QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Showing comments and forms 1 to 30 of 32

Comment

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

Representation ID: 21925

Received: 18/12/2016

Respondent: Ms Val Hunnisett

Representation Summary:

In general agree. But there is an inconsistency between the 'gap' for Combe Valley and the 'development by others' on this plan. Perhaps some amendment is needed. http://www.bovishomes.co.uk/northeastbexhill/masterplan/

Full text:

In general agree. But there is an inconsistency between the 'gap' for Combe Valley and the 'development by others' on this plan. Perhaps some amendment is needed. http://www.bovishomes.co.uk/northeastbexhill/masterplan/

Comment

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

Representation ID: 21969

Received: 20/12/2016

Respondent: Vanessa Crouch

Agent: Stiles Harold Williams

Representation Summary:

No comment

Full text:

No comment

Comment

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

Representation ID: 22166

Received: 31/01/2017

Respondent: Rye Town Council

Representation Summary:

Q18 - Strategic Gaps - Rye-Rye Harbour to be extended, Support the proposed definition of strategic gap, but given the unique nature and profile of Rye could be extended to gaps on the Eastern and Western approaches: New Road, Military Road and New Winchelsea Rd

Full text:

Comments by Rye Town Council on the Rother DC Development and Site Allocations (DaSA) (Local Plan)


1.The 2014 Core Strategy recognised that it needed a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies. It would need to tackle two specific issues affecting dwellings: to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

2. It is noted that the DaSA Plan records the preferred sites across Rother District in two categories:

- sites where no Neighbourhood Plan (NP) is being made
- sites identified in Neighbourhood Plans; Rye is in this category.

4. Rye Town Council has considered the DaSA Plan in its three parts.

- It has NOTED Part A - the Context: (the Core Strategy), with its development requirements (not for review), and related policies. Where NPs are being prepared these are listed (Rye is listed).
- It COMMENTS on Part B - Development Policies as below. Many of these draft policies affect the RNP. Some have argued that it would have been useful to have had these as Rye was drafting its RNP, but we are where we are. We have been specifically encouraged to consider the definitive housing requirements for the Rye Neighbourhood Plan area (Rye targets have already been reconciled by Rother officers) and the policies for Development Boundaries and "Gaps".

- It has NOTED Part C - There are the Site Allocations for those parishes where no NP is being made. The only site allocations in this section relating to Rye are in Rye Harbour which we have considered in the RNP. Also there is discussion of traveller sites including one in Rye.

5. Whereas we had, at first sight, presumed that Part B might conflict with the emerging Rye NP, this is not the case. As agreed, here is the Rye TC comments in consolidated form on the three parts of DaSA.

The Rother District Development and Site Allocations Local Plan

Part A - Neighbourhood Plans (NP) - Rye NP is listed as being drafted. Version 8 emerging plan is on the website. www.ryeneighbourhoodplan.org.uk
Rother Officers have reconciled numbers in the RNP with the DaSA.

Part B Q1 - Water Efficiency -Support approach: adopt standard through Bldg Regs

Part B Q2-4 - Suggest Rye Harbour for turbines and biomass. Solar panels are not mentioned and could be fitted to large industrial and educational buildings in Rye. Support approach - should adopt national guidance standards.

Q5 - Retention of sites of social or economic value - Support approach and proposed criteria for retentions.

Q6 - Equestrian development - Support approach - as drafted

Q7 - Affordable Housing - Support Option B, in line with PPG (None under 10; 30% over 10 dwellings)

Q8 - Access to housing and space standards (Older people) - Support Option E

Q9 - 10 - Custom and self-build housing - 1% of target of 160 houses= 2 for Rye Rye could support 5 homes which is around 3%. Support Option D; a site is identified in Rye NP

Q11 - External residential areas - Support proposed policy

Q12 - Extensions to residential gardens - Support proposed policy

Q13 - Extensions and alterations, including annexes - Support proposed policy

Q14 - Boundary treatments and accesses -Support proposed policy

Q15 - Shopfronts and advertising - Strongly support proposed (more prescriptive) policy

Holiday Sites - Support proposed policy

Q16 - Existing Businesses and Sites - Support proposed policy

Q17 - Landscape and AONB - Support proposed policy

Q18 - Strategic Gaps - Rye-Rye Harbour to be extended Support the proposed definition of strategic gap, but given the unique nature and profile of Rye could be extended to gaps on the Eastern and Western approaches: New Road, Military Road and New Winchelsea Rd

Q19 - Bio diversity and Green Space - Support the policy approach

Q20 - Drainage - Support the policy approach

Q21 - Land Stability - There is a risk of (sandstone) rockfall around Rye. The rock structure is of similar composition to cliff structure of Fairlight / Pett . The risk locations include East, South and West Citadel; land above Military Rd and at Cadborough. Rye should be specifically identified and a similar policy applied to land at risk above and below where historical falls have occurred. Propose inclusion of Rye as for Fairlight and Pett Level

Q22 - Environmental Pollution - Support policy approach

Q23 - Comprehensive Development -Support policy approach

Q24 - Development Boundaries - The RNP proposes two changes to the development boundary of Rye. Policy approach should cater for this.

Part C - Targets
Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour), 10-20,000 sqm employment. Dwellings Number Breakdown has been agreed with Rother DC Officers:

Total Completions Large Site Small Site Windfall
355 198 22 6 22
Balance: 107

Rye Harbour - Allocation to Rye Harbour - 40 dwellings - Support policy approach; as directed by Rother DC, and for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish)
The 40 are included in the Rye target of 400 as above.

Traveller sites - Traveller Site - Rye Gritting Depot is listed but not a preferred option - Support policy approach


Comment

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

Representation ID: 22241

Received: 20/02/2017

Respondent: AmicusHorizon Ltd (Rother Homes)

Representation Summary:

No - it is hard to justify in some circumstances keeping a Strategic Gap. Flexibility to allow developments to be considered on a scheme by scheme basis. There may be some sites that are suitable for self build or custom build

Full text:

No - it is hard to justify in some circumstances keeping a Strategic Gap. Flexibility to allow developments to be considered on a scheme by scheme basis. There may be some sites that are suitable for self build or custom build

Comment

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

Representation ID: 22247

Received: 15/02/2017

Respondent: Crowhurst Parish Council

Representation Summary:

Crowhurst Parish Council (CPC)and its Neighbourhood Plan Group do, in principle, agree with Question 19. However, the removal of the Strategic Gap (SG) to the North/Northwest of Crowhurst concerns the CPC. It is felt this area does play an important role in separating the settlements of Crowhurst, Battle and Telham.
The extension of the SG to the South/Southeast of Crowhurst is supported provided the final boundary is agreed between Crowhurst and RDC. Our emerging Neighbourhood Plan may need to amend the current development boundary. It is vital that we are able to objectively assess and allocate sites.

