Minerals Planning

Safeguarding

The DaSA document correctly identifies at 2.15 that the East Sussex, South Downs and Brighton & Hove WMP and the WMSP (once adopted) are part of the development Plan for the area. However, apart from the new safeguarded area at Broomhill, it does not refer to the provisions of these Plans which apply to the Rother Local Plan area. These include a number of safeguarded wharves and railheads, facilities for concrete batching, coated materials manufacture and other concrete products, and land-won mineral resources. These are set out in SP 8, SP 9 and SP10 of the WMSP and should be identified in the DaSA.

In particular, the two areas of safeguarded wharves at Rye Port have not been specifically referenced in the DaSA. There is a reference in 15.101 to the use of Rye wharf for aggregate imports (sometimes known as Rastrum's wharf). However, there is a further safeguarded wharf in Rye Harbour Road, which is currently vacant and was previously known as the old "ARC" wharf.

The proposed policy (RHA2), which incorporates the two aforementioned wharves, would permit B1, B2 and B8 uses on this site where various criteria are met. Our policies WMP 15 and SP 9 state that in such areas "capacity for landing, processing and handling and associated storage of minerals at wharves will be safeguarded. Alternative use proposals would need to demonstrate that there is no net loss of capacity within a port. Proposals for non-minerals development on or near the site that would prejudice the use of the facility, or result in incompatible development, should not be permitted".

At this stage in the DaSA preparation it is not possible to determine the exact type of development which could result through Policy RHA2 and the impact it would have on wharf capacity. We would suggest that an additional criterion is added to policy RHA2 to reflect this. E.g. "(v) proposals should demonstrate that the capacity for landing, processing and handling and associated storage of minerals at wharves is safeguarded and that there is no net loss of capacity within Rye Port".