Introduction
To be fair it is difficult to comment on a local plan trapped within both a process no longer suited to an age of increasing uncertainty due to global warming, and such a fixed model of forward planning which cannot embrace the longer term vision which is now needed.
Add to that the demand for high housing targets set within a framework of planning and land law which leaves a large number of empty buildings and undeveloped sites vacant and the validity of the whole regime comes into question. Though the fundamental point being missed here is that while the plan is only for 20 years, the buildings it may well give rise to should be constructed to last for at least the next 100 years[1]. This contradiction is no more clearly exemplified than in two policies within the local plan:
- Some sites on Bexhill Road have been identified as having a higher flood risk by 2070-2125 and so will require a flood risk assessment including a SUDS assessment. While it is great in these isolated examples that the longer term is recognised, why only here and just how is SUDS supposed to work in a high flood risk area? Given the present rate of ice melt at both poles the whole of Bexhill Road will likely be under water by the end of the century.
- On the other hand policy 9 states it is not possible to avoid flood risk while at the same time Hastings town centre is being identified for more development! Reality avoided?
Is it surprising that the public are confused by how this plan is presented?
So, the style and content of the plan in an age of worsening global warming feels both broad and generic and as such risks overlooking some of the deeper place specific challenges that define Hastings. While the plan does acknowledge rising deprivation, there is scope to engage with the structural realities underpinning the towns low wage economy and wider social context even though these may be addressed in other strategies. How these impinge on spatial planning is not fully recognised especially with regard to truly locally affordable housing provision. For example, despite repeated requests there was no public consultation involvement of town planners in formulating the housing strategy. There is also a missed opportunity to explore the tension between narratives of creativity and the lived experience of deprivation. Stretching the truth will not of itself create the type of urban spaces we need e.g Queens Road as a ‘creative quarter’ and the station forecourt as a ‘town square’. Is the general public really seen as that naïve? These two statements alone show how little the plan’s authors understand the potential benefits of a fully worked out urban design strategy. Lessons appear not to have been learnt from the failure of the last regeneration attempt in the town, which applied a standard, rather than a Hastings appropriate, model of regeneration. Expensive empty buildings stand as a monument to a mis-guided approach.
Moreover, in a town with so much history and so many conservation areas without even any appraisals, and thus many important buildings at risk from flooding, there really should be more emphasis on the possibility of more contextually contingent housing models especially with the higher densities now being proposed. The Heritage study misses the serious risk that flooding creates to the town’s history, the potential for more intensive use of existing buildings, and how the proposed more dense development in existing areas is to be assessed. Again, and again vague policies leave designers of buildings (which by their nature are specific things) to ask: ‘where is the specific guidance I need to design?’
Policy Comments
SP1 4.6 Flood risk mitigation: the who and the how are missing here. Is this realistic given the likely unavailability of insurance for both the old and the proposed new houses in flood risk areas? Nobody has yet shown how you mitigate for essential public services that are at risk from flooding.
SP1 4.7 This is supposed to be a spatial plan yet this policy only recognises two dimensions. Development will have to go higher more than hitherto, and suitable sites are available to do so though they are not identified in the draft plan.
SP1 4.8 Why then have not all potential brownfield sites been identified?
SP1 4.9 The density zone map is not fairly presented as the ratios between zones are not equal. This is grossly misleading.
SP1 4.10 Some of the assumptions in the density study are flawed. For example the assumption that high density areas should be made more dense because they have good services and transport. This gravitates against areas on the outer fringes which may have more suitable sites for tall buildings but might then, by their existence, justify better transport (buses, car share/clubs, cycle routes). They may also be better visually if well designed rather than crammed in against established areas.
SP1 4.11 This is good, but requires much better understanding of design than is presently contained in current HBC design guidance. A small sites/infill policy and guide are needed, possibly through Supplementary Planning Guidance.
