The Royal Society for the Protection of Birds (RSPB) welcomes the opportunity to comment on Rother District Council's Development and Site Allocations (DaSA) Local Plan.

We welcome the wording within policy DEN5 (IV), to include 'multi-functional' delivery of objectives. In order to strengthen this and reduce failure of delivery we would recommend including examples/prompts within the wording such as;

Revised wording:
'.......... The provision of habitats and support for biodiversity including flower rich grassland in each treatment and conveyance stage; reinforcing local landscape character with appropriate choices of planting; enhancing the design of the development with the appropriate use of soft and hard landscape SuDS treatments. Where these form part of the street scape and frontage any formal planting of eg. bioretention and rain gardens are of high wildlife value to pollinators; provision of open space/recreation by making appropriate multi-functional use of treatment stages; ...........'

We note that within policy DEN5 (IV) it requires that "applicants should demonstrate that arrangements are in place for ongoing maintenance of SuDS over the lifetime of the development". This requirement does not however provide sufficient long-term protection to the SAC.

We urge the policy to include that a specialist management company is in place before the first occupation on the site and that there are step-in rights that the Local Authority should have secured to ensure SuDS are managed in perpetuity, (in the event of the failings of the management company in place).

Revised wording:
'Applicants should demonstrate that arrangements are in place for ongoing maintenance of SuDS over the lifetime of the development. This should including a specialist management company to be in place before the first occupation and the step-in rights for the Local Authority which will need to be secured to ensure SuDS are managed in perpetuity in the event of failure of the management company.'

It's encouraging that reference is made to 'incorporate at least two stages of suitable treatment' (IV) however we would encourage you to emphasis 'source control' as one of those treatments.

Revised wording:
'Within the Pevensey Levels Hydrological Catchment Area, unless demonstrably inappropriate, SuDS designs should incorporate at least two stages of suitable treatment, with particular emphasis on source control features being one of those stages; and'