant at the Wastewater
Treatment Works to cater for
future population and
housing growth and ensure
effective management of
wastewater in the Borough
and beyond.
Agree the proposed
amendments. However,
the whole of appendix D
and E is to be removed
from the IDP as it is
based on developer
contributions currently
collected through the
Section 106 process and
not the emerging
Community Infrastructure
Levy.
No further changes required
Southern Water has limited powers to
prevent connections, particularly on
previously developed land. This is the case
even when capacity is insufficient.
178
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
The Council supports the
proposed amendments.
However, the whole of
appendix D and E is to be
removed from the IDP as
it is based on developer
contributions currently
collected through the
Section 106 process and
not the emerging
Community Infrastructure
Levy.
No further changes required
Therefore look to the planning authority to
facilitate connection at the nearest point of
capacity for water and wastewater in
planning policies. This will help to prevent
reduced levels of service to new and
existing customers, for example poor water
pressure or increased risk of flooding.
IDP3
Appendix D:
Developer
Contributions
, D4 Water
(p58)
Southern Water
This also provides early warning to
developers, which is the key to ensuring
that necessary local infrastructure is
provided.
The text in the box below could also
include the following:
“Strategic infrastructure (e.g. treatment
works): Funded by water companies but
can involve long lead times partly due to
the OfWat periodic review process which
takes place every 5 years.”
Southern Water is currently investigating
options for providing additional wastewater
treatment capacity. Options are to expand
Eastbourne wastewater treatment works,
constructing a new wastewater treatment
works on a new site with a new discharge
point, or extending an existing wastewater
treatment works and transferring part of
the treated effluent to a new discharge
point.
A new discharge point would require
179
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
The Council supports the
proposed amendments.
However, the whole of
appendix D and E is to be
removed from the IDP as
it is based on developer
contributions currently
collected through the
Section 106 process and
not the emerging
Community Infrastructure
Levy.
The Council supports the
proposed amendments.
However, the whole of
appendix D and E is to be
removed from the IDP as
it is based on developer
contributions currently
collected through the
Section 106 process and
not the emerging
Community Infrastructure
Levy.
The Council appreciate
that the assessment of
developer contributions in
No further changes required
permission to discharge from the
Environment Agency. If a new works is
required, planning permission would be
required from East Sussex County Council.
IDP4
Appendix E,
Expected
Developer
Contributions
By
Neighbourhoo
d, (1)
Neighbourhoo
d 1: Town
Centre (p63)
Sarah Harrison,
Southern Water
IDP5
Appendix E,
Expected
Developer
Contributions
By
Neighbourhoo
d
Southern Water
The infrastructure requirements for the
remaining neighbourhoods requires
clarification. At D4 the type of service
should read ‘Water and wastewater’. In
the box below, the text: ‘and spending
allocated’ should be deleted. Southern
Water has not allocated spending but
rather looks to the development to pay for
the cost of enhancements to the local
sewerage system.
IDP6
Appendix D:
Developer
Contributions
East Sussex
County Council,
Children’s
Major concern with the IDP is with
Appendix D. Appendix D estimates the
contribution from LDF development
the infrastructure requirements for the
Town Centre Neighbourhood need
amending. At D4 the type of service
should read ‘Water and wastewater’. And
the text below, in the left hand column,
should read:
‘Capacity issues identified and spending on
flood alleviation scheme in Terminus Road
allocated.’
No further changes required
Remove Appendix D and E in
their currents state and
replace with one appendix
180
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Services
Department
towards infrastructure provision, including
schools. To do this it uses the current DfE
based Cost Multipliers used in s106
agreements. The problems are:
the Infrastructure
Delivery Plan was only a
crude analysis of the
money that could be
collected towards
educational facilities
based on existing S106
arrangements. It is
agreed that both
Appendix D and E will be
removed in their current
form, and will be replaced
by an appendix which
summarises the
infrastructure
requirements for each
neighbourhood.
which summarises the
infrastructure requirements
for each of the Borough’s 14
neighbourhoods. This is being
prepared as part of the
general revisions to the
Infrastructure Delivery Plan.
1. These cost multipliers significantly
underestimate the true costs of providing
school places
2. The approach runs counter to what was
assumed would be the approach used to
determine CIL (i.e. estimate global actual
costs then estimate funding available from
other sources, with funding from
development bridging the gap)
3. The calculations used assume that all
the dwellings built will be flats, when EBC's
own estimates reveal there will be a
significant number of houses.
Very concerned that the above 'tariff'
approach (and the assumptions contained
within it) could leave us with a massive
funding shortfall for additional school
places
Additionally EBC have used ESCC's very
rough approximations of our School Place
Planning Areas to their Neighbourhoods to
make statements in Appendix D about
which neighbourhoods ESCC will be looking
to locate new/expanded schools in and
which neighbourhoods we won't. This is
181
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
misleading and could constrain ESCC's
future plans for increased provision in the
Borough.
For the above reasons we would like
Appendix D taken out of the Document
pending further discussions.
IDP7
Section 8:
Infrastructure
Requirements
: Part F Transport
East Sussex
County Council,
Transport
Department
Welcome the support for the LTP3 specific
transport objectives which are cited as
aspirations of Eastbourne’s Core Strategy
and the IDP.
Support welcomed
No Change
IDP8
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F1 - Walking
East Sussex
County Council,
Transport
Department
Note the recognition of ESCC Walking
Strategy.
Support welcomed
No Change
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F2 - Cycling
East Sussex
County Council,
Transport
Department
Whilst ESCC has responsibility for the
physical delivery of new on-road cycle
routes and routes adjacent to the highway,
EBC would be responsible for new off-road
routes along the seafront or through
existing parks/green spaces.
It is agreed that reference
should be made to the
joint responsibility of
ESCC and Eastbourne
Borough Council for the
delivery of new cycle
routes. Further text will
also be required to
explain how the cycling
network should link into
the South Wealden area
The following amendments
should be made to the IDP:
IDP9
Support the principle of creating new
walkways, opening up Eastbourne Park to
the wider community.
Would like to see reference to the need to
consider wider links into the south
Wealden area including
Willingdon/Polegate, Hailsham and the
Add the following two
sentences to para. 8.120:
… Eastbourne Borough
Council is also responsible for
the delivery of off-road
routes including those
through existing parks and
green spaces.
182
ID
No.
IDP1
0
IDP1
1
IDP1
2
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Stone Cross, Westham and Pevensey area.
The network of cycle routes will also need
to provide localised links to enable access
to the wider National Cycle Network (NCN)
route towards Bexhill/Hastings and the
NCN Route 21 via Polegate and the Cuckoo
Trail to Hailsham/Heathfield.
and provide access to the
wider National Cycle
Network (NCN).
Recommended Change
…Eastbourne’s expanded
cycle network will link into
South Wealden and will
provide access to the wider
National Cycle Network
(NCN).
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F3 – Smarter
Choices
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F4 - Buses
East Sussex
County Council,
Transport
Department
Welcome the support for joint working with
ESCC on smarter choices initiatives
through the Travel choice branding.
Support welcomed
No change
East Sussex
County Council,
Transport
Department
Welcome reference to the four Quality Bus
Corridors and the development of the Bus
Quality Partnership for Eastbourne.
Support welcomed. Real
Time Passenger
Information should be
referred to specifically in
paragraph 8.130
Amend the first sentence of
paragraph 8.130 to read:
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F5 - Rail
East Sussex
County Council,
Transport
Department
Would like to see reference to reinstating
the Willingdon Chord within the Core
Strategy and IDP on the proviso that there
would be no reduction in the existing rail
passenger service to Eastbourne.
Strongly agree that improvements to the
connectivity within the whole bus network
of Eastbourne and South Wealden is
important.
Can anything be added here about Real
Time Passenger Information?
The Council do not
support the reinstatement
of the Willingdon Chord
because of the potential
for a reduction in the
service provision for
‘The promotion of bus
services will be achieved by
providing relevant, high
quality passenger transport
information in advance at the
time of the journey, such as
Real Time Passenger
Information’
No Change
183
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
In the response to Network Rail's Sussex
RUS consultation, we stated: 'One option
assessed in the RUS was to reinstate the
chord, with an additional hourly service
between Brighton and Ashford. This option
would retain the existing and well utilised
service to Eastbourne, with an additional
(faster) service between these Regional
Hubs. This would reduce journey times
between Brighton and Ashford, which
would be of benefit to visitors and
residents, including those from the Bexhill
area.
Unfortunately this option was discounted,
citing 'insufficient demand to justify the
additional service and construction costs'.
Eastbourne and objected
to LTP3 on this point. The
Council also believe that
the rail link is not
deliverable and is not
supported any Network
Rail. The IDP lists
infrastructure
improvements which are
considered deliverable
and which have been
committed for delivery by
Network Rail. The
investigation of the
feasibility of a new station
at Stone Cross has been
referenced in the IDP.
In addition to the passenger benefits which
would be achieved through reinstating the
Willingdon Chord, there are also freight
benefits enabling the sustainable
transportation of freight on rail along the
East Coastway strengthening the economy,
reducing road based vehicular journeys
and leading to a reduction in carbon
emissions and road congestion.