Full text:

In principle, Crowhurst Parish Council and its Neighbourhood Plan Group do agree that development within Strategic Gaps should be carefully controlled and support enhancement of the Gaps. However, as detailed below, we do have some concerns about the proposed areas of Strategic Gap around Crowhurst Parish.
The Core Strategy defines a strategic gap as 'area of largely open land between settlements, which helps to maintain the separate identity and amenity of settlements and prevent them merging together. The boundaries are defined in the Local Development Framework.' Whilst it is noted the 2006 plan primarily focussed on the gap between Hastings and Battle, it is considered that Rother District Council (RDC)should consider the term more broadly, particularly as Crowhurst is located sensitively between settlements which are subject to a greater growth, namely Battle, Bexhill and Hastings. The existing gaps between these settlements and Crowhurst should therefore be maintained in order that the identity of the village's individual character is maintained.
In terms of the suggested deletion of part of the strategic gaps to the North/Northwest of Crowhurst, it should be noted the land subject to deletion from the strategic gap does still provide a physical and valuable gap between the settlements of Battle, Telham and Crowhurst itself. Furthermore, the weight applied to criteria such as visibility and inter-visibility, whilst being relevant, are not the only factors that are relevant and these do underplay the wider role of this land in maintaining appropriate physical separation between settlements, especially as the varying topography doesn't always afford long range views between the gap edges. Thus using such limited criteria should be applied with caution. It is considered such land does still play a valuable role in a physical sense in maintaining the identity of the settlements, including Crowhurst, and are valuable as a protective tool in locations such as this, which are subject to development pressures on account of proximity to railway stations and sustainable hubs. Whilst it is considered the deletion of this land will not have an immediate impact on Crowhurst, the need to alter such boundaries and the gap area when it remains a valuable tool is questioned.
In terms of the extension to the strategic gap to the south, this approach is generally supported as it will provide greater additional protection to the village of Crowhurst but this support is on the basis the boundary of the gap is not yet final and shall, in its final form, be consistent and have regard to the Crowhurst Neighbourhood Plan which will contain the site allocations and a revised village development boundary. As the neighbourhood plan is being prepared alongside the DaSA plan and will allocate the development required for Crowhurst, it is essential that the strategic gap boundaries do not influence or prohibit our process of objectively assessing and allocating sites for our plan and its other policies and therefore it is assumed the boundaries of the strategic gap are not fixed at this stage, pending the preparation of the Neighbourhood Plan. In order to ensure that both plans proceed appropriately, it is envisaged that there will be regular communication between Crowhurst and Rother in order the aspirations of the Neighbourhood Plan and the District Plan are compatible throughout the process and also at adoption. This need for collaborative working and communication also applies to the other boundaries of the strategic gap or other policies which may require alteration on account of the outcomes of the Neighbourhood Plan.

Comment

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

Representation ID: 22306

Received: 15/02/2017

Respondent: Fairlight Parish Council

Representation Summary:

While supporting the strategic gap, and understanding the rationale for the extension, we would like to have time to discuss this matter with the residents living in the immediate vicinity, and the wider village, to ascertain their views before a final decision is made.

Fairlight Parish Council is currently developing a Neighbourhood Plan and it would be much better for this matter to be addressed as part of that process, rather than residents being presented with a fait accompli which may undermine trust in the openness and integrity of the Neighbourhood Plan.

Full text:

While supporting the strategic gap, and understanding the rationale for the extension, we would like to have time to discuss this matter with the residents living in the immediate vicinity, and the wider village, to ascertain their views before a final decision is made.

Fairlight Parish Council is currently developing a Neighbourhood Plan and it would be much better for this matter to be addressed as part of that process, rather than residents being presented with a fait accompli which may undermine trust in the openness and integrity of the Neighbourhood Plan.

Comment

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

Representation ID: 22324

Received: 16/02/2017

Respondent: Mr David Wright

Representation Summary:

Fully support extension of strategic gap in Fairlight

Full text:

Fully support extension of strategic gap in Fairlight

Comment

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

Representation ID: 22338

Received: 16/02/2017

Respondent: Mr Derek GREENUP

Representation Summary:

I live in Fairlight.
I am in total agreement with the proposal as it makes great sense in terms of a rational clear approach.Well done

Full text:

I live in Fairlight.
I am in total agreement with the proposal as it makes great sense in terms of a rational clear approach.Well done

Comment

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

Representation ID: 22341

Received: 16/02/2017

Respondent: Mrs Carole Gallagher

Representation Summary:

I wish to support Rother's intention to increase the strategic gap in Fairlight as shown on the Fairlight Map 1

Full text:

I wish to support Rother's intention to increase the strategic gap in Fairlight as shown on the Fairlight Map 1

Comment

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

Representation ID: 22376

Received: 16/02/2017

Respondent: linda parker

Representation Summary:

yes

Full text:

yes

Comment

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

Representation ID: 22403

Received: 17/02/2017

Respondent: Ticehurst Parish Council

Representation Summary:

Within the strategic gaps, developments should be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive and not detract from the openness of the area.
Enhancement of the Gaps through effective landscape management that strengthens and reinforces their significance as protected landscape areas will be supported.
Strengthen the policy to include gaps between wards within parishes and further more strategic gaps between hamlets as recommended in emerging Neighbourhood Plan.

Full text:

Within the strategic gaps, developments should be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive and not detract from the openness of the area.
Enhancement of the Gaps through effective landscape management that strengthens and reinforces their significance as protected landscape areas will be supported.
Strengthen the policy to include gaps between wards within parishes and further more strategic gaps between hamlets as recommended in emerging Neighbourhood Plan.

Comment

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

Representation ID: 22411

Received: 17/02/2017

Respondent: mrs wendy colegate

Representation Summary:

I agree with the proposed definition of the extension of the Strategic Gap relating to Fairlight/Fairlight Cove/Hastings. I am also in favour of the proposal to create soft/screening boundaries to enhance visual aspects and long views of these gaps e.g. screening around the large white modern building which replaced Warren Farm in Fairlight.

Full text:

I agree with the proposed definition of the extension of the Strategic Gap relating to Fairlight/Fairlight Cove/Hastings. I am also in favour of the proposal to create soft/screening boundaries to enhance visual aspects and long views of these gaps e.g. screening around the large white modern building which replaced Warren Farm in Fairlight.

Comment

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

Representation ID: 22430

Received: 17/02/2017

Respondent: Northiam Conservation Society

Representation Summary:

NCS agree with the defined strategic gaps.

Full text:

NCS agree with the defined strategic gaps.

Comment

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

Representation ID: 22511

Received: 18/02/2017

Respondent: Rye Conservation Society

Representation Summary:

Rye Conservation Society agrees to the proposed policy and wording.

Full text:

Rye Conservation Society agrees to the proposed policy and wording.

Comment

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

Representation ID: 22568

Received: 19/02/2017

Respondent: Mrs Sheena Carmichael

Representation Summary:

Has Rother considered the use of Strategic Gaps within the rural areas, in order to prevent ribbon development between villages?

Full text:

Has Rother considered the use of Strategic Gaps within the rural areas, in order to prevent ribbon development between villages?

