Hastings Local Plan Consultation – March 2021 Nick Chitty Key Issues 1. PAUSE TO ASSIMILATE BREXIT AND COVID IMPACTS It is recognised that there are likely to be significant changes to demographics and the way people live and work as a result of the ongoing Covid pandemic and the impacts of Brexit. A pause in the Local Plan process is recommended to allow time to understand the effects of these historic events, assimilate any changes in government projections and guidance and undertake any necessary further research and evidence gathering. 2. URBAN SPRAWL There is a stark disconnect between OSP1 (and others) and the many urban fringe development sites which are likely to be car-dependent and harm or destroy wildlife habitat. The plan should be adjusted to give greater priority to developing brownfield sites for low or car-free housing in the town and district centres, including some car-parks, and existing under-utilised spaces, for example above shops. 3. TRANSPORT The transport context will change dramatically during the lifetime of this plan. By 2039 most cars and many commercial transport vehicles are likely to be powered by electricity or hydrogen (or other alternatives). Motorised vehicles will become more and more connected to each other and transport infrastructure, while their operation will become more, perhaps fully, autonomous. At the same time the importance of active travel cannot be overstated for benefits to health, wellbeing, the local and global environment and sustainable development. The Governments ‘Gear Change’ document published in 2020 sets out the national context and aspiration for active travel and this should be recognised appropriately in the plan. The plan must recognise these fundamental changes and ensure appropriate obligations are placed on developers. In collaboration with others, such as ESCC, the Plan must support changes to remove or reduce motor traffic dominated places and enable equitable and active travel opportunities. Examples where action is required include: – the 1-way system at London Road/Norman Road, St Leonards where there is appallingly poor provision for pedestrians to cross – Support projects to reduce the dominance of motor traffic and parking along the seafront, such as by extending the Pelham Boulevard footway widening eastwards to the Rock-a-Nore junction – Side road junction treatments to slow traffic and improve crossing conditions for pedestrians – 20mph speed limit in all residential streets, high streets, schools and local shopping streets 4. MASTERPLAN APPROACH FOR HASTINGS TOWN CENTRE Consideration should be given to a Master Planning approach for Hastings Town Centre (referencing the AAP consultation and the 700+ public responses in 2018) to tie together the various development sites with objectives for improving the public realm, transport, housing (eg above shops) and conservation (at and beyond Trinity HAZ) and to ensure alignment to other proposals such as the Town Deal ‘Green Garden Town’ and the ‘15 minute city’. There are apparent additional opportunities for valuable, ‘car-free’ development sites along the north/west side of Queen’s Road where there are currently gaps in the building line at the Morrisons car-park slip road (alternative is available via Waterworks Road) and a few parking spaces. black = NC comments submitted | ||
Foreword and Development Objectives | Development Objectives: There is a disconnect between the climate change and green infrastructure objectives and many of the sites proposed for residential and employment development that are edge of town / urban fringe with few or no amenities within walking distance and are therefore likely to be car dependent. Much greater emphasis needs to be placed on a comprehensive cycle network (designed for all ages and abilities and for e-bikes and e-scooters), all hours public transport and provision of local amenities within walking distance for existing and new residential sites. To minimise sprawl and reduce harm to the ‘extraordinary’ natural environment of the town, priority should be biased towards residential development in town, district and local centres, especially on brownfield sites and by converting existing redundant or under-used buildings, such as space above shops. This will also achieve greater vibrancy and viability for existing and new businesses in those centres. To be meaningful and effective, the concept of the ‘15 minute city’ for access to everyday needs, mooted for the town centre in the current Town Deal proposals, should be applied to the whole town. Insert the words ‘and protecting’ after ‘celebrating’ in the final bullet point of ‘Development Objectives’. Summarised to meet 100 word limit: A disconnect exists between the climate change and infrastructure objectives and many of the car-dependent sites proposed for homes and employment. Greater emphasis is needed on better bus and cycle networks and amenities within walking distance of homes. To minimise sprawl and avoid harming the ‘extraordinary’ natural environment around the town, prioritise residential development in existing centres, brownfield sites, and under-used buildings. The concept of the ‘15 minute city’, mooted for the town centre in the current Town Deal proposals, should be applied across the whole town. Insert ‘and protecting’ after ‘celebrating’ in the final point of ‘Development Objectives’. | |