Recommended Change
The electrification and
dual tracking of the
Ashford – Hastings route
is considered too far
outside of the Borough to
be explicitly referenced in
the Infrastructure
Delivery Plan.
Would like to see a new station in the
Stone Cross/Polegate locality, and also at
Glyne Gap. Additionally, reference should
be made to the dual tracking and
electrification of the Ashford-Hastings rail
184
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
capacity improvements.
IDP1
3
IDP1
4
IDP1
5
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F6 - Parking
Section 8:
Infrastructure
Requirements
: Part F –
Transport
F7 – Road
Network
East Sussex
County Council,
Transport
Department
Welcome recognition that parking controls
are important for maintaining traffic flows
especially for buses in the town centre.
Support welcome
No change
East Sussex
County Council,
Transport
Department
Welcome reference to the SWETS study.
Support welcome
No change
Section 9:
Infrastructure
Priorities
East Sussex
County Council,
Transport
Department
Support the inclusion of “IP8 Expansion of
the Eastbourne Cycle Network”, specifically
to develop the Horsey Sewer cycle route
and seafront route, to be supported by an
emerging Borough wide Cycling Strategy.
This contributes in some way to most of
the LTP3 Specific Transport Objectives.
Support welcomed. It is
agreed that reference to
measures towards
expanding Eastbourne’s
Cycle Network will be
dependent on secured
funding through
developer contributions.
Add the following sentence to
the explanation column of IP8
Expansion of the Eastbourne
Cycle Network:
Welcome the statement that the previously
safeguarded routes identified across
Eastbourne Park will not be brought
forward through Eastbourne’s LDF,
following SWETS which confirmed that no
new roads are required within Eastbourne
to cater for future population growth. The
recommendation to formally rescind these
highway schemes was approved, with the
exception of the St Anthony’s Link, by
ESCC Transport & Environment Lead
Member at his decision-making meeting on
31 January 2011.
‘Development of Eastbourne’s
Cycle Network is dependent
on securing funding through
185
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Note that “The implementation of
Eastbourne’s Cycling Strategy, ensuring
that new cycle routes are provided across
the Borough” has been identified as an
important requirement. Recommend that it
is stated that development of the cycling
network is dependent on securing funding
through the development contribution
process.
This can added to the
‘explanation’ column of
the table.
the development contribution
process and other funding
streams.’
Support welcomed
No Change
It is accepted that
delivery of the entire
cycle network will not be
The following changes should
be made to the Infrastructure
Delivery Schedule:
Support “The implementation of a
borough-wide Parking Strategy to identify
future changes to parking measures across
the Borough”.
IDP1
6
Section 10:
CrossBoundary
Infrastructure
Issues
East Sussex
County Council,
Transport
Department
Strongly agree that improvements to road
infrastructure are considered at a wider
level than administrative boundaries, and
take account of complex patterns of
movement and levels of usage.
Strongly agree that Highways Agency
improvements to the trunk road network
north of the Borough will be required to
cater for increased levels of strategic traffic
movements in that area and those financial
contributions may be required by both
South Wealden and Eastbourne.
IDP1
7
Section 11:
Infrastructure
Delivery
East Sussex
County Council,
Transport
In the Cycle Routes section, ‘Timing’
column, it states “delivery of the new cycle
network is prioritised between 2010-2014”.
186
ID
No.
Section
Paragraph
no. and
subject
Schedule
(p51)
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Department
This is too short a timescale and it would
be unrealistic to deliver a whole network in
this period. Recommend this to be
amended to “deliver a core network of
routes”.
secured in the short term.
The timescales for
delivery related
specifically to the delivery
of the first stage of the
cycle network only. This
needs to be made clear in
the Infrastructure
Delivery Schedule.
Transport Interventions
Status of Scheme – to read
‘Concept Plans’
Timing – to read
‘Delivery of key junction
improvements are prioritised
in the medium term (20152019)
In the Transport Interventions section (Key
Junction Improvements), the ‘Status of
Scheme’ and ‘Timing’ columns incorrectly
refer to the Allotment Strategy and
therefore need amending.
An amendment is
required to take out
reference to ‘allotment
plots’ in the ‘timing’ and
‘status of scheme’ column
which were made in error.
New wording is required
in these columns
Cycle Routes
Timing – to read
‘Delivery of the first stage of
the Cycle Network is
prioritised in the short term,
within the next 5 years
(2010-2014). Further
enhancements to the cycle
network will be delivered
later on in the planning
period. ’
IDP1
8
IDP General
Comment
East Sussex
County Council,
Transport
Department
Would like to see a statement early in the
IDP that acknowledges the recent changes
in government will affect the public sector
funding streams and service delivery and
therefore the delivery of the IDP. The IDP
will need to be reviewed regularly in light
of these changes.
An additional sentence
should be added to the
first section of the
Infrastructure Delivery
Plan.
Add an additional sentence to
paragraph 1.6 to read:
‘Changes in government may
affect public sector funding
streams and service delivery.
The IDP will need to be
reviewed regularly in light of
these changes.’
IDP1
Section 8:
East Sussex
Para. 8.63 states that no applications for
It is accepted that further
Add an additional sentence to
187
ID
No.
9
IDP2
0
Section
Paragraph
no. and
subject
Infrastructure
Requirements
Part D –
Utilities,
Waste and
Flooding, D5
- Waste
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
County Council,
Waste and
Minerals LDF
Team
new waste facilities are anticipated in the
next 5 years (up to 2014). Whilst this may
be the case for facilities catering for
Municipal Solid Waste, there is an ongoing
need for new facilities to provide capacity
to enable landfill diversion of Commercial &
Industrial waste. The majority of
Eastbourne is identified as an area of
search for such facilities in the ‘East
Sussex and Brighton & Hove Waste and
Minerals Core Strategy – Preferred
Strategy’, and as such the possibility of
applications for new facilities within the
town cannot be ruled out.
text is required to explain
the need to look for sites
for landfill diversion of
commercial and industrial
waste. The recommended
text should be added to
the IDP.
paragraph 8.63 to read:
‘There is an ongoing need for
new facilities to provide
capacity to enable landfill
diversion of commercial and
industrial waste. The majority
of Eastbourne is identified as
an area of search for such
facilities in the ‘East Sussex
and Brighton & Hove Waste
and Minerals Core Strategy –
Preferred Strategy’
Section 8:
Infrastructure
Requirements
Minerals
East Sussex
County Council,
Waste and
Minerals LDF
Team
This marina area at Sovereign Harbour was
identified in the Minerals Local Plan as a
site where aggregates could be extracted
in conjunction with the new excavated
marina water areas. For the purposes of
providing minerals in the MLP the
Sovereign Harbour site has been
completed. However, the EBP p61 sets out
a vision for Sovereign Harbour involving
various elements of development. The
extent of the remaining aggregates
reserves (if any) underlying this site are
not known but a policy requirement to
utilise and/or extract any arising from the
new development would be supported in
accordance with the emerging Waste and
Minerals Core Strategy objectives, in
It is accepted that
reference will be made in
the IDP to a required
need for waste and
mineral resources along
with reference to the
Waste and Minerals
Development Framework
proposals. Clear reference
will also be made in the
flood defences section
To the use of recycled
beach shingle for beach
replenishment.
Reference to waste and
minerals as well as flooding
defences will be made during
the general revisions to the
IDP.
The Sustainable Design SPD
will cover in detail the issues
raised with regards to the
recycling of materials in the
representation.
The recycling of materials
in construction and
188
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
particular SO2, the draft of which states
“To achieve prudent and efficient use of
minerals, having regard to the market
demand and supply restrictions in East
Sussex and Brighton & Hove, and to
recognise waste as a resource in order to
reduce local demands on waste, energy,
land and primary raw materials including
soil and minerals.”
through mineral
extraction is a matter
which is too detailed for
discussion in the Core
Strategy. The Council has
begun work on a
Sustainable Design
Supplementary Planning
Document (SPD) which
will cover such as issues
as detailed in the
representation.
KSO1 and 9 require sustainable
construction methods and are therefore
supported. It is noted that Policy D1 and
supporting text give more detail as to how
these will be implemented. Whilst many
aspects of sustainable development are
covered there does not appear to be any
mention of using recycled materials e.g.
aggregates, bricks and other materials.
While this may be covered by BREEAM or
the Code for Sustainable homes it would
be desirable to state it in the text.
IDP2
1
Section 8 – F
Transport
Wealden District
Council
Pleased the Core Strategy is supported by
an Infrastructure delivery plan and
schedule. Welcome the acknowledgment of
cross boundary issues regarding
infrastructure delivery and look forward to
further dialogue and collaborative working
in relation to these issues and in relation to
the development of a CIL charging
schedule.
Support welcomed.
Continued joint working
on the IDP and
infrastructure
requirements with
Wealden District Council
is essential, especially for
cross boundary issues
such as transport
Recommended Change
The following amendments
will be made to IDP to take
account of the representation
made. They will be made
during the general revisions
made to the IDP:
•
Clearer reference to the
cross-boundary
189
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
However, although reference is made to
the SWETS study and interventions in the
transport narrative section of the IDP
(para. 8.141 - para. 8.145), the particular
SWET interventions and requirements are
not included within the Borough wide
Infrastructure Schedule nor within any of
the neighbourhood infrastructure
schedules. Concerned that the SWETS
items may be 'lost' in negotiations with
developers for contributions.