Comment

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

Representation ID: 22588

Received: 19/02/2017

Respondent: Mrs Elizabeth Wright

Representation Summary:

The area is of unique scenic beauty. Ribbon development would soon destroy this.

Extension of the strategic gap as proposed would be the most effective way of preserving the area.

Full text:

The landscape in the area is of high scenic quality. Existing development along Battery Road already detracts from the character of the area to some extent but we agree that the current arrangement and character of the houses gives a feel of low density.

We believe that the creation and maintenance of strategic gaps is fundamental to maintaining the character and feel of this unique area and that there is a strong case for extending the gap as proposed. Specifically:

* Further ribbon development along Fairlight Road would detract from the character of the area and undermine the current separation between Fairlight and Fairlight Cove (para 8.4)

* It is particularly important that pressures for infill development between the northern boundary of the existing gap and Battery Hill are resisted (para 8.16). An extension of the strategic gap as proposed would be the most effective way of achieving this

* We strongly agree that Warren Road is/should be at the heart of the strategic gap and that infill development along it should be resisted (para 8.19)

For these reasons we support the proposal to extend the strategic gap as suggested in Fairlight Map

Comment

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

Representation ID: 22595

Received: 19/02/2017

Respondent: Mr Haydon Luke

Representation Summary:

We live in the Hastings/Fairlight SG. Thus the matter is directly relevant so we strongly support the concept of SGs.
Proposed extension makes this SG coherent, safeguarding several vulnerable fields important for the landscape especially for the view to the north and northwest, observed from Firehills/coast.
Wooded gardens and low housing density in extension to SG maintain its rural character.
Woods along Warren Road and the Wood Field area are necessary to the quality of the landscape. Warren Road is unmade maintaining the rural nature of the area. Infill here should be resisted as detrimental to SG.

Full text:

We live in the Hastings/Fairlight SG. Thus the matter is directly relevant so we strongly support the concept of SGs.
Proposed extension makes this SG coherent, safeguarding several vulnerable fields important for the landscape especially for the view to the north and northwest, observed from Firehills/coast.
Wooded gardens and low housing density in extension to SG maintain its rural character.
Woods along Warren Road and the Wood Field area are necessary to the quality of the landscape. Warren Road is unmade maintaining the rural nature of the area. Infill here should be resisted as detrimental to SG.

Comment

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

Representation ID: 22667

Received: 20/02/2017

Respondent: CPRE Sussex

Representation Summary:

We agree with the maintenance of Strategic Gaps and the cases referred to in your policy. We would suggest in addition the following:
Rye and Playden
Battle and Crowhurst
Broad Oak and Brede/Cackle Street
Battle and Netherfield

Also we believe that there may be other opportunities in Rother for the use of a similar policy, which we would call 'Green Wedges', where the countryside is able to be seen from within a development boundary. Examples would be to the south and north of the High Street in Battle.

Full text:

We agree with the maintenance of Strategic Gaps and the cases referred to in your policy. We would suggest in addition the following:
Rye and Playden
Battle and Crowhurst
Broad Oak and Brede/Cackle Street
Battle and Netherfield

Also we believe that there may be other opportunities in Rother for the use of a similar policy, which we would call 'Green Wedges', where the countryside is able to be seen from within a development boundary. Examples would be to the south and north of the High Street in Battle.

Comment

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

Representation ID: 22684

Received: 20/02/2017

Respondent: Simon Apperley

Representation Summary:

The extension to the Strategic Gap to include areas of existing settlement would most likely create a significant hurdle to any future development, both positive and negative. The use of the Fairlight Neighbourhood Plan and good general planning policies would most likely prevent negative development, whilst allowing positive development - which would be in the interest of current and future residents of Fairlight.

Full text:

My comment regards the proposal to extend the existing strategic gap between Hastings and Fairlight to include an area which incorporates existing settlement, around roads such as Hill Road, The Close, Warren Road and Battery Hill.

In my capacity as a member of the "Design Working Group" for the Fairlight Parish Neighbourhood Plan, I was involved in a significant discussion around the proposals to cover existing settlement within the Fairlight Parish as part of the changes to the Strategic Gap in the DaSA Local Plan consultation.

The general mood of the discussion was that this inclusion of the original Fairlight settlement in to the Strategic Gap was seen as an attempt to apply a 'blunt instrument' to the control of development in an area where buildings can have quite a significant impact on the aesthetic value of the landscape (both positive and negative). The background paper mentions a recent development of a Contemporary Architecture style residential dwelling, which is part of Fairlight Cove as an example of a building which has a significant impact on the landscape. However, this building obviously passed the necessary planning permission hurdles in order to gain permission for development. My view is that the future Fairlight Neighbourhood Plan should be the mechanism used to capture what is acceptable development in Fairlight Parish, rather than impose a very strict blanket policy over an area of existing settlement. The proposed area of the new strategic gap extension includes a number of very poor quality buildings as well as brown field development opportunities that would benefit from being re-developed in the future to extend the residential capacity of the parish, where sites for significant development are very difficult to find due to the coastal nature of Fairlight constraining development sites, and there being a need to balance the impact of large new housing development sites with sympathetic infill. Hence some level of carefully controlled infill development would most likely have a positive impact to the housing stock in Fairlight Parish.

The extension to the Strategic Gap would most likely create a significant hurdle to any future development, both positive and negative. The use of the Neighbourhood Plan and good general planning policies would most likely prevent negative development, whilst allowing positive development - which would be in the interest of current and future residents of Fairlight.

Comment

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

Representation ID: 22751

Received: 20/02/2017

Respondent: Miss Elizabeth Parker

Representation Summary:

Strongly object to the proposed deletion of the Battle and Hastings/St Leonards Strategic Gap between Forewood Lane and Battle Abbey, Battlefield and the historic town. The Strategic Gap protects the open landscape lying between the urban settlements of Bexhill, Hastings and Battle and the mainline railway: the ridge and the setting of Battle Abbey on the ridge are protected by the gap policy.

The proposed deletion abandons the existing safeguarding from encroachment and incremental development out from Battle development boundary along the ridge.

Full text:

POLICY DEN3: STRATEGIC GAPS
Question 19
Strongly object to the proposed option of deletion of the Battle and Hastings / St
Leonards Strategic Gap between Forewood Lane and Battle Abbey, Battlefield
and the historic town. The Strategic Gap protects the open landscape lying between the urban settlements of Bexhill, Hastings and Battle and the mainline railway: the ridge and the setting of Battle Abbey on the ridge are protected by the gap policy.
The proposed option of deletion of the northern part of the Strategic Gap abandons
the existing safeguarding from encroachment and incremental development out
from Battle development boundary along the ridge into the Strategic Gap.
The retention and protection of this Gap area is important to the conservation of
local landscape character around the historic town of Battle, in particular due to
its ridge top ribbon development form leading out towards the larger urban
settlements.
Removal of the gap strategy from the open landscape below the ridgeline leaves the
development boundary length currently strongly protected newly exposed. Use
of gap strategies to protect historic towns is nationally supported and once identified, their retention and protection is supported. Protecting the open landscape between the development boundary and the London-Hastings mainline railway is logical and justifiable.
The Strategic Gap is seen from the surrounding landscape, neighbouring villages
and the London-Hastings mainline railway. It is not only seen from the Battle-
Hastings road or from within the Strategic Gap area itself.
The Strategic Gap study only reviewed the gap from within the gap area and did not
study the gap from long range views from the west, outside the gap area. From
Catsfield, the two settlements of Battle and the edge of Hastings are held in one
view at either end of the ridge: the Strategic Gap provides the critical setting for
Battle Abbey on the ridge above the Battlefield.
There is also reference to views from the roads and public vantage points, with
apparent reference to a lack of need to protect the integrity and openness of the
open landscape behind the road frontage as a Strategic Gap. The Strategic Gap
protects the open landscape form between settlements, not the road frontage only.

