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

Showing comments and forms 1 to 24 of 24

Comment

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

Representation ID: 21937

Received: 18/12/2016

Respondent: Ms Val Hunnisett

Representation Summary:

Agree, so long as the roads can cope.

Full text:

Agree, so long as the roads can cope.

Comment

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

Representation ID: 22007

Received: 03/01/2017

Respondent: Chris Horne

Representation Summary:

No to scale of development.
Traffic flows on to Ellerslie Lane will add to dangers for pedestrians. There being no pedestrian pavements to the north until the junction with Turkey Road.
Traffic flow to the north will meet the additional movements expected as a result of any approval from. BEX3 and BEX6.
Cumulative effect clearly not considered by anyone of note?

Full text:

No to scale of development.
Traffic flows on to Ellerslie Lane will add to dangers for pedestrians. There being no pedestrian pavements to the north until the junction with Turkey Road.
Traffic flow to the north will meet the additional movements expected as a result of any approval from. BEX3 and BEX6.
Cumulative effect clearly not considered by anyone of note?

Comment

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

Representation ID: 22022

Received: 04/01/2017

Respondent: Mr Charles Coombes

Representation Summary:

Yes. Brownfield site.

Full text:

Yes. Brownfield site.

Comment

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

Representation ID: 22041

Received: 05/01/2017

Respondent: Mr Barry Welch

Representation Summary:

The density of the developments off of Barnhorn Road is just below 20 dwellings per hectare (RR/2015/3115/P is 3.41 hectares for 67 dwellings and RR/2015/3125 is 14.1 hectares for 275 dwellings). On the same basis the potential for the land at Moleynes Mead, Fryatts Way (0.9 hectare) would be 18 dwellings.

Full text:

The density of the developments off of Barnhorn Road is just below 20 dwellings per hectare (RR/2015/3115/P is 3.41 hectares for 67 dwellings and RR/2015/3125 is 14.1 hectares for 275 dwellings). On the same basis the potential for the land at Moleynes Mead, Fryatts Way (0.9 hectare) would be 18 dwellings.

Comment

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

Representation ID: 22067

Received: 14/01/2017

Respondent: Mr Mark Harris

Representation Summary:

Previous applications for this site were rejected due to the type and density of housing proposed, considered not suitable for the area. Whilst I can only speak for myself, I believe a more sympathetic view would be taken by local residents if a more suitable scheme was proposed, such as retirement properties or bungalows. Whilst we all have to accept the need to additional housing these days, in this beautiful area residents will clearly fight hard against plans for inappropriate housing scheme's.

Full text:

Previous applications for this site were rejected due to the type and density of housing proposed, considered not suitable for the area. Whilst I can only speak for myself, I believe a more sympathetic view would be taken by local residents if a more suitable scheme was proposed, such as retirement properties or bungalows. Whilst we all have to accept the need to additional housing these days, in this beautiful area residents will clearly fight hard against plans for inappropriate housing scheme's.

Comment

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

Representation ID: 22185

Received: 06/02/2017

Respondent: Mr Roger Fendall

Representation Summary:

Brilliant.

Full text:

Brilliant.

Comment

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

Representation ID: 22189

Received: 06/02/2017

Respondent: Mrs Ephrosine Govan

Representation Summary:

The area is not appropriate for family's it would be of better use for housing for elderly people who wish to down scale from their larger homes, and after reading the paper today with the government asking elderly people to free up their houses for family's we need to start providing accommodation for them [the elderly] as much as for family's, and this area would be ideal

Full text:

The area is not appropriate for family's it would be of better use for housing for elderly people who wish to down scale from their larger homes, and after reading the paper today with the government asking elderly people to free up their houses for family's we need to start providing accommodation for them [the elderly] as much as for family's, and this area would be ideal.