SP1 4.12 The contribution that so called ‘windfall’ sites could make is underestimated but to make the numbers work they would be better termed as ‘infill’ and supported by specific design guidance. This particularly applies to conservation areas where the default decision is presently to refuse permission. A proactive design guide would enable more small sites to come forward if an initial approval in principle (rather than a detailed design) approach was possible in conservation areas. The expense of a full application in conservation areas inevitably puts some people off applying for permission on infill sites.
SP1 4.13 If these sites have such potential why do they not have Local Development Orders (LDOs)? The masterplan for the convent must include for partial demolition to realise it’s full potential e.g for a tall building or two. Such densification could pay for a ‘crystal palace’ to be built over the chapel to make it not only a great tourist attraction but also a way of gathering solar gains to heat the new housing. Similarly with the arcade fronting St.Mary in the Castle, this will need to be sacrificed to build a sea defence wall if the church itself is to be saved. The central Hastings area must include for flooding of the lowest parts at least, but how is this to be determined? Building a first floor street might be one way of doing this.
There is no recognition in this key policy for the effects that flooding will have on key infrastructure, heritage, or visitor amenity let alone the Priory Meadow shops and town hall area. In point 10 of the Directing Growth policy panel the borough has made statements like this before but never stood by them. Hitherto there has been precious little acknowledgement of innovative design. A clear design guide is needed which promotes better use of design and access statements to explain how designs are developed. Planners need to up their game on use of this valuable design tool.
SP2 Making housing more affordable will necessarily mean greater density for the usual commercial developers and so clearer guidance is needed on shared amenity spaces within such schemes. Gypsy and traveller sites are necessarily low density, which places an undue space burden on other areas but there are already sites available that may meet this need and so could have been identified. There is considerable potential for infill housing in existing Registered Provider development sites that have yet to be identified and have the potential to even out densities across the town. More work needs to be done on this, particularly on the potential that increased land values could be transferred into making existing buildings more sustainable. The borough does keep a self or custom build register but there are no sites on it, which must in a large part be due to them making a charge for it. That charge is not made by most other councils and must be dropped. Self-build could be encouraged, just like infill, with Supplementary Planning Policy or even LDOs. In terms of affordable housing the recognition that much of our existing housing stock could be thermally upgraded by judiciously increasing its density by upward and/or outward expansion could be identified by examples and followed by targeted SPG. This potential is simply not recognised in the draft plan. 4.4 Recognises HBC owned land but, along with other publicly owned land in the borough, of which there is plenty, it is hard to identify. The Council, and indeed The Planning Inspectorate and Homes England, need to canvass the government for a publicly accessible register of unused or under used public land holdings and make them available for self build free until any permitted developments are fully occupied. Indeed, providing unused public land free for affordable housing could be a practical way to make it work financially. Church authorities especially perhaps should be conscious of how their land holdings could contribute to housing need. All this would very much oil the wheels of development and take advantage of the human ‘nest building’ drive. The SHELAA assessment is fundamentally flawed in not accounting for all the sites that could become available if certain land owners were approached. The suitability of sites appears to be based on developer type standard houses and densities rather than what creativity and higher densities might achieve,
SP3 No particular comments on this section other than to say that a close eye needs to be kept on changing work patterns including what the increased use of Artificial Intelligence will have on the nature of work. Business development also needs to be more open to mixing uses on commercial sites including housing where directly associated with the work space. The policy in 5a is welcome but only alongside more sustainable transport provision including shared or community car use.
SP4 Generally not much comment except that the effects of flood risks have not been addressed in this policy. Given the national increase in online shopping there needs to be a detailed assessment of the potential reduction of the extent of shopping streets at their ends to create more potential housing. Bohemia Road for example is certainly going that way but could be encouraged by a clear policy, some traffic calming measures and showing good examples in a shop alteration design guide. Replacing narrow frontage/deep plan shops with wide frontage/shallow plans might be one way to keep active street frontages.