Introduction | 1.7 A mechanism to support the aspiration for ‘well designed’ development is required. Mandatory Design Review for developments fulfilling specific criteria (location (prominent/conservation / >2 stories) and scale) should be considered and perhaps referencing existing local examples of good/award winning design (suitably caveated) such as The Stade and Hastings Pier. For urban realm, use of Manual for Streets and MfS2 should be adopted and mandated for all relevant projects affecting the public realm (with commitment to adopt the revised MfS when published). 1.15 New road capacity should be avoided in favour of public transport and active travel provision. Any transport modelling must use updated forecasts taking account of the effects of Brexit and Covid including demographic changes resulting in more home/remote working. | |
Hastings in Context | 2.7 Greater priority should be given to active travel and public transport provision, with reference to Government policy such as ‘Gear Change’ published in 2020, and working with ESCC to support the LCWIP. Cross departmental working and procedures are required within HBC to ensure a ‘joined up’ approach to achieving active travel objectives. 2.15 More development in the area to the north of Queensway should be minimised or avoided to minimise harmful impacts on the biodiversity and the natural environment that is described as ‘extraordinary’ and to be protected and enriched in 2.12. | |
Development Strategy | 3.3 The claim that the Focus Areas are well supported by sustainable transport infrastructure is not correct. There is no rail station on the Bexhill line at West Marina and Little Ridge / Ashdown House is not well served by attractive, affordable and accessible public transport. Such provision is required simultaneously or in advance of development if these sites are to be viable and sustainable. To support active travel it is essential that new developments are permeable for walking and cycling, avoid creating barriers to active travel and with easy, direct connections to wider networks, amenities, rail stations and bus stops. 3.10 Do not agree that Local Development Orders may be used to facilitate intensification in industrial areas. Many of these are close to and / or visible from other parts of the town and surrounding countryside including the AONB and Hastings Country Park. New development should be required to go through the full planning process, consulting with stakeholders as appropriate. 3.12 As noted against the Foreword, to minimise sprawl and reduce harm to the ‘extraordinary’ natural environment of the town, priority should be biased towards residential development in town, district and local centres, especially on brownfield sites and by converting existing redundant or under-used buildings, such as space above shops. This will also chieve greater vibrancy and viability for existing and new businesses in those centres. Leisure uses may be suitable (such as mini-golf, as trialled in the Observer Building) in larger buildings to enhance the leisure provision for residents and visitors. 3.15 I agree that some sites are rightly subject to constraints on new housing development owing to their proximity to environmentally important areas such as the AONB and Hastings Country Park. However, the same constraints do not seem to be considered applicable for industrial development. This is an inconsistency in policy that should be rectified so that adverse impact on the environment from any development type is identified and avoided or minimised. 3.19 Measures should be taken to limit the quantity of short-term holiday rental properties in areas such as the Old Town. The high number of such properties in such areas is having a detrimental impact on the availability of housing for local people.. 3.20 Good social infrastructure includes public houses and these valuable assets and businesses have been poorly protected in recent years by HBC. For example, nearly all pubs in the West Hill area have closed in recent times leaving the area without options for the social, leisure and community activities that pubs provide, including for the elderly and lonely. Hastings should adopt a policy to protect pubs from change of use or redevelopment as many other towns have done. | |
Over-arching Strategic Policy OSP1 Tackling Climate Change | OSP 1.C This is a weak statement that requires a commitment to more than ‘encouragement’. Clearer actions are needed, requiring collection of mode share data and setting targets for increases in proportions of trips made by walking, cycling and public transport and reductions in car use, to be monitored and reported on annually. OSP 1.E More detail is required on the location of the land at Breadsell (on the edge of the AONB ?) and the nature and impacts of the projects referred to. | |