It is also very important that the Strategic Gap protects against the spread of
lighting and light pollution between the settlements: the gap protects against
lighting coalescence.
The Strategic Gap background study contains strong material to support, contrary
to the recommendation, a continuing need to protect the land as a Strategic
Gap. The study states the positive impacts of the existing Strategic Gap and
notes adverse changes sustained, notwithstanding the gap policy protection:
"the gap does maintain the separate identity and clear distinctiveness between the
settlements"
"the town of Battle is maintained by the gap and the settlements are clearly
distinct"
The farmsteads within the gap "do not detract from the objective to prevent
coalescence".
"Despite the considerable amount of development scattered across the area, the
rural character has been preserved. "
The areas noted to have suffered gentrification around Battle, with adverse effect
on local landscape character, fall within the area of the Strategic Gap proposed
for deletion.
"The ribbon development along the ridge between Battle and Hastings does reduce
the impression of the gap along the northern boundary. The urban edge of Battle is the ribbon development along Hastings Road through Telham": this emphasises the reason why the protection of the open landscape within the existing Strategic Gap abutting this extended development edge of Battle should be retained and reinforced, not deleted. This ensures the open landscape gap is retained, even if the impression of the open landscape gap from the road frontage is reduced by the frontage development.
The study notes it is not possible to obtain long views and vantage points of the gap
from within the gap: the long views and vantage points from which one can look
across the entire Strategic Gap are obtained not from within the gap but from
higher ground to the west, in and around Catsfield. This is where the value of the Strategic Gap can be truly appreciated. No views from neighbouring areas were studied. From Catsfield, the boundaries of the Strategic Gap area and views across the gap area to its opposite edges are seen and valued.
"Ribbon development is typically strung out along Forewood Lane between Battle
and Crowhurst": a very good reason why Forewood Lane should not become the
new boundary of the Strategic Gap but should continue to be protected within the broader area of the existing Strategic Gap.
"The ribbon development which extends along Forewood Lane reduces the
experience of leaving one settlement and arriving on another" and "There will be pressure for residential development to expand and infill the area along Forewood Lane to the north of Crowhurst, especially as it is served by a station": again, very good reasons why Forewood Lane should not become the new boundary edge of the Strategic Gap but should continue to be protected within the broader area of the existing Strategic Gap. The Strategic Gap should not newly break at a point of vulnerability.
"The area would be sensitive to change especially on the more open areas and the
higher ground and ridges": the open landscape adjoining the Battle ridgeline
development boundary is proposed for deletion yet it is recognised to be
especially sensitive to change.
There is no justification for deleting part of the established Strategic Gap. No
reasons why this part of the Strategic Gap must be deleted are provided. No planning harm is identified from the continuing application of the policy. It is submitted to delete part of an existing Strategic Gap, overriding and substantial
reasoning necessitating its deletion should exist which are not present here.
The part of the Strategic Gap proposed for deletion also provides the additional
benefits of protecting land around the overhead high voltage pylon line from
incremental development which could augment its adverse effects within the AONB. This is the part of the pylon line proposed for undergrounding under the National Grid visual impact improvement programme and deletion of the part of the Strategic Gap through which the pylon line runs could prejudice its implementation.

Comment

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

Representation ID: 22779

Received: 20/02/2017

Respondent: Icklesham Parish Council

Representation Summary:

Support the policy.

Full text:

Support the policy.

Comment

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

Representation ID: 23132

Received: 16/02/2017

Respondent: Dr Simon Young

Representation Summary:

Having conducted recently (2014) a wildlife survey of Knowle Wood and the surrounding fields, I realise the immense importance of this area which runs along the edge of the proposed Extension to Gap.(See your Map 3 Fairlight which is marked as a Site of Nature Conservation Interest SNCI). If there is any development in the future to this proposed Extension it will result in the deterioration of the amenity and the unique wildlife value of this area. So I am against this proposal for Fairlight Village.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28032

Full text:

I have only just been informed of this proposal as a resident of Fairlight. It is extremely difficult to work out how I reply to you and follow all the instructions laid out in the various documents to reply or object, by 20 February 2017.

Having conducted recently (2014) a wildlife survey of Knowle Wood and the surrounding fields (Survey attached) I realise the immense importance of this area which runs along the edge of the proposed Extension to Gap.(See your Map 3 Fairlight which is marked as a Site of Nature Conservation Interest SNCI on your map). If there is any development in the future to this proposed Extension it will result in the deterioration of the amenity and the unique wildlife value of this area. So I am against this proposal for Fairlight Village.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28032

Comment

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

Representation ID: 23174

Received: 19/02/2017

Respondent: Rother Environmental Group

Representation Summary:

Could strategic gaps or wedges be identified in single communities as well - Battle for example?

Point 10.23: We want to query the reduction of the gap South of Battle, west of Forewood Lane, as this is not strongly argued by RDC.

Reference: https://www.rother.gov.uk/dasa

Full text:

Could strategic gaps or wedges be identified in single communities as well - Battle for example?

Point 10.23: We want to query the reduction of the gap South of Battle, west of Forewood Lane, as this is not strongly argued by RDC.

Reference: https://www.rother.gov.uk/dasa

Comment

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

Representation ID: 23236

Received: 18/02/2017

Respondent: Mr Dominic Manning

Representation Summary:

Agree. The increase in size of most strategic gaps is welcome. However, there is little justification offered for reducing the gap under item 10.23, so the preference is to not delete the area in question from the gap.

Full text:

Agree. The increase in size of most strategic gaps is welcome. However, there is little justification offered for reducing the gap under item 10.23, so the preference is to not delete the area in question from the gap.

Comment

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

Representation ID: 23308

Received: 20/02/2017

Respondent: Mr Chris Lewcock

Representation Summary:

Policy DEN3 is strongly supported insofar as it relates to the extension of the Strategic Gap between Hastings and Bexhill by inclusion of land at Glyne Gap field adjoining Lewis Avenue.

Full text:

Policy DEN3 is strongly supported insofar as it relates to the extension of the Strategic Gap between Hastings and Bexhill by inclusion of land at Glyne Gap field adjoining Lewis Avenue.