A firmer emphasis and statement within
the IDP and Core Strategy as to how these
essential physical infrastructure items will
be approached in relation to collecting
developer contributions and developing
CIL, and confirmation that are intended to
be part of the IDP and Core Strategy
delivery, would be very welcome.
The focus in the Infrastructure Schedules
(including the Green Infrastructure
schedule) at the Borough wide and local
infrastructure level provides a clear
indication of requirements, provision and
timescale for most of the infrastructure
elements. Support the further development
of these schedules as part of CIL.
Proposed Response
Recommended Change
infrastructure.
The SWET interventions
to be delivered inside the
Borough are currently
accounted for in the
Infrastructure Schedule.
It is agreed that it would
be wise to include
reference to the strategic
infrastructure required in
South Wealden within the
Schedule which would
also benefit the Borough.
The neighbourhood
sections of the IDP are
being rewritten, therefore
reference to any transport
infrastructure required in
specific neighbourhoods
will be provided in the
revised text.
•
•
infrastructure
requirements and the
delivery of transport
interventions in the
South Wealden area
within the transport
section of the IDP;
Specific mention of the
transport interventions
required in each of the
Borough’s 14
neighbourhoods;
Clear mention of the
cross-boundary
infrastructure
requirements in the
Infrastructure Delivery
Schedule.
Amendments to ‘Section
E: Implementing the
Strategy’ of the Core
Strategy will be covered
in the relevant section of
representations.
190
ID
No.
Section
Paragraph
no. and
subject
Respondent
Summary of Representation/Comment
Proposed Response
Recommended Change
Appendices
Appendix B: Monitoring Framework
ID
No.
99/
100
Section
Paragraph no.
and subject
Appendix B:
Monitoring
Framework
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Mr. Derrick
Coffee
East Sussex
Transport 2000
Sustainable Travel Indicators - it
would be useful to know the
breakdown of journeys to work
by all modes; and the Travel
Plan indicator would be more
useful if it also included the
number of Travel Plans actually
operating following completion of
a development. A further piece
of information that could be
usefully included is on traffic
volumes on key routes in town.
Origin/destination data would be
very informative* as would
journey purpose data.
In order to calculate the
percentage of journeys to
work undertaken by
sustainable modes, a
breakdown of journeys to
work by all modes is required
therefore this information will
be collected by the Council
from statistics prepared by
East Sussex County Council.
No change
Origin/destination data has
been collected to assist in the
policy recommendations of
key evidence reports such as
the Council’s Transport
191
ID
No.
129
Section
Paragraph no.
and subject
Appendix B:
Monitoring
Framework
Respondent
Ms Hannah
Mears
Planning Liaison
Officer
Environment
Agency
Summary of
Representation/Comment
Proposed Response
*Stats are available from the
recent WSP parking survey and
to a great extent, could be made
public by limited post code
information.
Assessment and the Housing
Market Assessment. When
these documents are
reviewed, further research
will be undertaken for the
evidence document. There is
therefore no requirement to
monitor these on a regular
basis.
It is recognised that some of
the indicators proposed do
not directly relate to the
targets or policy objectives,
but it is essential to use
monitoring mechanisms that
are already in place. To
effectively monitor the target
of creating ‘a diverse and
multi-functional network of
green space’ an additional
indicator is required which
will monitor the amount of
net open space which is
created by new development.
Recommend amending the
indicators for biodiversity. The
indicators suggested for
monitoring Policy D9: Natural
Environment would not help do
this. For example, the number of
planning applications decided in
line with our advice on flood risk
would not help measure
achievement. Objective 7: A
diverse and multi-functional
network of green space.
Reference to Policies as ‘B’s and
not ‘D’s in your Monitoring
chapter. Please amend this to
help cross referencing.
Recommended Change
A further indicator should be
added to the Natural
Environment section to read:
The amount of net open space
which is created by new
development. This will be
informed by regular reviews of
all open space resources in the
Borough.
Core Strategy policy ‘Economy’
through to ‘Eastbourne Park’
should be referenced as D
policies not B policies. C1
Infrastructure Delivery should
be referenced as E1.
Sustainability Appraisal
ID
No.
SA1
Section
Paragraph no.
and subject
Sustainability
Appraisal
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
Jo Clarke
Natural
All references to the “Sussex
Downs Area of Outstanding
Agreed. Reference to the
Sussex Downs ANOB
Amend Sustainability
Objective 12: Conserve and
192
ID
No.
SA2
Section
Paragraph no.
and subject
Sustainability
Appraisal
Respondent
Summary of
Representation/Comment
Proposed Response
Recommended Change
England
Natural Beauty (AONB)” should
be amended to the “South
Downs National Park”, Strongly
support the proposed addition
of “landscape and species’
sustainability” to objective 12
(Key Task A2.1.)
Recommend the adding of
ancient woodland as an
important indicator.
Wealden District Council has
prepared an AA for the
Pevensey Levels which should
be cross referenced in the SA.
should be amended.
‘Landscape and Species’
should be added to the
sustainability objective
and an indicator for
Ancient Woodland should
be included.
enhance the Borough’s
biodiversity, landscape and
species’ sustainably.
It is not felt necessary to
cross-reference the AA,
because it was considered
that any affect on the
Pevensey Levels as a
result of development
would only come from
Wealden, thus not entirely
relevant to Eastbourne.
Sustainability Objectives:
Accessible greenspace and
Biodiversity enhancement:
… Existing green spaces
need to be protected from
development and
biodiversity should be
protected and enhanced
where possible.
Hannah Mears
Environment
Agency
Page 16: Effective Protection of
the Environment: Accessible
Greenspace and Biodiversity
Enhancement. The text under
this heading would benefit from
recognising the protection and
enhancement of biodiversity.
Areas at Risk of Flooding: The
final sentence conflicts with PPS
25: Development and Flood
Risk. This paragraph should
recognise the need for the
Sequential Test to be applied to
direct development away from
areas at risk of flooding.
Support the introduction of SA
objective 16 to maintain and
All other suggestions for
changes are accepted and
revised wording is
proposed.
Areas at risk of flooding:
Remove The precautionary
principle should be applied
to further development on
the floodplain replace with
The Sequential Test should
be applied to direct
development away from
areas at risk of flooding.
Should sites identified in
Flood Zones 2 or 3 be
justified for development by
this evidence, the Exception
193
ID
No.
Section
Paragraph no.
and subject
Respondent
Summary of
Representation/Comment
improve water quality in
Eastbourne. This could be
strengthened to be fully
consistent with the aims of the
South East River basin
Management Plan.
Proposed Response
Recommended Change
Test should then be applied
to make sure the
development is safe and
will not increase flood risk
elsewhere.
194
Appendix B2: Neighbourhood Event Responses
Summary of Comments made at Neighbourhood Consultation Events
Section of
Eastbourne Plan
A1 Portrait of
Eastbourne
A2 Spatial Vision
Comments
•
A3 Key Issues
•
A4 Spatial
Objectives
B1 Spatial
Development
Strategy
•
•
•
•
•
•
•
•
•
B2 Creating
Sustainable
Neighbourhoods
•
•
•
•
•
•
•
•
B3 Key Diagram
•
Creating a plan to 2027 is unwise because nobody can predict that
far ahead
The Eastbourne Plan needs to take more account of development
on the outskirts of Eastbourne in Wealden as these developments
will use Eastbourne's services and facilities
The Eastbourne Plan won't achieve its objectives because there are
too many of them
The high reliance on ‘windfall’ sites suggests that the Council
would encourage back gardens development
It would be better to regenerate and use existing empty housing
stock, particularly in the Town Centre, than build new ones
Some brownfield sites are overcrowded and overdeveloped and
this in turn creates social problems
Greenfield sites should be protected to prevent any further housing
development on them
There is too much housing in some neighbourhoods. Development
should be concentrated in other neighbourhoods
Eastbourne is already over populated and there are too many
people here. The existing services and infrastructure in Eastbourne
cannot support any additional growth
Where did the housing target come from? Councils are no longer
required to comply with regional plans and the number of units
should be based on local need and residents expectations
There is no need for additional housing in Eastbourne to meet the
needs of local people as deaths in the Borough vastly outnumber
births
The Sustainability Ranking for Sovereign Harbour is not accurate
because the community facilities and play areas in Kingsmere are
not accessible to people from Sovereign Harbour
Sovereign Harbour is not a sustainable neighbourhood as it doesn't
have the necessary facilities
A short paragraph is needed to describe what an unsustainable
neighbourhood would look like
A 'lack of affordable housing' is not a weakness for a
neighbourhood
If the Eastbourne Plan is neighbourhood-based, shouldn’t each
neighbourhood have a shopping centre/store related district
There should be no additional housing should be built in the least
sustainable communities
The Eastbourne Plan aims to reduce the standards of the best
parts of Eastbourne rather than improve the poorest parts
By definition, the further a neighbourhood is from town centre, the
less sustainable it is. There is potential for greater investment in
those neighbourhoods to the detriment of more ‘sustainable’
centrally located ones
Neighbourhood boundaries can be confusing and all housing in one
road should be within same neighbourhood
195
•
C Localism: A
Neighbourhood
Approach
•
C1 Town Centre
•
•
•
•
•
•
•
•
•
•
•
•
C2 Upperton
•
•
•
•
C3 Seaside
•
•
•
•
C4 Old Town
•
•
•
•
There is an area of land to the east of the town behind Langney
Sports which is being ignored for housing development.