Strategic Policies 1-10 | ||
SP01 Directing growth | 4. There appears to be insufficient recognition of the need for mixed-use thinking in all developments. Significant housing developments should include local shops and other amenities and opportunities should be taken to retrofit such provision in to existing poorly served housing areas. 5. To meet the desired ‘high architectural standards’ a Design Review Process should be developed to provide objective context, support and advice for developers and where appropriate, facilitate constructive engagement of stakeholders, including councillors and highway authorities. Significant clusters of development sites, such as the Town Centre, should be subject to Master Planning to enable co-ordination of development and, along with the highway authority and other partners, support the ambition of ‘curated public realm’ set out in the Town Deal proposals. Large and prominent sites such as HL80 (Sedlescombe Road North) should be considered suitable for a design competition. Summarised to meet 100 word limit: 4. Insufficient recognition of mixed-use approach with significant housing developments incorporating shops and other amenities, taking opportunities to retrofit these in existing housing areas. 5. To achieve ‘high architectural standards’ a Design Review Process should be developed to provide objective context, support and advice for developers and facilitate constructive engagement of stakeholders as appropriate. Significant clusters of development sites in the Town Centre should be subject to ‘Master Planning’, enabling co-ordination of development and, with partners, support the ambition of ‘curated public realm’ (Town Deal). For large and prominent sites, such as HL80 (Sedlescombe Road North), consider a design competition. | |
SP02 New and affordable housing | None. | |
SP03 Office and Industrial Uses | None. | |
SP04 Retail and Leisure Uses | None. | |
SP05 Conserving and Enhancing the Natural Environment | These proposals are broadly supported but these places must be protected and made attractive for active travel and biodiversity by reducing harmful impacts of development (eg noise, lighting) during and after construction and associated transport infrastructure such as low noise road surfaces, minimising lighting and providing suitable noise barriers. A planting strategy should be developed with ESCC and other partners to support more planting along the seafront and along streets to support delivery of the green garden town initiative (Town Deal). | |
SP06 Enhancing the Historic Environment | 3. The seafront strategy has resulted in some low quality and inappropriate developments which have harmed the value and setting of historic assets. The (currently disused) kiosk on the elevated promenade should be removed and seating reinstated. Contrary to stated policies, this kiosk has blocked ‘treasured’ views towards the pier and along the coast on the elevated promenade which is one of the greatest pieces of municipal engineering in the town and region. A new seafront strategy is needed focusing on maintenance, conservation and de-cluttering while enhancing accessibility for active-travel and mitigating adverse impacts from roads and car-parking. | |
SP07 Managing Coastal Erosion and Flood Risk | None. | |
SP08 Transport Infrastructure | 5. To provide sufficient capacity for comfortable use and growth in numbers a policy to increase the width of the seafront shared path to at least 5m between the Stade and Carlisle Parade should be applied and supported. The Plan should recognise the Government’s ‘Gear Change’ document published in 2020 and set out how the Plan will support the objectives of that document and work with Active Travel England. 6.There is an over-emphasis on increasing highway capacity for motor traffic that is at odds with climate change, environment and active travel objectives. The council should also support interventions to re-balance the highway network in favour of active travel, such as: – the 1-way system at London Road/Norman Road, St Leonards where there is appallingly poor provision for pedestrians to cross – Support projects to reduce the dominance of motor traffic and parking along the seafront, such as by extending the ‘Pelham Boulevard’ footway widening eastwards to the Rock-a-Nore junction – Side road junction treatments to slow traffic and improve crossing conditions for pedestrians – 20mph speed limit in all residential streets, high streets, schools and local shopping streets Summarised to meet 100 word limit: 5. Recognise DfT’s ‘Gear Change’ (2020) and set out how the Plan will support the objectives of that document working with Active Travel England. 6.Measures to increase capacity for motor traffic is at odds with climate change, environment and health objectives. The council should support interventions to re-balance the highway network in favour of active travel, such as: – changing the 1-way system at London Road/Norman Road – extend ‘Pelham Boulevard’ footway widening eastwards to Rock-a-Nore – town / area wide 20mph speed limit and side road entry treatments – widen seafront shared path between The Stade and Carlisle Parade | |