Comment

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

Representation ID: 23346

Received: 20/02/2017

Respondent: Hastings Borough Council

Representation Summary:

Whilst there is background evidence to support the policy formulation around the defined areas of the proposed strategic gaps, specifically, in relation to the Bexhill-Hastings/St Leonards proposed Strategic Gap, Hastings Borough Council believes it will be helpful to state that at the present time we are continuing to discuss the potential for a substantial sports development on HBC owned land at Bexhill Road within Rother.

We recognise that the scale of development likely to be proposed may trigger the 'exception' test which is not only part of the proposed Policy DEN3 but is already adopted Policy DS5.

Full text:

Whilst there is background evidence to support the policy formulation around the defined areas of the proposed strategic gaps, specifically, in relation to the Bexhill-Hastings/St Leonards proposed Strategic Gap, Hastings Borough Council believes it will be helpful to state that at the present time we are continuing to discuss the potential for a substantial sports development on HBC owned land at Bexhill Road within Rother District. Without prejudice to any future planning application we believe that such a scheme is potentially capable of significantly improving the sporting/leisure provision for both Hastings and Bexhill; providing new homes and achieving financial, health and employment gains, all of which are strategically important objectives for this Council.

At this time discussions are on-going, but planning applications, which will need to be considered by both authorities, are yet to be submitted. We recognise that the scale of development likely to be proposed may trigger the 'exception' test which is not only part of the proposed Policy DEN3 but is already adopted Policy (Rother Local Plan, Policy DS5 (adopted in 2006)).

Comment

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

Representation ID: 23378

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

Supporting text (10.19-10.21) does not indicate reasons for the exclusion of the area of existing Bexhill and Hastings/St Leonards gap to be removed.
The council should consider the value of the gaps in harnessing natural capital. We suggest this is reflected in policy wording:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'
This wording will reflect the importance of strategic gaps for ecosystems service delivery and compliance with NPPF.

Full text:

The following comments, related to biodiversity matters, are made on behalf of the Sussex Wildlife Trust.

If a question from the consultation is not included below, please assume that the Trust has no comments to make at this time.

PART B: DEVELOPMENT POLICIES

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside and the need to ensure that these features are safeguarded. In relation to this we highlight that in paragraph 7.16 the last sentence states 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining to add clarity.

We are concerned about equestrian developments being proposed on designated sites such as Local Wildlife Sites. Therefore we welcome an approach to more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per National Planning Policy Framework ( NPPF) section 165.

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Creative approaches and orientation should be considered when designing external spaces. Their setting within the green infrastructure aspirations of the District should be looked at during the planning application stage. This would ensure a holistic and considered approach to green infrastructure.

While bullet point (i) gives clarity to the external spaces of dwellings of 3 or more bedrooms, there is a lack of commitment to the amount of space need for flat and complex developments. The last sentence of this bullet point states that, 'an appropriate level of usable community and amenity space should be provided'. We are concerned that this statement does not give the decision maker a clear enough direction for its interpretation.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF section 109. The council may find the RHS advice leaflet useful www.rhs.org.uk/advice/profile?PID=738

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF section 118 'Opportunities to incorporate biodiversity in and around developments should be encouraged'.

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed policies? If not, what changes would you wish to see?

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Figure 7 demonstrates that an area of the existing Bexhill and Hastings/St Leonards green gaps is proposed to be removed from the strategic gap. However the supporting text (10.19 - 10.21) does not indicate the reasons for the exclusion. We feel the supporting text for this section would benefit from a brief explanation for the reason in inclusion or exclusion of areas.

We ask the council to consider the value of the strategic gaps in harnessing the district's natural capital. This natural capital will be delivering vital ecosystem services to the district and potentially to the authorities adjoining Rother District. Therefore we would suggest that this is reflected in the policy wording by:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'

We believe this additional wording will reflect the importance of strategic gaps for ecosystems service delivery and will also enable the policy to sit in line with NPPF para 109.

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

We are encouraged by the manner in which the supporting text for this policy has been approached. The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to the wording and ethos of Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed. The proposal is either supported in full or it is not, 'in principle' adds nothing to the policy.

Part ii - the word 'significant' should be removed. All developments should aim to avoid harm to biodiversity.

Part iii - should look to reflect the sentiments of the NPPF section 109. The first sentence should be amended to read:
'In addition to ( ii) above , all developments will be expected to deliver net gain to biodiversity by retaining and enhancing biodiversity in a manner appropriate to the local context ....'

Part iv has a requirement for 'larger developments of more than 2 hectare or 50 dwellings...' to produce a green infrastructure (GI) masterplan'. Looking at the allocations, very few meet this requirement. We recognise that there are some larger allocations around Bexhill where we would certainly support the need to produce GI masterplans but we are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings. We also recommend that the policy requires all development to contribute to the aspirations of Rother's Green Infrastructure Strategy.

We suggest that Rother District Council include an Ancient Woodland policy within the Local Plan. This would reflect the ethos of the NPPF which clearly states in section 117:
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?

Reviewing the supporting text and policy wording there is no recognition of Pevensey and Pett being low lying areas (below sea level) and the associated risk of sea and ground water flooding. We suggest that this is included.

QUESTION 23: Do you agree with the policy approach to managing environmental pollution through the planning process and with the proposed policy wording?

The policy would be strengthened by ensuring that there is mention of biodiversity within the policy bullet point relating to lighting.

Lastly, although the supporting text highlights that the district is not subject to any Air Quality Management Areas, with increasing development we suggest that the council recognise the natural capital that helps filter and deal with pollutants.

Increased levels of development in the district means resources may come under increasing pressure. It may benefit the council to consider talking to the Sussex Biodiversity Record Centre about their Ecoserve programme. This programme shows where the district's natural capital is delivering ecosystem services such as air purification in relation to population demand.

QUESTION 24: Do you agree with the policy approach to comprehensive development and the proposed policy wording?

We support recognising the importance of a holistic approach to development which considers the three roles of sustainable development. In order to achieve this within the policy wording we suggest that the policy looks to include wording regarding net gain to biodiversity as per section 109 of the NPPF. We feel that this is important as phased development may overlook the cumulative impact on the district's natural capital and the ecosystem services being delivered.

PART C: SITE ALLOCATIONS

General Comments
The Trust recognises that the presence of designated sites and priority habitats and species has been a contributing factor in the assessment of the suitability of site allocations. We very much support the council's approach to exclude designated sites and sites of high biodiversity value for development. However we note that the site assessments were primarily based on desk-top studies. With the exception of North Bexhill and Spindlewood Drive it does not appear that any on the ground assessments have been carried out.

Given the council's commitment in the Core Strategy objectives 'To protect important ecological resources in the district' and in policy EN5 to 'support opportunities for management, restoration and creation of habitats...' we recommend that preliminary ecological appraisals are carried out for the preferred sites before they are officially allocated. This will ensure that any issues relating to ecology are identified before the plan reaches the examination stage.

