Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24524

Received: 07/12/2018

Respondent: RSPB

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Four of the allocated sites are very close to the boundary of the Dungeness Complex.

There are two allocated sites in Rye Harbour (RHA1 and RHA2) that adjoin the Dungeness Complex. We note that Policies RHA1 and RHA2 do not state that proposals will be permitted where "there is no adverse impact on the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA or Ramsar site", unlike in Policy CAM2 (and in respect of the SSSI, CAM1). We are not sure why there is this inconsistency and would recommend that this requirement is incorporated within Policies RHA1 and RHA2. We were also unsure why this requirement is not applied to all the site allocations that have been subjected to an Appropriate Assessment in the HRA.

Full text:

As landholders within the Rother district, we would like the opportunity to be present for discussions where there could be possible impacts to the Dungeness Complex.

Four of the allocated sites are very close to the boundary of the Dungeness Complex. Of the two in Camber both adjoin the SSSI-designated sand dunes that are part of the Complex. Policy CAM1 states that proposals will be permitted where "there is no adverse impact on the adjacent Dungeness, Romney Marsh and Rye Bay SSSI". Policy CAM2 states that proposals will be permitted where "there is no adverse impact on the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA or Ramsar site, including the sand dunes". Given that CAM1 is situated 130m from the SPA and Ramsar Site it seems to us that the reference to the SPA and Ramsar Site should also be incorporated in the Policy CAM1.

There are two allocated sites in Rye Harbour (RHA1 and RHA2) that adjoin the Dungeness Complex. We note that Policies RHA1 and RHA2 do not state that proposals will be permitted where "there is no adverse impact on the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA or Ramsar site", unlike in Policy CAM2 (and in respect of the SSSI, CAM1). We are not sure why there is this inconsistency and would recommend that this requirement is incorporated within Policies RHA1 and RHA2. We were also unsure why this requirement is not applied to all the site allocations that have been subjected to an Appropriate Assessment in the HRA.