SP09 Renewable Energy and Low Carbon Heating | None. | |
SP10 Community Facilities and Digital Infrastructure | None. | |
Development Focus Areas | ||
Hastings Central Focus Area (4.4-4.7) | 4.6 It is too simplistic to say the town centre needs a new purpose. It already has multiple purposes and it now needs to evolve and adapt to a changing context with the support of the planning system. Enhancing the public realm should go hand in hand with supporting the restoration of the numerous historic buildings and interiors that have been neglected over many decades which will improve the sense of place and generate community pride in the town. 4.7 There needs to be a public realm Master Planning approach with appropriate design guidance and palette. There is not enough emphasis on appreciation, protection and restoration of the many historic buildings in the Central Focus Area. Stronger policies are required on shopfront design, street-lighting, advertising, de-cluttering and the like. These should be developed in conjunction with projects such as the Trinity Triangle Heritage Action Zone and applied to the wider town centre and local centres as appropriate. | |
Bohemia Focus Area (4.8-4.10) | There are important green spaces, woods and mature individual trees in the Bohemia area that must be protected and incorporated within any development of new homes. The width of Bohemia Road provides an opportunity to improve provision for pedestrians and cyclists on this key direct route to and from Hastings town centre and station. | |
Little Ridge and Ashdown House Focus Area (4.11-4.12) | A clearer plan for a step change in public transport and cycling accessibility to the town centre, stations and other amenities is required if the proposed development in this edge of town area is not to result in significant additional car traffic. Also, to ensure sustainable development and support a ‘15 minute city’ concept, provision for more local, smaller shops, surgeries, school places etc. is required. | |
West marina and West St Leonards (4.13-4.14) | None | |
FA1 Hastings Central
| 3. Any new building should be no taller than the existing building. A taller building would be more visible from surrounding land across the whole town, be dominant amongst the relatively uniform roofscape and potentially harm strategic views such as to and from the Castle. Taller buildings would contradict Development Policy 5.7. 6. Disagree – taller buildings would adversely impact on the historic roofscape of the town centre and contradict Development Policy 5.7. | |
FA2 Bohemia
| 2. Existing mature trees should be protected. There is significant scope to reduce the width of Bohemia Road carriageway and provide protected space for cyclists, wider footways and better and more frequent crossings. | |
FA3 Little Ridge and Ashdown House
| See above. | |
FA4 West Marina and West St Leonards
| Site HL115 is a valuable and attractive ‘green gap’ supporting biodiversity and health objectives and should not be developed for housing. | |
Possible additional Focal Areas?
| Queen’s Road / Morrison’s car-park – nowhere to submit this in consultation document ? | |
Development Policies | 5.1 This should say we want consistently good standards of design. The award winning Stade development and pier set a standard to maintain (notwithstanding subsequent inappropriate alterations to the pier). Also recognise historical importance such as the elevated promenade which has been harmed by recent inappropriate development of the ugly and unused kiosk that compromises the setting of nearby listed shelters and the adjacent weather station and obstructs views along the coast, towards the pier and along the promenade itself. 5.7 Relevant to Ivy House Lane for example, visible from Land at North’s Seat and the AONB | |
DP1 Design – key principles
| 1.A-C These principles are inappropriately mixing a number of different aspects which should each have their own distinct policy (eg views vs character and existing heritage assets vs views across the borough) G A town-wide policy with a design palette / guidance is required to better manage these elements, restoring and reinstating historic shop fronts, over-lighting, inappropriate lighting, avoiding up-lighters etc. It is essential that lighting is appropriate and minimal and avoids harmful LED lighting (eg EasyLet sign on Queens Road) and digital advertising displays, including on bus stops). | |
DP2 Design – Space and accessibility standards
| None | |
DP3 Sustainable Design
| None | |
DP4 Flood risk and water quality
| None | |
DP5 Bio-diversity
| 5. This policy requires more consideration and scrutiny to avoid developers paying their way out of biodiversity obligations. | |
DP6 Green infrastructure