We are pleased to see that the 'Key constraints/opportunities' sections for many of the preferred site allocations consider ecological impacts. However, these considerations are again inconsistently reflected in policy wording. For example, policy IDE1 requires that an ecological assessment is undertaken and that any impact on protected species mitigated. Further to this, policy MAR1 states that development proposals should be subject to an ecological survey.

By singling out only two of the site allocations, this may give the impression that proposals for other allocations may not require ecological surveys. The NPPF has a clear requirement for planning decisions to be based on up to date information and for development to achieve net gains for biodiversity. It would not be acceptable for proposals to proceed without the inclusion of up to date ecological information, especially given that thus far the sites have only been assessed at a desk-top level. This position needs to be reflected in the Biodiversity Policy (please see comments for QUESTION 20) and in all the site allocation policies. Therefore the following wording should be added to all site allocations:
'Prior to determination:
A site wide landscape and ecological management plan that is informed by up to date ecological information, including information on the site's utilisation and delivery of ecosystems services, will be produced. Mechanisms needed for implementation will be identified and secured. This will be to the
satisfaction of the local planning authority to ensure long term maintenance of retained and newly created habitats.'

We recognise that information regarding a site's utilisation of ecosystem services maybe too onerous for small allocations. However, we take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Ecoserve. This programme uses biodiversity and habitat data to look at the ecosystems services currently provided by an area's natural capital. It also assesses where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider as an aid to helping smaller developments see how they could make a contribution or enhancements to the continued delivery of those services through their site.

Additionally, many of the site allocations are adjacent to ancient woodland. Again whilst this is usually noted in the 'Key constraints/opportunities' section, it is not consistently reflected in the policy wording for the allocation. For example Policy BRO1 part (v) specifies that 'a buffer zone of at least 15 metres is provided to the Ancient Woodland', while the presence of an ancient woodland is not mentioned in, for example, policy BEX1 or BEX2. Conversely policy BEX 9 does specify the need for a buffer to protect the adjacent ancient woodland, but the width of the buffer is not specified.

Core Strategy policy EN1 and NPPF paragraph 118 require the protection of ancient woodland in the district. Additionally, Natural England's Ancient Woodland standing advice is clear that a minimum buffer must be at least 15 metres. We therefore recommend that an Ancient Woodland policy is included in the DaSA and that any site allocation policy with the potential to impact on ancient woodland includes a requirement of a buffer zone of at least 15 metres.

We also note that most of the allocations require the 'retention and enhancement of boundary planting'. We understand that this requirement is primarily to mitigate visual impacts on the AONB, however this is also an opportunity to ensure that each allocation contributes to the creation of an ecological network for the district. We therefore recommend that when boundary planting is specified, additional wording is used, such as:
'Provision is made for the retention and enhancement of boundary planting, for the benefit of biodiversity and for screening purposes'.

The majority of the site allocation policies use the term 'some' when describing the number of dwellings or size of employment space required within a development. This is not a standard planning term and hence we are concerned that its use leaves the policies open to broad interpretation. Given the landscape and ecological sensitivities of many of the site allocations, we recommend that a maximum figure is proposed in each policy. This will provide clarity and ensure that the policy can be robustly applied.

Alternatively, if an approximate value is preferred, we recommend the use of the word 'approximately' rather than 'some' as this is more frequently used in a planning policy context. However, if the council is minded to use this approach, we would ask that an additional requirement is added to the policies to ensure that overdevelopment does not occur. We recommend the following:
'The final number of dwellings/employment size selected must be based on up to date environmental information that demonstrates the current ecosystem delivery of the site and its capacity to absorb the proposed level of development. '

QUESTION 26: Do you agree with the requirements of Policy BEX1? If not, how would you wish to see it amended?

General comment
The Sussex Wildlife Trust supports a plan-led planning process and acknowledges that site BEX1 is included in the adopted North East Bexhill SPD. However, we question whether the district's natural capital can absorb this level of development around Bexhill. All the allocated sites around the north east of Bexhill should be treated holistically and assessed for their impact on ecosystem services (NPPF paragraphs 109, 114 and 117). There must be a strategic approach to the development of these sites to ensure that ecological networks are retained across the sites.

Policy BEX1
We support the protection of the adjacent ancient woodland and the retention of the tree line through the centre of the site, as shown in the detailed map. However, this protection does not appear to be repeated in the policy wording. Additionally, the 'Key constraints/opportunities' section recognises that the land along the Combe stream to the north-west of the site should be retained as an amenity/wildlife corridor. Again, this is not reflected in policy wording. If requirements are not included in the policy, we are concerned that they may be disregarded at the application stage. This could also lead to confusion for developers and inconsistency in the decision making process. Therefore, policy BEX1 should be strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 The retention of the central belt of trees and enhancements to create a robust corridor between the ancient woodland and the wider countryside.
 The retention of the land along the Combe stream as an amenity/wildlife corridor
The Trust supports the retention of the central tree belt; however, the proposed access appears to sever this corridor. We recommend that the access is reconfigured to ensure the corridor is preserved in its entirety. If this is not deemed feasible wording should be added to ensure that the tree belt still functions as and ecological corridor.

It is vital that any green infrastructure within the site connects well to the surrounding area. We recommend additional wording in section (iv) to insure this:
'landscape and woodland belts are developed, implemented and connected to the wider landscape as an integral part of proposals'.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

The Trust questions whether the district's natural capital is able to absorb this level of development around Bexhill. Before finalising site allocations, especially larger greenfield sites around the development boundary, we recommend that the council assesses the capacity of these sites to provide ecosystem services. We take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Eco serve which uses biodiversity and habitat data to look at the ecosystems services the natural capital is currently providing and where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider.
QUESTION 28: Do you agree with the requirements of Policy BEX2? If not, how would you wish to see it amended?

General comment
As per our comments for QUESTION 26, site BEX2 should be assessed strategically with allocation BEX1 and BEX3. Overall, these allocations cover a significant area of greenfield, which will be providing vital ecosystem services to the district. The cumulative impact of these allocations on the district's natural capital needs to be assessed and accounted for to ensure that the expansion of Bexhill is truly sustainable as per the NPPF. Additionally, any green infrastructure strategy should cover all these sites to ensure permeability throughout the developments and multifunctional benefits across the north east of Bexhill are achieved.

Policy BEX2
As per our comments for QUESTION 26, we are concerned that some of the intentions in the 'Key constraints/opportunities' section and the detailed map are not reflected in the policy wording. We recommend that policy BEX2 is strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 Part (ii) should include a requirement for the pond to be retained as an ecological feature with landscaping to connect it to the wider countryside

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

Notwithstanding our general comments in QUESTIONS 26 and 28, if development is to occur here then option 1 would be preferable. This would retain a larger proportion of greenfield and allow more creative approaches to green infrastructure and ecological enhancements. We recommend that information on the site's utilisation and delivery of ecosystem services should be produced and used to inform the site's layout.

The Trust is concerned that the now approved North Bexhill Access Road severs the ghyll woodland at Kiteye Wood.