The neighbourhood approach must be employed in how services
are delivered and in how people can engage in decision making. It
is not sufficient to adopt it only as a plan principle
The problem with the neighbourhood approach is town-wide issues
(e.g. cycle paths) will be ignored. The neighbourhoods need to be
linked and joined up planning should be part of each
neighbourhood’s strategy
Parking restrictions in the Town Centre should be removed in order
to increase trade
The Town Centre needs more trees, parks and green spaces
Can we have more secure cycle parking and cycle lane from
station all along Terminus Road?
The Shopping and retail outlets in the Town Centre are too spread
out and should be more contained into a proper shopping centre
The Town Centre shopping area needs to be improved to attract
more major retailers as the façade looks run-down and shabby
The Town Centre redevelopment should concentrate on
specialist/local shops rather than extending the Arndale Centre
The statue of the grenadier is wasted in Cavendish Place. It should
be re-site it at the pedestrianised end of Terminus Road
The Seafront is extremely attractive but links with town centre are
a disaster. The top end of Terminus Road needs to be improved
There needs to be more pedestrianisation in the Town Centre and
Seafront to make it safer to pedestrians and cyclists
The role of Hyde Gardens needs to be established - is it gardens or
car park?
Why can’t the buses use the covered parking area at Railway
Station and Terminus Road be pedestrianised?
Action should be taken to deal with the rat-run through Upperton
There is not enough shops in Upperton neighbourhood
The Upperton neighbourhood should be extended to include the
area around Crown Street as this gives a great sense of
community, trade culture and a sense of diversity to the area
Too many blocks of flats have been granted in Upperton already
and the area is at risk of becoming a concrete jungle
There is significant congestion on Seaside, particularly at the
Seaside roundabout. It needs to be made safer for cyclists and
pedestrians
Although there are many shops in Seaside they are mainly
businesses and services. There is a need for more food shops and
fewer takeaways
There are unattractive structures around the Redoubt. If these
were to be removed it would improve tourism
The creation of a Quality Bus Corridor in Seaside will create more
congestion
Better parking is required by Green Street shops to ensure
economic development within the area
Longland Road Recreation Ground in Old Town needs to be
protected from development
There is a need for more pedestrian crossing on Victoria Drive as it
is very dangerous for young people to walk to school on such a
busy road
The facilities at Gildredge Park need to be improved. The provision
of a new car park to the refurbished tennis courts at the entrance
to Gildredge Park will encourage younger generations to use the
196
•
•
C5 Ocklynge &
Rodmill
•
•
•
•
C6 Roselands &
Bridgemere
C7 Hampden Park
•
•
•
•
C8 Langney
C9 Shinewater &
North Langney
C10 Summerdown
& Saffrons
C11 Meads
•
•
•
•
•
•
•
•
C12 Ratton &
Willingdon Village
C13 St Anthony’s
& Langney Point
C14 Sovereign
•
•
•
•
•
•
•
facilities
There is a need for more facilities and activities for young people
to do in Old Town
The quality of Bus Service in Old Town (especially Cherry Garden
Road and Hill Road) is not good enough
The Hospital roundabout cannot sustain any more traffic,
particularly at peak times. Its needs to be made safe
Rodmill residents feel let down by the proposed Kings Drive
development
There should be no more housing built in Ocklynge & Rodmill as
the Kings Drive development will already increase housing
significantly
Cycling around the Hospital roundabout is dangerous and more
crossing points are needed
The old Toyota Garage site in Churchdale Road needs to be
redeveloped
Improved signage is required around Hampden Park railway
station to encourage people to use trains, walk and cycle
Any additional housing in Hampden Park will increase the problems
of traffic at the railway crossing
Hampden Park and associated sports fields should be protected
from development
Summerdown and Saffrons need to be considered separately as
they are intrinsically different
Parking is a problem in Meads
Issue of students creating litter and noise in Meads
There should be no more additions or buildings for Brighton
University in Meads
Grange Gardens is an unused/neglected green space which should
be open for the community
Houses in Meads from 1930s should be protected as well as those
which are already 100 years old
Meads has its distinct character because of the lack of low cost
housing. The provision of affordable housing is in conflict with the
continuation of the existing ambience in a conservation area
There is too much housing development planned for Meads. This
will result in more 'garden grabbing' and development on green
land, and adversely affect the Conservation Area
The amenity grass/woodland on Woodland Avenue should be
protected
Cars use Ratton as a rat-run to avoid A2270
Access to a Secondary School from St Anthony’s & Langney Point
is difficult. The closest is Bishop Bell and this school is difficult to
get into
The Biodiversity Map at the Sovereign neighbourhood event
identifies an area of woodland on the beach.
The public realm in Sovereign Harbour needs to be improved
through more trees and greenery
There are parking problems in Sovereign Harbour. An area is
required for vans to park to remove them from roads and housing
areas
Sovereign Harbour is already overdeveloped. No more housing
197
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
D1 Sustainable
Development
•
•
•
•
should be considered in the neighbourhood because it would not
be sustainable
There is not enough play areas for children in Sovereign Harbour
and the garden areas are marked no ball games.
There is too much traffic on Atlantic Drive and further housing will
increase this. Traffic calming measures are required
There is no desire for a hotel in Sovereign Harbour. A park with a
café and amenities on the beach would be better
The development of further housing in Sovereign Harbour will
mean that there will be no room for tourism development
Where are the housing sites in Sovereign neighbourhood going to
be located?
We need a link road from the South Harbour to the North Harbour
to improve access
Additional family homes are needed in Sovereign Harbour, not flats
The community infrastructure needs to be in place before any
additional housing development in Sovereign Harbour is allowed
A range of smaller, individual shops would be most welcome in
Sovereign Harbour, especially at the Waterfront
There are enough shops in Sovereign Harbour and there is no need
for any more
The high number of empty flats and second and holiday homes at
Sovereign Harbour means that there is no need for any additional
housing development
The Haven School in Sovereign Harbour will be unable to take the
extra children from the additional housing development
How will 150 new residential units in Sovereign Harbour fund the
delivery of the essential community infrastructure? The developer
contributions would be insufficient
The housing in Sovereign Harbour is already 'affordable' due to the
drop in house prices. There is no need for any more
The Martello Towers at Sovereign Harbour are not being properly
maintained. They should be converted for community uses
Kingsmere should not be included in the same neighbourhood as
Sovereign Harbour as there is no links between the areas
Why can't the Dotto Train run all the way into Sovereign Harbour?
There is a need for more dog bins in Sovereign Harbour
The Council Tax gained from the housing in Sovereign Harbour
should be used to pay for the creation of community facilities in
the neighbourhood
The Council Tax bandings in Sovereign Harbour are too high and
inconsistent, especially compared to other areas of the town
A cross-Harbour bus service is urgently required
There are a lack of buses serving Sovereign Harbour and are at
inconvenient times
The Biodiversity Map at the Sovereign Neighbourhood Event
identified 'amenity green space' in private development. This is in
a private gated development and is not open to the general public
I would prefer no new community facilities if it means no new
housing development in Sovereign Harbour
Crime is increasing in the town. Safety could be increased by
gating alleyways
More houses mean more waste and this needs to be addressed as
a matter of urgency
Wind farms are not effective and any wind turbines should not be
positioned to spoil the seafront
Solar and wind energy should be encouraged and solar panels
198
•
D2 Economy
•
•
•
•
•
D3 Tourism &
Culture
•
•
•
•
•
•
•
•
•
•
•
•
•
•
D4 Shopping
•
•
•
•
•
•
should be included on every new build
All new development should incorporate energy efficiency
measures
There should be no office/industrial development at Sovereign
Harbour as there is no demand, no public transport and it would be
a blight on the landscape
There should be no more ugly trading/industrial estates built in
Eastbourne
Eastbourne needs to encourage more employment opportunities
(high profile companies and small independent businesses) to setup here by lowering business rates
Where are the jobs for all the people that the additional housing
will create?
There is not enough detail about what form employment
opportunities will take
There is a need for more local industry to bring jobs into the area
The plan does not see the value of Sovereign Harbour.