| 1 Remove the word ‘major’ from this clause. All green infrastructure should be assessed and considered for protection or enhancement to support climate change, biodiversity, health and greening objectives. 4.This is insufficient. To support climate change, biodiversity, health and greening objectives, all green assets should be assessed and considered for protection including those with no designated conservation status. 5. Existing protections need to be enhanced with a procedure that requires senior officer, councillor or committee sign-off for removal or substantive reduction in green assets such as tree felling and hedge removal. There is much evidence that mature trees have a much higher value for biodiversity than new saplings and therefore they should be afforded proportionately greater protection in policy. A much more proactive policy on provision, care and replacement of street trees is required, working with ESCC and local groups and residents as necessary. This will support climate change, health, greening and biodiversity objectives. See Mann Street, Hastings for examples of where space has been created within the carriageway for trees. Summarised to meet 100 word limit: 1 Remove ‘major’ from this clause. All green infrastructure should be assessed and considered for protection or enhancement to support climate change, biodiversity, health and greening objectives. 4.To support climate change, biodiversity, health and greening objectives, all green assets should be assessed and considered for protection including those with no designated conservation status. 5. Existing protections need to be enhanced with a procedure that requires senior officer sign-off for substantive harm to green assets such as tree felling/hedge removal. Give mature trees proportionately greater protection in policy than new trees. A better, more proactive policy on street trees is required. | |
DP7 Access, servicing and parking
| 8 Remove ‘where feasible’ from 1st sentence and strengthen second sentence as charging points will be required (eg in car-parks) to achieve electric vehicle objectives. Add requirement to support car-clubs. To support wider objectives, develop a policy with ESCC to reduce on-street parking particularly in historically valuable areas with high footfall and good non-car based accessibility. Use space for wider footways, cycle lanes, cycle parking, street cafes, parklets etc. Strike a better balance between the desire for an attractive seafront and the large swathes of surface car parking that dominate Rock-a-Nore/Pelham including incentivising use of existing town centre/underground parking facilities. | |
DP8 Planning obligations (Section 106)
| B Apply CLOCS (Construction Logistics and Community Safety) as a requirement for all construction sites and associated vehicles. https://www.youtube.com/watch?v=ZhTx8x3ydBQ | |
Other planning policies
|
OTHER PLANNING POLICIES A To support biodiversity, climate change, energy, health and tourism objectives a dark-skies policy and supporting technical advice is required to limit, manage and where appropriate, remove excessive lighting (such as adopted in the South Downs National Park). This should apply across the borough but is especially important in the urban fringes including where it can adversely impact the AONB, Hastings Country Park and other nature reserves.
5.8 Table 5.3 POLLUTION AND HAZARDS This should include stricter controls on the use of noisy machinery and equipment such as leaf blowers, chain-saws and the like, especially out of hours and at weekends. MANAGING THE IMPACT OF SHORT TERM VISITOR ACCOMMODATION A policy to control such development is supported and is overdue in areas such as Hastings Old Town. MANAGING BUILT HERITAGE Protection needs strengthening and should include the towns extensive C20 assets like the elevated promenade, other Sidney Little structures, St Leonards Church and others. SITE ALLOCATIONS FOR RENEWABLE ENERGY PRODUCTION This should be considered collectively with any offshore wind proposals. MANAGEMENT OF BIODIVERSITY NET GAIN AND URBAN GREENING To support climate change and biodiversity objectives develop policies to support wilding of urban spaces such as tree planting and wildflowers in appropriate green spaces (such as West Hill). Also collaborate with landowners, developers and adjoining authorities to protect and enhance continuous habitats and wildlife corridors. Summarised to meet 100 word limit: 5.8 Table 5.3 POLLUTION AND HAZARDS Tighten controls on noisy machinery/equipment eg leaf blowers, chain-saws etc. | |
Monitoring and Review
| Differentiate between on and off-street cycle parking/electric charging points (through development or on-highway) Add a measure of the number of car-club spaces enabled or delivered (on / off-highway) | |
Definitions of Key Terms
| None | |
References
| None | |
Appendix 1: Site allocation schedule and Figure 4.1 | ||
Site reference: TC1 Site name: Priory Street car park and ESK | Consider opportunities for removing 1-way system from the residential Cambridge Gardens to remove adverse impacts of motor traffic as well as simplifying pedestrian movements at junctions and directing 2-way traffic via Priory Street. Possibly in conjunction with site TC3. | |