Any development in this area should seek to mitigate this impact through appropriate habitat creation and/or management. Additionally, the policy should make reference to the retention of the land along the Combe stream as an amenity/wildlife corridor, as per policy BEX1. These requirements could be included in part (vii) of the policy, which we support.

As with previous comments the wording to protect ancient woodland should be strengthened to include a requirement for a 15 metre buffer.

We also recommend that the policy protects the 'Woodland Complex at Buckholt Farm' Local Wildlife Site, to the north east of the site allocation. Whilst it sits outside the development boundary, this ancient woodland could still be harmed by the indirect impacts of the development. These need to be assessed and avoided at the master planning stage.

QUESTION 33: Do you agree with the requirements of Policy BEX7? If not, how would you wish to see it amended?

The Trust supports the retention of the southern section of the site as an ecology area. However, the wording of section (iv) should be strengthened to include a requirement to enhance the area as per core strategy policy EN5. We recommend:
'The southern section of the site remains undeveloped as an ecology area. Ecological enhancements should be implemented to improve the area for biodiversity. Provision should be made for the long term management of this area.'
QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

The Trust supports the retention of the tree belts in the centre of the site, the designation as a natural green space and the wording of part (vi). However, it is not clear to us how this corridor will be retained intact given that vehicle access is only proposed from the east of the site. This indicates that internal roads will sever the corridor in order to access the residential area in the North West. This should be a consideration in designing the layout of the site. At the very least we recommend wording to ensure that the integrity of the green corridor is maintained.

We support the inclusion of section (vii), however this should be strengthened with a requirement for the ancient woodland buffer at least 15 metres wide.

Additionally, it should be specified that the pond is retained as an ecological feature, rather than as part of any SuDS scheme for the site.

QUESTION 36: Do you agree with the requirements of Policy BEX10? If not, how would you wish to see it amended?

The Trust supports requirement (ii), however this should be expanded to specify that integration includes an integrated scheme of green infrastructure to ensure that the entire site remains permeable and receives multifunctional benefits.
The words 'where possible' should be removed from part (v). The pond should be retained and enhanced; this cannot be seen as unduly onerous given the site of the scheme.

QUESTION 37: Which of the development options for Northeye do you prefer? Should other options be considered?

Any policy for this site must include protections against the potential negative impacts of the creation of sports pitches such as flood lighting and impermeable surfaces. We recommend wording is included to ensure that there are no harmful impacts of this type of development.

QUESTION 38: Do you agree with the requirements of Policy BEX11? If not, how would you wish to see it amended?

This policy should include wording to manage the type of playing pitches which might be suitable on this site. Consideration should be made to the use of artificial pitches and associated lighting. In particular, potential impacts on bats which are likely to be present in the area should be considered.

QUESTION 43: Do you agree with the requirements of Policy BEX15? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that 'a large proportion of the site suffers from surface water flooding'. Therefore, we recommend that an additional criterion is added to the policy to ensure that a SuDS scheme is implemented to rectify this issue. We also recommend that green infrastructure is included to both help with the flooding issue and to connect the site to the wider GI network in the town.

QUESTION 47: Do you agree with the preferred site for housing development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust supports the allocation of brownfield sites of low ecological value over the allocation of greenfield sites. A large amount of development is already proposed for the fringes of Hastings through the Hastings Development Management Plan. We would not support any further urban sprawl into the surrounding countryside without full accounting of the area's natural capital and assessment of the area's utilisation and delivery of ecosystem services.

QUESTION 49: Do you agree with the preferred sites for employment development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust does not support further urban sprawl at the Hastings fringe; however of the four sites recommended, the preferred sites seem to be the least damaging. As stated previously we recommend that preliminary ecological appraisals are carried out before sites are formally allocated to ensure that there is no significant harm to biodiversity.

Additionally, a wider green infrastructure plan should be required, covering both of these sites in conjunction with the adjacent Hasting allocations to ensure a holistic approach.

QUESTION 50: Do you agree with the requirements of Policy HAS2? If not, how would you wish to see it amended?

We recommend that point (iv) is strengthened as follows to ensure net gains to biodiversity as per the NPPF:
'provision is made, in conjunction with the adjoining employment allocations, for the retention, enhancement and long-term future management of woodland to the north of the site for the benefit of biodiversity'.

QUESTION 51: Do you agree with the requirements of Policy HAS3? If not, how would you wish to see it amended?

We support criterion (iv), however any green infrastructure should be integrated into the surrounding employment allocations, to ensure multifunctional benefits are seen across the whole area.

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

We recommend an addition to criterion (ii) to ensure net gains to biodiversity as per the NPPF.
'...the Site of Nature Conservation Importance within it, and creates net gains to biodiversity within the Park...'

QUESTION 54: Do you agree with the recommendation regarding the Hastings Fringes development boundaries? If not, please explain how you wish the development boundaries to be applied to this area?

The Trust strongly supports the designation of a strong development boundary which prevents further urban sprawl into the wider countryside. (Please see QUESTION 47).

QUESTION 56: Do you agree with the requirements of Policy BEC1? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 57: Do you agree with the requirements of Policy BEC2? If not, how would you wish to see it amended?

We recommend that the policy is strengthened to better reflect the contents of the 'Key constraints/opportunities' section. In particular, reference should be made to the requirement to keep the remaining area as amenity land and to the retention of the pond as an ecological feature rather than as part of any SuDS scheme deemed necessary.

QUESTION 59: Do you agree with the preferred sites for development at Broad Oak? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value such as BO14. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 60: Do you agree with the requirements of Policy BRO1? If not, how would you wish to see it amended?

The Trust strongly supports the wording of requirement (v) and the specification of a buffer of at least 15 metres. We recommend that this wording is replicated in other policies for sites adjacent to ancient woodland.

We support requirement (iv), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 61: Do you agree with the requirements of Policy BRO2? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 65: Do you agree with the requirements of Policy CAM2? If not, how would you wish to see it amended?

This policy needs to be strengthened to ensure that the adjacent Local Wildlife Site, Local Geological Site, SSSI and Special Protection Area are protected from harm. Whilst the protection and management of the dunes is a key landscape and ecological objective of the SPD, there does not appear to be a specific requirement to protect and enhance these designated sites. This should be addressed in the policy.

QUESTION 66: Do you agree with the proposed development boundary? If not, how would you wish to see it amended?

The Trust strongly supports the deletion of the SSSI from the development boundary. Dungeness, Romney Marsh & Rye Bay SSSI is of national importance to biodiversity and should not be degraded through encroaching development.

QUESTION 68: Do you agree with the requirements of Policy CAT1? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that buffer planting should be informed by ecological surveys, however this requirement is not reflected in the policy wording. Given that the site appears to contain well developed scrub, any application for this site must include a thorough ecological survey to assess if the site can absorb the level of development suggested whilst producing net gains for biodiversity.

QUESTION 69: Do you agree with the requirements of Policy CAT2? If not, how would you wish to see it amended?