SP5 The aims set out in Meeting the Challenge of Climate Change do not relate to the identification of flood risk areas, including the town centre, for development. An obvious contradiction that must be addressed in any revision to the draft plan. In particular, the plan says nothing about sewage disposal in areas identified for development or if other essential public services have capacity for the planned growth in the town. A longer-term issue perhaps, though unlikely to be beyond the next plan, is the potential breeching of the cliff face at the Bulverhythe gap which will cut off the Hastings south coast rail line. Other places along the south coast may go first of course including much of the Pevensey Marsh link rail line. Are Railtrack and central government looking at this? No mention in the plan.
SP6 This low carbon policy is laced through with words such as ‘seek’, ‘support’, ‘explore’ etc with little or no statements of firm decision making. This is not good enough. In particular the use of solar panels and domestic scale wind turbines should have clear design and application guidance on their use including on listed buildings and in conservation areas. In the long history of Hastings such use will be short term before other low carbon technical solutions are established but could contribute to saving our shared heritage.
SP7 See various comments above but the short termism of the present local plan system does not help in establishing the longer term view which is needed to protect our historic buildings. We really do need to establish a strategy now for possible relocation of some buildings in the most vulnerable locations. We cannot go on ‘kicking the ball down the road’.
SP8 4.96 Identifies the need for designated wildlife sites to be protected but might not others be created in some of our wooded valleys? For example in the deep wooded part of the Summerfields valley? If fenced in and properly managed this could form a possible beaver habitat, which would reduce flood surge in the town centre while at the same time releasing land around the sports centre for housing development. Several hundred flats could be built on this site alone.
SP9 more specifics are needed here if developers, potential new property owners are to understand their level of flood risk but this seems unlikely against a very unpredictable future. As building owners face increasing difficulties in obtaining mortgages and insurance in flood risk areas this will determine development location more than anything which can be stated in the local plan. Talk of resilience is all but a nonsense against this backdrop.
SP10 This is very much an East Sussex responsibility and they need to take a more sustainable approach to car use in particular. Hitherto their policies in principle appear to support reduced car use but they go on asking for high car parking numbers in urban developments and also will not approve development centred shared car use in, for example, apartment blocks. Both ESCC and HBC have also not supported development of Greenway routes in Hastings, sometimes even allowing development to block previously agreed routes e.g at Hastings station. On-street car charging must be installed rather than within existing carbon fuel stations so that eventually those ‘petrol stations’ can be freed for housing development.
SC3 7.152 Whilst it is good to see some positive words supporting more sustainable buildings there are again too few specifics and too many get out clauses. This one has been selected because it is illustrative of how far we still have to travel in terms of sustainable design. In the early 1990s Brenda and Robert Vale designed and built a house[2] to demonstrate principles they had set down back as far as 1975. This particular sub-clause states a target figure of 100 litres per day for water consumption, while the Vale house achieved an actual use (laundry, dishes, drinking and cooking, and personal hygiene) of 39 litres per person/day…..some way to go then!
CONCLUSION
Whilst this plan is marginally better than the current one it still does not deal with the major issues facing the town, it seeks refuge in the status quo and the familiar. Whilst in theory at least we have a planning system that is use-class based rather than the rigid zoning schemes of some countries, it is also meant to be a discretionary system but rarely works that way. The discretion required now is to take off the blinkers, build a continuing dialogue with local people and think differently. It’s as if the planning establishment, even in a time of global warming and dire housing need is afraid to be innovative. The intended approach to development in conservation areas, the misguided logic behind where higher density projects are placed, and the apparent blindness to the impacts of global warming are there but paradoxically not responded to at the same time. The people of Hastings can only hope that when the public inquiry is held the planning inspector will have greater awareness and vision than presents itself in this inadequate document. In particular with regard to affordable housing there is enough public land standing empty in Hastings that could subsidise such housing if central government permitted it to be given at no cost for that purpose.
K G DAVIS MA DipArch DipBuildCons DipTP.
Chair Hastings Urban Design Group 1/04/26
[1] Unless of course we make greater use of buildings which can easily be relocated.
[2] The New Autonomous House, Brenda and Robert Vale, Thames and Hudson Ltd, 1990.