I agree with the policy in the main, but do not support the
retention of defunct or underused hotels which could be
redeveloped for residential use
A clear cultural strategy, including improving use and marketing of
the Cultural Centre, is needed
The Wish Tower site needed to be improved and give an indoor
tourism alternative to help make Eastbourne a winter destination
too
Additional housing development will adversely affect the number of
tourists coming to the town
Hotels on the seafront should be listed to prevent ‘modernisation’
spoiling them
There should be increased marketing and promotion of Eastbourne
seafront. It is Eastbourne’s main selling feature as it is lovely,
clean and well looked after. It is very important to keep it as such
Hotels are closing each year due to too many bed spaces for too
little business. Creating more would be very detrimental to existing
hotel providers
Eastbourne has a plethora of existing tourist accommodation and
attractions. This stock should be upgraded and modernised rather
than building more
There is no mention of improving facilities for tourists coming to
Eastbourne to visit the South Downs, especially in Meads
We can increase visitor levels and tourism by making the town
more attractive through simple things like providing more seating,
increased planting schemes, encourage people to have hanging
baskets etc
I disagree that we need any more tourism in the area
There needs to be an improvement to the theatre buildings and
offers should be given to fill the performances
It will be difficult to regenerate the town centre. The high number
of empty shops in an around town centre need consideration
Retailers must be supported and retail districts must be cleared up
to become more appealing to shoppers
I would like to see the Upperton Road row of shops demolished
and starter homes built in their place
I would like to see support for improvement and continuity of the
shops on Green Street and Upperton Road
What is meant by hierarchy in retail? This needs to be clearer
Extending the designation of the Meads Street Shopping Area will
199
•
D5 Housing
•
•
•
D6 Gypsies,
Travellers and
Travelling
Showpeople
•
•
•
•
D7 Community,
Sports and Health
•
•
•
•
•
D8 Sustainable
Travel
•
•
•
•
•
•
•
•
•
•
result in more empty shops. Local neighbourhood shops should be
encouraged rather than national chains
There are too many empty shops around the town. New uses
should be found.
Sheltered housing for the elderly should be exempted from
affordable contributions
The only type of housing needed in Eastbourne is sheltered
accommodation for the elderly
The proposed level of affordable housing seems unrealistic. This
will have an adverse effect upon the ability of private developers to
provide new residential development. The threshold net gain of 1
is set way too low and should be set at 15+.
The Gypsy and Traveller policy should also consider additional
traffic/transport problems, schools and other community support,
and support for minority groups
Gypsies and travellers should be treated like human beings. They
need somewhere to live too
The policy should include more information about where the Gypsy
and Traveller sites would be located
There is no need for a Gypsy & Traveller site in Eastbourne
because there is already official traveller sites in the County (e.g.
Bridies Tan)
There is a need for more youth facilities in the town that are
relevant to the things that young people want to do
You need to be more specific with your use of ‘Primary’ or ‘Junior’
schools in order to give prospective parents accurate information
Eastbourne needs more publicly accessible community and sports
facilities to promote and encourage community participation so
that people feel proud of their neighbourhood or take ownership of
it
Churches and faith communities should be persuaded to make
their facilities more freely available for public hire
There needs to be more council-run facilities in the town to
increase the provision of community and leisure facilities and make
them accessible for the whole community
The town is not wheelchair friendly. The provision of dropped
pavements is urgently needed
Cycling needs extensive promotion in Eastbourne
The roads and pavements around town are in a poor condition
Where are the people living in the additional housing going to
park? Will there be adequate provision for parking of all the extra
vehicles that will be involved?
The road and rail infrastructure in and out of Eastbourne is not
adequate for our rapidly expanding town. It is a deterrent for
business investment
In order to promote cycling as a sustainable form of travel there
needs to be safe and continuous cycle routes connecting different
parts of the town
Eastbourne needs road improvements and better road
infrastructure between Lewes and Polegate
The proposed station at Stone Cross/North Langney is supported,
but what about a new station at Willingdon Trees?
Encouraging sustainable modes of transport means penalising car
drivers. Sustainable travel should not be at the expense of the
private vehicle
The town desperately needs a Park and Ride facility, even if land
needs to be purchased to achieve this
200
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•
•
•
•
•
D9 Natural
Environment
•
•
•
D10 Historic
Environment
•
•
•
•
•
D11 Eastbourne
Park
•
•
•
•
•
•
•
•
•
E1 Infrastructure
Delivery
•
•
There should not be a designated cycle path on the seafront
promenade. It is dangerous and unnecessary
New housing development will create a significant increase in
traffic. Each dwelling produces 2 cars with the resulting pollution
and congestion
A seafront cycle lane is needed, especially from Fisherman's Green
to Holywell and South Downs with a link to the Railway Station
Cycling Infrastructure and Facilities need to be improved, such as
cycle priority at junctions, dropped kerbs and more cycle parking
The bus service is not convenient and reliable, and bus fares are
too expensive. Are electric buses on the agenda?
Cyclists can pose a danger to pedestrians and they should not be
encouraged
I am concerned that the new allotment sites will not come forward.
Land at St Anthony’s Hill is a possible future allotment site to help
address need at Sovereign and St Anthony’s
I would like to see green investment across the wider town and
Sovereign Harbour in particular
The National Park is a huge asset which should be preserved and
protected. It could perhaps be used more to promote the town by
identifying the town as a gateway to the South Downs
Public areas have been allowed to become rundown.
Improvements to these would make areas more attractive
The Eastbourne Plan does not pay enough attention to improving
the attractiveness of the public realm
Heritage and Listed Buildings around the town need to be
protected for the public in the future. Also, some should be
renovated as they are looking shabby
A lot of accommodation around the town is not properly
maintained. We need a 'pride in your property' campaign to
improve the appearance of properties
Litter is a huge problem around the town and more bins are
required
It is essential that Hampden Park is included in Eastbourne Park as
it was in previous plans, to ensure its safety from development
The policy should be more specific in protecting areas such as
Shinewater Lake
A green space should be set aside for events such as the
Eastbourne Bonfire Society fireworks display.
The Eastbourne Park lakes should be used for boating activities.
The Eastbourne Cricket Ground should be relocated to Eastbourne
Park to entice Sussex Cricket Club to the town again
The Eastbourne Park Golf Course should be extended to make it 18
hole instead of 9 hole
I am not happy about the removal of the link roads. They are
required to reduce congestion at the Seaside roundabout and on
Cross Levels Way. They will be required to manage the additional
traffic coming from housing development in Wealden.
Eastbourne Park needs to be made more accessible to residents
and visitors in a similar way to Shinewater Park
Query reference to Eastbourne Park location
A sensible and flexible approach needs to be taken as far as
developer contributions are concerned or there will be no
development in the current climate.
Developers must be forced to make provision in the areas they
develop
201
•
Other Comments
•
•
•
•
Housing developments should include cycle facilities as part of the
development
How do we know that our comments matter and it hasn't already
been decided?
The Eastbourne Plan does not reflect the views and wishes of the
people.
Don’t remember being consulted about this at an earlier stage.
The consultation should take the form of an independently audited
on-line consultation because post-it notes and sticky dots are
easily lost, misplaced or disregarded.
Changes Required to the Core Strategy
•
•
•
•
•
•
•
•
Add sentence referring to the need to ensure disability standards are met and
adhered to when re-designing or creating new pavements and travel facilities
across the Borough.
Reference the need for increased demand of sheltered housing within the
Borough. This will be addressed in the cabinet report.
Add retail hierarchy definition to the glossary.
Maps and displays at future consultation events will be designed to limit the
opportunity for misinterpretation
Amend the Sovereign neighbourhood key diagram to identify the Sovereign
Harbour bus gate
Amend second sentence of para. 3.4.8 as follows: “This should help to improve
safety and linkages between the two sides of the road and at the Seaside
roundabout.”
Add sentence after the third sentence in Para 3.2.5 as follows: “Some of the
retail offer in the town centre is relatively dispersed and there needs to be
improved links between these areas.”
The neighbourhood boundaries will be redrawn to separate Sovereign Harbour
and Kingsmere, and the Sustainability Rankings be updated as a result of this
change
202
Appendix B3: Summary of Brochure Response
Summary of Comments made through Summary Brochure Responses
Section of
Eastbourne Plan
A1 Portrait of
Eastbourne
A2 Spatial Vision
Comments
•
•
•
A3 Key Issues
•
•
•
A4 Spatial
Objectives
B1 Spatial
Development
Strategy
•
•
•
B2 Creating
Sustainable
Neighbourhoods
B3 Key Diagram
C Localism: A
Neighbourhood
Approach
C1 Town Centre
•
•
•
•
•
C2 Upperton
C3 Seaside
C4 Old Town
C5 Ocklynge &
Rodmill
•
More could be made of the fact that we are a classic Victorian
seaside town
The vision for Eastbourne is dependent on having finance, lets
hope it can become a reality
The plan gives the impression that Eastbourne is master of its own
destiny, but in reality government, ESCC policy and other factors
will determine the town future
The vision for Eastbourne is meaningless
The focus should be attracting more business/shops to the Town
Centre to make it more attractive to all
Other focus should be to create more cycle paths and more tourist
attractions for young families
Stop any building on the east side of Kings Drive – its mostly a
flood plain
Why must SE England be packed with people – we have Europe’s
highest density
I understand the earlier proposed road from the DGH to Lottbridge
Drove has been removed from the plan – this is very ill conceived
an inconsistent with the earlier phase of seafront defence work
We need a policy to ensure that the Town Centre is for all ages at
all times, not just for young people and serious drinkers. At
present older people avoid the area at night which impacts on
restaurants and the cinema
Keep cars out of the centre of town – make Southern end of South
Street 2 way, close Hyde Gardens Car Park, as we have two high
rise car parks in town hardly used
Make pedestrian area in Town Centre bigger, and make crossing
on Cornfield Roan near Terminus Road
The Town Centre desperately needs attention – I would like to see
development here not to turn Eastbourne into another faceless
clone, but to give us back a Town Centre we can be proud of
Direct pedestrian access from St Anne’s Road to Town Centre via
new bridge over the railway line, perhaps part of a future bus/rail
interchange for this area?