Requirement (iii) should be subject to ecological surveys to assess the impact of severing the hedgerow. We also recommend that 'for the benefit of biodiversity' is added to the end of requirement (iv)(b) to ensure that any tree and hedgerow planting contributes to the wider ecological network in Catsfield.

QUESTION 72: Do you agree with the requirements of Policy HUR1? If not, how would you wish to see it amended?

As the stream/ditch that sub-divides the two lower fields is recommended to be retained for both heritage and ecological reasons, this should be reflected in the policy. We recommend that requirement (vii) is amended to:
'...is retained and incorporated within the layout as an ecological feature. Development should ensure that the biodiversity value of the feature is enhanced and that it is integrated into the wider blue/green infrastructure plan for the site...'

QUESTION 73: Do you agree with the requirements of Policy HUR2? If not, how would you wish to see it amended?

This site is adjacent to Hurst Green Meadows and Woodland Local Wildlife Site. This should be acknowledged in the policy and a requirement to protect and enhance the LWS should be included.

QUESTION 76: Do you agree with the requirements of Policy IDE1? If not, how would you wish to see it amended?

We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species. Opportunities to incorporate biodiversity gains throughout the development should be taken.

QUESTION 79: Do you agree with the requirements of Policy NOR1? If not, how would you wish to see it amended?

Enhancements to the existing tree belts should be sought for the benefit of biodiversity.

QUESTION 82: Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?

The Trust strongly supports the protection of the traditional orchard and the aims to bring it into long-term sustainable management. This is a priority habitat and as such its protection and enhancement is fundamental to the council's aims in the Core Strategy. We strongly support requirement (v) and recommend that there is a requirement for a long-term ecological monitoring and management plan for the site.

Requirement (vi) should include 'enhancement' as well as retention to ensure net gains to biodiversity. We also recommend that the requirement for a SuDS scheme is included in the policy.

QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

The Trust strongly supports the exclusion of the traditional orchard from the development boundary. This will help to protect the site in the long term.

QUESTION 84: Do you agree with the preferred site for development at Rye Harbour? If not, which site should be preferred?

The Trust strongly supports the exclusion of sites designated as SSSI. These would clearly not be suitable for development and their allocation would be contrary to the Core Strategy and NPPF.

QUESTION 85: Do you agree with the requirements of Policy RHA1? If not, how would you wish to see it amended?

The site is also adjacent to the SPA and this should be acknowledged in the policy. We recommend that requirement (iv) is extended as follows:
'...development of RH10 does not adversely impact upon the Rye Harbour SSSI and avoids impacts on the SPA'.

QUESTION 86: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

It appears a typo is included in paragraph 15.98. The reference to Donsmead, Station Road should be removed.

We support the proposed development boundary as it should prevent further development encroaching onto sites designated for their biodiversity value.

QUESTION 87: Do you agree with Policy RHA2 regarding the Harbour Road Industrial Estate and the proposed boundary changes? If not, how would you wish to see it amended?

Given the ecological sensitivity of the land surrounding this allocation, we recommend that requirement (iii) is strengthened as follows:
'...a comprehensive landscaping strategy and an ecological monitoring and mitigation plan to improve the overall appearance and the biodiversity value of development.'

QUESTION 88: Do you agree with the preferred sites for development at Westfield? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 89: Do you agree with the requirements of Policy WES1? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. Further to this, as identified in the 'Key constraints/opportunities' section, the previous ecological appraisals suggested biodiversity gains. The Trust strongly supports the inclusion of wording to support biodiversity gains but seeks that these are not limited to bird and bat boxes. Instead biodiversity gains should be implemented depending on the findings of the up to date ecological surveys submitted at the time of the application. We remind the council that if they are minded to suggest bird and bat boxes as part of the gains for this site in future, wording should be included to highlight the need to incorporate natural features supporting these artificial homes.

QUESTION 90: Do you agree with the requirements of Policy WES2? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. The aerial photograph shows the degraded formal gardens and it would be interesting to see if this allocation could consider how these former gardens might be integrated into the layout of the development site, as it may enable the retention of features of interest.

QUESTION 91: Do you agree with the requirements of Policy WES3? If not, how would you wish to see it amended?

The southern section of the allocations lies within the Hasting Fringes Biodiversity Opportunity Area (BOA). We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species.

Opportunities to incorporate biodiversity gains throughout the development as per the ecological surveys and aspirations of the BOA should be taken.

QUESTION 92: Do you agree with the requirements of Policy WES4? If not, how would you wish to see it amended?

We note this allocation falls outside the 2006 development boundary. However, we are supportive of measures taken to encourage modes of sustain able transport and to interlink those benefits with biodiversity gains. The text accompanying the allocated site states that there are locally present protected species. Therefore we recommend that (iii) reads:
'ecological improvements are based on up to date ecological surveys and are implemented in accordance with these findings and those of the Hasting Fringes Biodiversity Opportunity Area and Rother Green infrastructure Strategy'.

Question 93 - 103

We support the retention of gaps between settlements. While these gaps are often retained for reasons of coalescence and visual sensitivities, we highlight that the Sussex Wildlife Trust also sees the need to recognise the importance of these green gaps in delivering ecosystem services to the local communities (NPPF section 109).

QUESTION 105: Do you agree with the requirements of Policy GYP1, including the boundary as defined on the Policies Map? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per are general comments at the start of this section.

QUESTION 109: Do you agree with the requirements of Policy (MAR1)? If not, how would you wish to see it amended?

We support the requirement for an ecological survey. We recommend that criterion (i) includes 'for the benefit of biodiversity' and the criterion (iv) requires the use of SuDS.

QUESTION 110: Do you agree with a policy to support the continued allocation for the re-instatement of the railway link from Robertsbridge to Bodiam along its original route?

The Sussex Wildlife Trust support sustainable modes of transport. However, we do not have enough information about this particular scheme to offer an opinion on this policy. It is unclear whether the application has been progressed with the consideration of the existing landowners and the level to which biodiversity interests have been considered.

QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?

We highlight the need for a specific Ancient Woodland Policy as per section 117 of the NPPF.
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

We welcome the inclusion of the green infrastructure study as an evidence base for the local plan. We would like to know if this will progress into a clear strategy identifying delivery mechanisms. We suggest that the local plan may benefit from a specific policy on green infrastructure/ecological networks to ensure consistent integration of this infrastructure within development.

Should you have any further questions regarding our consultation response please feel free to contact me.

Yours sincerely,
Laura Brook
Conservation Officer

Comment

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

Representation ID: 23537

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Landscape

ENVIRONMENT Page 79

Yes

Full text:

Landscape

ENVIRONMENT Page 79

Yes

Comment

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

Representation ID: 23609

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Archaeology

ENVIRONMENT
-Strategic gaps

Yes

Full text:

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

ENVIRONMENT
-Strategic gaps

Yes

Comment

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

Representation ID: 23702

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Ecology

ENVIRONMENT Page 79

-Strategic gaps

Yes.

Full text:

Ecology

ENVIRONMENT Page 79

-Strategic gaps

Yes.