Site reference: TC3 Site name: Queensbury House, Havelock Road | See comments on site ref TC1 | |
Site reference: TC8 Site name: Corner of Wellington Place and Albert Road; Cinema, Queens Road; 1-7 Wellington Place | Existing cinema building / façade on Albert Road-Queens Road should be retained. Should include a clause to protect and restore Queen’s Arcade as appropriate. It is unclear what the reference to securing parts of the site means. Permeability for pedestrian movement should be retained and enhanced as appropriate to support active travel objectives and natural surveillance. | |
Site reference: TC6 Site name: Former Post Office, Cambridge Road and former University of Brighton building, Priory Quarter (nb follows TC8 in consultation document) | It is unclear what the reference to securing Priory Square means. Permeability for pedestrian movement should be retained and enhanced as appropriate to support natural surveillance. | |
Site reference: TC9 Site name: Harold Place (site of former public conveniences) | High quality and accessible public conveniences are required in the town centre and should be incorporated as a requirement in any proposals. Reference to ‘landmark building’ is inappropriate and unnecessary. Re-word to be a building of high design quality and appropriate to the location which could be a multi-storey building of contemporary design no taller than adjacent buildings. Add the opportunity for closure of Pelham St as a through route to improve road safety, deter use for unauthorised parking and support improved public realm. | |
Site reference: TC10 Site name: Cornwallis Street car-park | Development should have zero or disabled only car-parking as has excellent public transport and amenity access. | |
Site reference HL21: Horntye | Add clause to retain and protect the trees to the Bohemia Road side of the site or remove that strip from the development site. | |
Site reference: HL80 Site name: Ashdown House, Sedlescombe Road North | As this is a highly visible landmark site on the primary highway entrance into the town and ‘highly contemporary design’ is proposed a design competition should be considered. | |
Site reference: HL7 Site name: Former St Leonards Academy (Grove School), Darwell Campus, Darwell Close | This site should not be developed as there is considerable impact on natural assets, woodland and open spaces and there are few or no amenities within easy walking distance and no provision for new amenities so it will be a car-based development on the urban fringe that goes against many other policies, including Climate Change and Biodiversity. | |
Site reference: HL19 Site name: Land adjacent to Sandrock Park, The Ridge | This site should not be developed as there is considerable impact on natural assets, woodland and open spaces and there are few or no amenities within easy walking distance and no provision for new amenities so it will be a car-based development on the urban fringe that goes against many other policies, including Climate Change and Biodiversity. The trees along the north side of the site must be retained for screening, biodiversity and climate change. Reference to impact on the adjacent St Helen’s Church is required | |
Site reference: HL9 Site name: Seaside Road, West St Leonards | Providing amenities that attract visitors without generating significant car traffic is problematic on this site as it does not have good public transport accessibility. Road access and parking are likely to prove challenging (for this and HL11) especially provision of a safe junction solution at Bexhill Road owing to the proximity of the signal controlled junction at Filsham Road. There is also a risk of retail uses abstracting custom from existing Bexhill Road businesses. | |
Site reference: HL113 Site name: Former Westerleigh School playing fields | To provide a connection with the past and add value, retain and restore historical buildings on the site, along with landmark trees. Apply TPOs to significant trees. | |
Site reference: HL115 Site name: Former West St Leonards Primary School, Bexhill Road | This site forms a ‘strategic’ green gap between buildings and should not be developed owing to adverse impacts on landscape, biodiversity and climate change | |
Site reference: HL63 Site name: Land at Rock Lane | This site is unsuitable for development owing to adverse impacts on the AONB, Biodiversity and Climate Change. There is no easy access to local amenities on foot. | |
Site reference: HL11 Site name: Cinque Ports Way (former Stamco timber yard and TA centre) | Road access and parking are likely to prove challenging (for this and HL9) especially provision of a safe junction solution at Bexhill Road owing to the proximity of the signal controlled junction at Filsham Road. | |
Site reference: SIEA2 Site name: Ivyhouse Lane | Add wording to recognise the adjacent cemetery and require appropriate screening, protection from noise, light pollution etc. | |