Rodmill residents feel let down by what happened at the Kings
Drive Inquiry – please do not inject even more housing and
congestion, pollution etc on us.
203
•
•
Agree with neighbourhood approach apart from housing – please
do not allow any more
The Rodmill estate is already cluttered with cars parked on it by
DGH staff whilst there will be an additional burden on traffic
created by the Kings Drive development. The idea of a Quality Bus
Corridor is laughable. Emergency services beware!
C6 Roselands &
Bridgemere
C7 Hampden Park
•
Particularly support any help the Council will give to small business
tenants of Hampden Park in the Brassey Parade area of shops.
C8 Langney
C9 Shinewater &
North Langney
C10 Summerdown
& Saffrons
C11 Meads
•
What kind of enhanced tourism facilities are suggested for the
Meads area?
Where will be redevelopment of housing be in Meads? We need to
mention the protection of open and green space in the Meads area
specifically
No high rise buildings – buildings to be no taller than the general
height of those surrounding
Take down the multi-storey flats above Holywell.
Since the university arrived our streets have been clogged with
their cars. Control over parking around university sites is required.
They have a bus service; we do not in our area. When we drive,
two cars cannot pass and a number of roads are becoming rat runs
Cycle path is needed from Holywell along the seafront
Parked cars an increasing problem – many roads become single
track, dangerous for drivers, cyclists and pedestrians – more
parking restrictions required
Upper Meads is very historic in Eastbourne’s establishment, to a
lesser extent middle Meads. Too many properties/land has been
lost as to historic retention – conservation.
More 20mph speed Limits, particularly Wish Hill and Coopers Hill, if
you want to go faster, go by Willingdon Hill. All estate roads off
main road should be 20mph
•
•
•
•
•
•
•
C12 Ratton &
Willingdon Village
C13 St Anthony’s
& Langney Point
C14 Sovereign
•
•
•
•
•
D1 Sustainable
Development
•
•
•
•
D2 Economy
•
There is virtually no chance of a science park in Sovereign due to
contamination, no broadband and poor road and rail
communication
No new housing in Sovereign until community facilities have been
built
No mention in leaflet within ‘Community led neighbourhoods’ as to
the proposed building of 150 houses. No reference to promised
community facilities which have never been a priority
Change of land use would open doors to further unregulated
development
Unconvinced by wind power as a cost effective energy source
No high rise buildings – buildings to be no taller than the general
height of those surrounding
There are no effects of climate change that EBC can influence
Disagree with this policy because of inclusion of wind power –
turbines are ugly, noisy and are questionable economically
Without fast trains to London and decent road links, Eastbourne
204
•
•
D3 Tourism &
Culture
•
•
•
•
D4 Shopping
•
•
•
•
•
•
D5 Housing
•
•
•
•
•
D6 Gypsies,
Travellers and
Travelling
Showpeople
D7 Community,
Sports and Health
•
•
•
•
•
•
•
D8 Sustainable
Travel
•
•
•
•
will go nowhere as an economic entity
Regarding more industrial units, we already have a plethora
standing empty
The Councils needs to look after small businesses, which play a
vital role in Borough’s income source
Without a proper account of the story of the area, tourists will find
it difficult to grasp what Eastbourne is about
Why cant we get entertainers here as in other towns?
Real effort needs to go into growing as a tourist town – surely our
biggest economic asset
Council needs to attract tourists by using different modes of
attractive packages, as well as need to develop more facilities in
town
Question what the Congress Theatre loses each year.
I would like to see the expansion of the shopping area in
Eastbourne as it lacks some of the major retail stores
Without a key name in the world of shopping, e.g. John Lewis, the
town will not attract shoppers to the area
The focus should be attracting more business/shops to the Town
Centre to make it more attractive to all
Need more shopping arcades, specifically the Seaside Road area
which would also benefit from tourist attractions
Ashford Road and the Arndale Shopping Centre now has a lot of
empty shops
Housing should not be built on the flood plain or low-lying land
Any more housing or flats should be built with some character, not
faceless buildings which are not in keeping with this town’s image
No more housing, the town is big enough and the
infrastructure/services and facilities cannot stand it.
Properties are owned by non-residents and under-utilised except
for the summer months. These second homes should be taken
back into public ownership and added to the social housing stock
Any affordable housing should be to the North and East of the
Borough
We do not want to see too much ‘back garden’ development
We do not want Gypsy and traveller sites as there are very few
genuine, just travellers who want to take advantage.
The wider area is not suited to housing gypsies and travellers
because of the adverse impact their sites have on the environment
You cannot park a caravan on a set of criteria
Very important to ensure good community facilities are included in
any new housing developments
Far more provision for teenagers and families is required if the
population age is to decrease
More local outreach services for children/elderly to take part in
sports, make use of recreation grounds etc – not everyone can
access big sports centres
New development should construct good cycle lanes linking
existing cycle lanes, using dropped kerbs and access through culde-sacs, thereby promoting cycle usage and aiding wheelchair and
pushchair access also.
To encourage walking and cycling could we not have more 20mph
speed limits?
Cycle lane should be provided on A2270 from Willingdon
roundabout to Eldon Road, marked with solid white line
Take non cycling signs down from promenade/seafront, or maybe
205
•
•
•
•
•
•
•
D9 Natural
Environment
D10 Historic
Environment
D11 Eastbourne
Park
E1 Infrastructure
Delivery
Other Comments
•
•
•
•
•
•
•
•
•
•
•
•
timed use of seafront
Keep cars out of the centre of town – make Southern end of South
Street 2 way, close Hyde Gardens Car Park, as we have two high
rise car parks in town hardly used
Make pedestrian area in Town Centre bigger, and make crossing
on Cornfield Roan near Terminus Road
Concerns with traffic congestion which will only get worse as the
town grows – investment in new roads and alternative routes is
needed
You cannot create a pedestrian friendly environment when the
Kings Drive development is to go ahead
Provision must be made in the strategy for future areas of off-road
parking and Park-and-Ride – the problem will not go away with an
enhanced public transport system
Strongly support measures to increase cycling – we need a far
greater provision of cycle routes through all areas
I would like to see improved access to safe crossings of busy roads
– especially a crossing on the Lottbridge Drove end of Cross Levels
Way
It is essential that we keep our green spaces and curb
overdevelopment
There is conflict between approach to housing and protection of
the historic environment, especially for Meads
You cannot achieve the aims of Eastbourne Park by allowing the
Kings Drive development to go ahead
Before we increase housing we need to secure the support network
is in place. The DGH cannot accommodate the current population
No more housing, the infrastructure cannot stand it
I have a deep cynicism as to what will actually happen
Proper consultation needed on policy at the first stage
Better website needed to concentrate on what we have and to
counteract the ‘costa geriatrica’ perception
Any decision made by Planning Committee can be overruled,
obviously the Compton Estate has its own vision.
The whole leaflet is too general.
There are too many houses, too much traffic, too many social
problems, too much crime in what is a small town, which was
beautiful and now ruined by social problems due to too many
people
The key point in this is will the Council listen the community in
measurable terms, and that decisions made are taken
empathically to our current economic situation
206
Appendix B4: Summary of Online Survey
Comments
Summary of Online Survey Comments
Section of
Eastbourne Plan
A1 Portrait of
Eastbourne
A2 Spatial Vision
Comments
•
•
•
•
•
•
•
•
•
•
A3 Key Issues
•
•
•
A4 Spatial
Objectives
B1 Spatial
Development
Strategy
•
•
•
•
•
•
•
•
B2 Creating
Sustainable
Neighbourhoods
•
B3 Key Diagram
C Localism: A
Neighbourhood
Approach
•
•
C1
C2
C3
C4
•
•
There is an opportunity to develop a joined up plan for Eastbourne
Needs to develop into a progressive sustainable and attractive
town. It is at risk of becoming a poor relative of towns such as
Brighton or Hastings
In reality it has a chance to be a great place to live
Brave decisions need to be made, looking forward not backward
The town needs something big to put it on the map
Eastbourne has slipped significant since the post-war heyday as a
vibrant seaside resort we should work to avoid is slipping any
further
In reality a large section of the population is made of families and
young people who are regularly overlooked in planning matters
Fails to meet the aspirations of the Sovereign neighbourhood
Evidence on which this is based is neither robust or credible
Generally supported, but do not believe it will be followed due to
mistakes at Sovereign Harbour
The plan seems to address all the key issues
Need to improve links to the town – rail service and roads
Improvement is employment provision is omitted – we are too
reliant on seasonal trade
Achieving laudable objectives and policies is going to be extremely
difficult
Local housing targets – what is the evidence to support this?
