Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Representation ID: 23165

Received: 19/02/2017

Respondent: Rother Environmental Group

Representation Summary:

Item 3.2.17 of the SA main document, relating to Deprivation, states: 'Almost 9% of Rother households are classed as being in fuel poverty, which is low compared to
England & Wales, but high compared to the wider county and region'. Could RDC
provide more information, with specific numbers relating to England & Wales, the county and the region. This would better help in understanding to what extent this may be a RDC area issue, why this is and what solutions are being proposed. We have looked for the answer in the background information but it is not clear.

Full text:

Four comments:

1.Item 3.2.17 of the SA main document, relating to Deprivation, states: 'Almost 9% of Rother households are classed as being in fuel poverty, which is low compared to
England & Wales, but high compared to the wider county and region'. Could RDC
provide more information, with specific numbers relating to England & Wales, the county and the region. This would better help in understanding to what extent this may be a RDC area issue, why this is and what solutions are being proposed. We have looked for the answer in the background information but it is not clear.

2.SA Objective 11, page 65 of SA Appendices 1 & 2, shows the mean average annual gas and electricity consumption in the industrial and commercial sector. The figure for Rother in 2014 was 824,053 kWh, which is almost double the East Sussex figure of 418,633 kWh and the South East figure of 443,867 kWh. Is there an explanation as to why Rother's figure is so much higher and is it an issue that RDC should seek to address?

3.It is noted generally that many of the data sets date back to 2010 or before and are therefore in need of updating. The 'concentration of air pollutants' (SA Objective 10) for instance is based on 2005 data, now more than 11 years ago. With the increase in diesel cars air pollution in many cities has been getting worse, which is contrary to previous assumptions that air pollution will improve as cars got cleaner.

4. We have looked at the matrix to see how it rates the various policies against
biodiversity and the environment and we do not agree with a number of the ratings given and these would need further investigation.

a. The following site allocations could potentially have a negative impact on biodiversity due to the possible presence of protected species (scrub and rough grassland habitats) but there does not appear to be provision for them on site (they are mainly shown as neutral):
HAS2
BRO1 - showing as positive but probably negative
BRO2
CAT1
HUR1
IDE1
NOR1
RHA1
WES2
WES3
b. CAM1 and 2 are showing as positive but are more likely to be neutral unless there
are positive enhancements proposed which we could not see.

c. BEC2 - showing as negative but with the large amenity area it could have a positive impact if well designed and multi-functional.

d. RHA2 - showing as positive but no indication why. More likely to be neutral or even negative given that increased commercial use will mean more traffic and a deterioration in local air quality and the designated site habitats are sensitive to air pollution.

e. WES1 - as with BEC2 this could be positive if the recreation area is designed with
biodiversity and is multi-functional.