The spatial development strategy will be very difficult to deliver
without the adequate provision of schools, medical facilities etc
The priorities seem to be correct, housing is a general issue, but
accepted that more is required with sensitive planning
Focus on brownfield sites is supported
Expand on the preservation of green space
Broadly agree, apart from impact on Sovereign Harbour
Do not supported over intensity of development, especially loss of
residential garden land
If correctly implemented, it would meet the aspirations of the local
community
General misunderstanding of sustainable neighbourhood and
sustainable centre – clearer explanation required
Key Diagram is clear and comprehensible
Fully agree, different parts of the town have different
characteristics
Important that local residents have the opportunity to shape the
future of their neighbourhood
Town Centre
Upperton
Seaside
Old Town
207
C5 Ocklynge &
Rodmill
C6 Roselands &
Bridgemere
C7 Hampden Park
C8 Langney
C9 Shinewater &
North Langney
C10 Summerdown
& Saffrons
C11 Meads
C12 Ratton &
Willingdon Village
C13 St Anthony’s
& Langney Point
C14 Sovereign
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
D1 Sustainable
Development
D2 Economy
•
•
Object to any housing at Sovereign Harbour – no justification for
150 new dwellings to be built in Sovereign Harbour
Hotel on Site 1 would be supported
Support development of well designed business/science park at
Sovereign Harbour – some feel this may not be sustainable
Sovereign is not a sustainable neighbourhood due to lack of
infrastructure and community facilities, it will not be sustainable
with more housing
General misunderstanding of sustainable neighbourhood and
sustainable centre with particular reference to Sovereign – clearer
explanation required
Infrastructure should be delivered before more housing
development, not after
Views of Sovereign Harbour community were discounted in the last
consultation
Flats should not be built in Sovereign Harbour – people require
gardens
Original S106 agreement for Sovereign Harbour should have
secured the building of community facilities
The term ‘limited’ development implies that it will be controlled.
This could mean that more than 150 dwellings will be built.
Overdevelopment is not a vision
The employment potential of Sovereign Harbour land has not been
realised
The vision does not address the employment and tourism
opportunity of the remaining development sites
The neighbourhood boundary has been moved to include
Kingsmere/Kings Park
There is no guarantee that infrastructure will be delivered, or that
it will be adequate for the needs of the community
Evidence used is flawed. Must be re-examined/corrected before
the next stage
Encouraged to see large areas of green space proposed, both
larger and small play areas area also required, located around the
residential areas
More quality employment space required – we are too reliant on
the tourism and service industry
This will be difficult to deliver if major developers cannot be
persuaded to invest in Eastbourne
208
•
•
D3 Tourism &
Culture
D4 Shopping
•
D5 Housing
•
•
•
•
•
D6 Gypsies,
Travellers and
Travelling
Showpeople
D7 Community,
Sports and Health
D8 Sustainable
Travel
D9 Natural
Environment
D10 Historic
Environment
D11 Eastbourne
Park
E1 Infrastructure
Delivery
•
•
•
Problems with general accessibility of the Borough – need for
upgraded A27 and faster train service
Where is the innovation and entrepreneurship going to come from
for the Sovereign Harbour business/science park. The site has
been available for years and there has been no interest
Where is the money coming from to fund conference facilities?
Support for Town Centre redevelopment, but how will this be
delivered?
The HMA identifies a need for larger houses not flats in Sovereign
Harbour
The policy does not meet the objective of providing more family
housing across the Borough
The provision of affordable housing will not attract higher skilled
types of employment
The plan does not take account of residential density of proposed
development locations – this affects quality of life
Need to provide housing for all, not just retirement flats
The plan does not take into account nearby affected residents
opinions on the location of sites
•
•
This is undeliverable – we should be making vehicles more fuel
efficient, improving road network and taking out obstacles to cars
which only increase pollution
This is vital, trying to get around the town in a car is horrendous
There is no coordinated infrastructure for cyclists or pedestrians
•
Eastbourne Park has huge potential
•
There is no guarantee that infrastructure will be delivered, or that
it will be adequate for the needs of the community
Other Comments
209
Appendix B5: Minutes of Stakeholder Event
Eastbourne Plan Stakeholder Forum
23rd February 2011
10am-1.30pm
Attendance List
Stakeholder Forum Presenters & Facilitators
Jefferson Collard – Eastbourne Borough Council
Amy Douglas-Eastbourne Borough Council
Matt Hitchen-Eastbourne Borough Council
Sue Holland-Eastbourne Borough Council
William Nichols-Eastbourne Borough Council
Valerie Tupling- Eastbourne Borough Council
Stakeholders
Richard Bugler- Eastbourne College (Red Group)
Sue Burlumi- Eastbourne Borough Council, Housing (Blue Group)
Derrick Coffee- Campaign for Better Transport (Green Group)
Waunita Dean- Allotments and Gardens Society (Green Group)
Dennis Donovan-Crime Prevention, Sussex Police (Red Group)
Maureen Hamilton- Groves Builders and Contractors Ltd (Blue Group)
Chris Hughes- 3VA and Shaw Trust (Red Group)
John Hurwood- Campaign for the Protection of Rural England Sussex (Blue Group)
Derek Legg-Eastbourne Community Network (Blue Group)
Loretta Lock- 3VA (Blue Group)
Hannah Mears-Environment Agency (Green Group)
Marie Nagy- DPP Planning (Red Group)
Ron Naylor-Eastbourne & District Chamber of Commerce (Red Group)
Craig Noel- Strutt and Parker (Blue Group)
Mike Reid- Reid and Dean (Red Group)
Session 1 Feedback
In this session, delegates were sub-divided into three groups with each group asked
to consider one of three different proposed planning policies:
• Policy D1:Sustainable Development
• Policy D2: Economy
• Policy D5: Housing
Each group was asked to address the following questions and then feedback its
findings to the forum:
• What are the positive aspects of the policy?
• What are the negative aspects of the policy?
• Should any changes be made to the policy to make it more effective in
delivering the Council’s Vision?
210
Green Group
Policy D1: Sustainable Development
Positives
• Policy D1 stipulates the Code for Sustainable Homes Level 4.
• SPDs will provide extra guidance keeping the policy up-to-date.
• The stringent measures proposed will help mitigate the effects of climate
change.
• Development will be accessible to all users and help provide good links to
shops, services and facilities.
• The importance of conserving water has been addressed.
Negatives
• All non-residential development should also aim to achieve good BREEAM
standard.
Changes
• The Carbon footprint of transport use over a development’s lifetime should
also be considered.
• Flood risk could be cross-referenced with Policy D9: Natural Environment.
• The plan needs to look at how to improve the sustainability of existing
development, rather than just new build e.g. retrofitting.
• Green networks could be cross-referenced with Policy D9: Natural
Environment and expanded in a SPD.
• A checklist for the SPD could be produced to ensure all requirements are met,
and become a condition of planning application approval.
• The SPD needs to be cross-referenced in policy.
• The cost derived for the Carbon Buy Out Fund (£100 per tonne) may not be
enough over the life of the building.
General Comments
• The current BREEAM standard applies to buildings over 1,000 square metres.
However, it is often harder to implement in bigger buildings as these can be
in remote locations, have higher ceilings etc. Meeting this standard has the
potential to be very expensive and counter-productive. It is thought that it
may be more applicable to look at the purpose of the building to see if
standards are appropriate e.g. if it is a storage building and will not be
occupied, is it as important to reach high BREEAM standard? The use of a
building, rather than its size, is considered to be more important when
determining the amount of energy generated. There needs to be a greater
degree of flexibility.
• Some development in Eastbourne is already unviable and S106 agreements
might result in less development coming forward.
• The Buy Out Fund is appropriate for both commercial and residential
development, but there will need to be a differentiated approach for each
use.
Red Group
Policy D2: Economy
Positives
• Good policy overall but it needs amending to make it more effective.
211
•
It requires further clarification on how job growth and economic prosperity
policies will be put into action.
Negatives
• There is not enough emphasis on the existing economy.
• There is not enough emphasis on the town being a cultural centre.
• There is a need to ensure younger people see the benefits of the town, which
is currently perceived by many outside the area to be a retirement town.
• More references need to be made to outside Eastbourne e.g. the EastbourneHailsham Triangle.
• There is not enough mention of surrounding areas e.g. The South Downs
National Park.
• There is a need to change the public’s perception of the town to encourage
more businesses to locate here.
• There is a need to liaise more with Wealden and other nearby local authorities
to ensure that a coordinated approach to economic development is taken.
• Paragraph 1.24 is very proactive but needs to link to the policy statement on
the economy.
• There is a need to encourage more businesses to the area by freeing up
development costs and making it easier for businesses to relocate. This could
be done by the introduction of: Bid areas; Local Development Orders or
Simplified Planning Zones. Industrial estates and the Town Centre lend
themselves to these approaches. This would help Eastbourne set itself apart
from other areas and attract new businesses.
Blue Group
Policy D5: Housing
Positives
• Monitoring and provision of affordable housing.
• Higher density urban housing is good for the environment and enables
community facilities to be provided close to residents.
• Support 30/40 % affordable housing on site but this policy needs to be
flexible to ensure that schemes remain viable.
• Intensification of existing development encourages flats not family housing of
which there is a greater need. This may, however, be provided by within the
Greater Eastbourne area e.g. Wealden.
• Strong affordable housing policy has approval but questions remain over
viability. Would contributions from 1 unit deter windfall development?
• The policy needs to specify the split between rented and shared ownership. It
is difficult to deliver in the current climate. Is there room for negotiation with
the split?
Negatives
• No focus on quality/family housing provision.
• Tenure mix not necessarily viable due to market conditions.
Changes
• Refocus housing policy to encompass need for quality housing as well as
affordable housing- or split into two policies.
• The policy should be separated into two, with one policy dealing with Housing
and dealing more specifically with Affordable Housing.
212
General Comments
• The threshold at which affordable housing will be required has been set at
one. In comparison, neighbouring Wealden has set its threshold at five. This
has the potential to create viability issues.
• New development in Polegate will not provide enough infrastructure for other
developments.
• Page 79 of the Eastbourne Plan makes recognition of high value areas is a
starting point, but labelling areas high, medium etc may perpetuate the
problem.
• It is going to take time to change Eastbourne’s image as a retirement town
but in the meantime we can make it easier for businesses to locate here and
get planning permission.
• P79 D5 Housing Policy Box says High and Medium Value Areas but p79 says
High and Low Value Areas. Consistency is required throughout the document.
Session 2: Feedback
In this session, delegates were sub-divided into the same three groups. This time,
each group was asked to consider two of the following six policies:
• Policy D3: Tourism and Culture
• Policy D4: Shopping
• Policy D7: Community, Sports and Health
• Policy D8: Sustainable Travel
• Policy D9: Natural Environment
• Policy D10: Historic Environment
Each group was asked to address the following questions and then do a short
presentation to the forum:
• Name three potential consequences that the adoption of this policy would
bring to Eastbourne?
• Are there any other policy areas that should be included in the Eastbourne
Plan?
Red Group
Policy D3: Tourism and Culture
•
•
•
•
•
•
There is a need to recognise the value of the South Downs National Park:
4,000 acres of Council Owned land could be enhanced. There are a number of
derelict properties that could be redeveloped, helping tourism. It is easy to
accomplish and enhance what is already there.
The policy appears like more of a ‘wish list’ and needs to be more focused.
Development of the Wish Tower needs better management and a focused
strategy. This applies to all assets controlled by the Council.
The current usage levels of existing sports facilities need to be assessed and
from this determine focal areas for greatest use of future sports facilities.
There was a suggestion that the Council appoints somebody to promote and
oversee development and investment issues.
The policy should ensure existing green spaces are retained and kept
relevant- recognise this as an asset to the locality and enhance to maximise
usage.
Policy D4: Shopping
213
•
•
Hotels currently have a 2-year ruling to prove they are unviable, but in this
time the property deteriorates. If the hotel is considered to be unviable, they
should be required to wait for two years to prove this.
The first statement protecting large units is supported but it is felt that some
decisions have been made that contradict this e.g. subdividing of the Cooperative building.
General Comments
• The policy does not acknowledge the role the Council has to play, being
responsible for both land and property.
• Past policies have increased access to the South Downs but tourism guides do
not incorporate this information. There needs to be more communication
between the two.
Blue Group
Policy D10: Historic Environment
• This policy mainly replicates national policy requirements. There needs to be
a greater emphasis on what is specific to Eastbourne e.g. locally listed
buildings and townscapes.
• DPDs need to identify what is important about the 5 townscape areas and
how developers should take this into account. Reference is needed to subdocuments.
Policy D7: Community, Sports and Health
• Very broad location for facilities (penultimate paragraph). It is not
appropriate for all types of facilities.
• The location of facilities could be detrimental - why all together?
• Health Impact Assessment will help determine if it is relevant.
• This policy does not emphasize the benefits of dual use facilities. The Council
should encourage joint use facilities where practicable and this should be
incorporated into the policy.
• Need to embrace provision for separate age groups e.g. teenagers.
• Encourage new development to include facilities (including commercial).
• More definition in local provision e.g. use of recreation grounds.
Green Group
Policy D9: Natural Environment
3 Consequences
• High quality walking experiences will encourage less car use, and enable
people to enjoy wildlife and increase the usage of other modes of transport.
• The Council needs to look at provision of allotments beyond 2027 to ensure
that that no spaces are lost over this period.
• It is important to make people more aware of natural assets in their area to
encourage greater support for protection and enhancement.
General Comments from the group;
• Gardens are important spaces: retention and reinstatement needs to be
encouraged and supported within Policy D9. An audit of lost gardens could be
commissioned.
• Need to recognise and reference the ‘well-being’ aspects of nature for
people’s mental/physical health.
214
•
•
•
•
•
•
The benefit of the natural environment as a tourist attraction should be
maximised, creating a place people want to visit and stay.
Development should enhance existing wildlife networks/trees as a means of
encouraging nature in Sustainable Development Policy D1.
Clarification over species of importance is needed. Habitats also need
including.
Stronger emphasis on allotment retention (re-word surplus to requirements).
Encourage sequential tests for flood risk as a supporting document to
planning applications.
Note: No longer SUDS- now Sustainable Drainage.
Policy D8: Sustainable Travel
3 Consequences
• Quality of home/work links will encourage sustainable travel.
• Demand management is needed to implement policy and encourage
sustainable travel.
• More public awareness and incentives are needed to encourage sustainable
travel e.g. Real Time Passenger Information (RTPI) boards, road names.
Increased interaction with public transport providers.
General Comments from the group
• Better parking required to attract visitors and links with natural
environments.
• 2nd Paragraph should be re-worded to ‘sustainable modes’.
• The policy should be reworded to refer to ‘frequent regular bus service’
(‘regular’ is not time specific).
• Greater interaction with public transport providers will encourage use of
public transport (e.g. standards of practice- timetables being complicated
etc).
• New development re-word to ‘reduce the need to travel by car’ to ‘reduce the
need to travel, especially by car’. Could also add encouragement of
walking/cycling.
Other comments
• The requirement for Travel Plans to be required to a company all
developments of 5 dwellings or more, is rather onerous on developers on
small schemes. If implemented for small numbers it should only be if the
scheme is in an inaccessible location.
• There should be a significantly higher threshold for Travel Plans, as it could
affect conversions. It is considered to be an unnecessary burden.
• Travel Plans for employment-depends how you define non-residential.
• Travel Plans are an action to monitor.
• The private car is likely to continue to play an important role in future years.
Regulations limiting parking spaces are a problem.
• There needs to be recognition of changes to technology. New technology e.g.
hydro/electric cars will need car parking spaces.
Note: The notes above represent a summary of the comments that were made at
the Stakeholder Workshop on 23rd February 2011 and are not necessarily the views
of Eastbourne Borough Council. The comments will, however, be fully considered as
part of the continuing statutory consultation process and where appropriate and
justified, amendments may be made to the Eastbourne Plan.
215
Appendix B6: Summary of Interactive School
Workshops
In order to engage with the younger population, local schools were offered the
chance to take part in an interactive workshop. Four schools took up this offer, and
officers attended School Council meetings at St John’s School, West Rise Junior
School, Stafford School and Ocklynge Junior School, liaising with groups of between
10 and 18 children.
In order to allow them consider social and environmental issues that relate to
Eastbourne, the pupils were first encouraged to build their ideal town on a felt fabric
model. The different elements of a town that they could plan included housing,
offices, factories, shops, schools, open spaces, hotels, medical facilities, roads and
railways.
Issues arose and were discussed about the location of development and the pupils
were asked to consider possible problems of building in flood risk areas, or of
locating shopping and employment too far away from residential areas. The pupils
responded very positively to this ‘hands on’ approach, and produced a variety of
different ideas about how a town could be laid out.
The pupils were presented with a map of Eastbourne and were asked to suggest
what kind of development should take place in the town and where, over the next
16 years. Some of the more popular suggestions in all four events included more
attractions along the seafront and an increased number of sports facilities,
particularly football pitches. Other suggestions included:
• Vets
• Build-a-bear centre
• Fun-fair on the Pier
• Animal adoption centre
• Water park in Eastbourne Park
• Ice Rink
• Toy Shops
• Computer shops
• Sealife Centre on the Seafront
• Railway through Eastbourne Park linking Town Centre with Langney
• Parks at Sovereign Harbour
• Swimming Pool in Meads
• Lucky Charms Factory
• Horse Stables
A more detailed map of the school’s neighbourhood was then presented to the
pupils and they were asked how they would like their local area to change in the
future. Suggestions included:
• Reductions in speeding traffic
• More dog litter bins
• Less crime
• Football pitches
• Playgrounds
216
Appendix B7: Statistical Analysis of Responses
Received
Summary Brochure
Level of Support and Opposition to the approach to planning policies in the
Eastbourne Plan – Proposed Core Strategy
Neighbourhood Vision
Historic and Built
Environment
Natural Environment
Transport and Travel
Question
Community Facilities
Housing
Town Centre and
Shopping
Tourism and Culture
Economic Growth
Sustainable Development
Housing Distribution
Development Strategy
(Policy B1)
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Percentage of Responses (%)
Agree/Approve
Neutral
Disagree/Oppose
217
On-Line Questionnaire
Level of Support and Opposition to the approach to planning policies and sections of the Eastbourne Plan – Proposed
Core Strategy
Infrastructure Delivery (E1)
Eastbourne Park (D11)
Historic Environment (D10)
Natural Environment (D9)
Sustainable Travel (D8)
Community, Sports and Health (D7)
Gyspies, Travelleers & Showpeople (D6)
Questions
Housing (D5)
Shopping (D4)
Tourism & Culture (D3)
Economy (D2)
Sustainble Development (D1)
Neighbourhood Vision
Neighbourhood Approach
Key Diagram
Spatial Development Strategy
Spatial Objectives
Key Issues
Vision
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Percentage of Responses (%)
Agree
Neutral
Disagree
218