Comment

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

Representation ID: 22229

Received: 12/02/2017

Respondent: Mr Nelson Pentecost

Representation Summary:

Flooding.
This area is prone to flood as the existing mains drainage system is either, inadequate, poorly maintained i.e. insufficient jetting, no clearing of existing drainage ditches. Additionally the area is the lowest point so road flooding adds to the likelihood of road accidents.
Existing properties close to this site are already overwhelmed, on occasions, by the run-off water from the high ground in & around the cemetery. Yet more concreted areas will not help this already poorly drained area to improve.
I feel more evidence is required on the sites potential adverse impact on Pevensey Levels Hydrological catchment

Full text:

Flooding.
This area is prone to flood as the existing mains drainage system is either, inadequate, poorly maintained i.e. insufficient jetting, no clearing of existing drainage ditches. Additionally the area is the lowest point so road flooding adds to the likelihood of road accidents.
Existing properties close to this site are already overwhelmed, on occasions, by the run-off water from the high ground in & around the cemetery. Yet more concreted areas will not help this already poorly drained area to improve.
I feel more evidence is required on the sites potential adverse impact on Pevensey Levels Hydrological catchment

Comment

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

Representation ID: 22231

Received: 12/02/2017

Respondent: Mr Nelson Pentecost

Representation Summary:

Site Access.
Your proposal states that pedestrian access will be into Ellerslie Lane. With NO EXISTING footpaths to the north, nor any space to provide any, people will be forced to be hastily avoid oncoming traffic the whole way to Turkey Road. Equally, the lane is poorly lit. Somebody will be rundown soon, as Ellerslie Lane has become a rat-run, with NO regard for speed limits or width restrictions.
This will be worse if a 2nd vehicle access is made - only yards from the crest of the S bends to the south. This should be rejected.

Full text:

Site Access.
Your proposal states that pedestrian access will be into Ellerslie Lane. With NO EXISTING footpaths to the north, nor any space to provide any, people will be forced to be hastily avoid oncoming traffic the whole way to Turkey Road. Equally, the lane is poorly lit. Somebody will be rundown soon, as Ellerslie Lane has become a rat-run, with NO regard for speed limits or width restrictions.
This will be worse if a 2nd vehicle access is made - only yards from the crest of the S bends to the south. This should be rejected.

Comment

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

Representation ID: 22232

Received: 12/02/2017

Respondent: Mr Nelson Pentecost

Representation Summary:

Site Drainage.
Any additional drainage water exiting the site and discharged into Ellerslie Lane, will greatly adversely affect the ability of the existing drains to cope. Already most of the existing street drains are PERMANENTLY blocked with debris, mud etc and existing road sweeping, drain clearing does not solve the problem and allow free flow of water to be gathed into the drainage system.

Full text:

Site Drainage.
Any additional drainage water exiting the site and discharged into Ellerslie Lane, will greatly adversely affect the ability of the existing drains to cope. Already most of the existing street drains are PERMANENTLY blocked with debris, mud etc and existing road sweeping, drain clearing does not solve the problem and allow free flow of water to be gathed into the drainage system.

Comment

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

Representation ID: 22245

Received: 20/02/2017

Respondent: AmicusHorizon Ltd (Rother Homes)

Representation Summary:

Yes but subject to site/soil investigation outcomes on what is really required

Full text:

Yes but subject to site/soil investigation outcomes on what is really required

Comment

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

Representation ID: 22301

Received: 15/02/2017

Respondent: Mrs Margaret Burnett

Representation Summary:

Would suggest that smaller affordable homes would be far better suited with others similar in potential sites on north-east perimeters of town, eg Pebsham locale. That could provide better provision for children and young teenagers with like groups for companionship. Perhaps consider smaller bungalows for the elderly on this site as much more suitable and in-keeping with existing homes? Careful thought needed this site for parking, garaging, road access, flood risks, drainage issues, etc. Larger gardens required to match area and comply with various existing covenants.

Full text:

Would suggest that smaller affordable homes would be far better suited with others similar in potential sites on north-east perimeters of town, eg Pebsham locale. That could provide better provision for children and young teenagers with like groups for companionship. Perhaps consider smaller bungalows for the elderly on this site as much more suitable and in-keeping with existing homes? Careful thought needed this site for parking, garaging, road access, flood risks, drainage issues, etc. Larger gardens required to match area and comply with various existing covenants.

Comment

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

Representation ID: 22533

Received: 18/02/2017

Respondent: Bexhill Wheelers

Representation Summary:

Agree: Agree: Vital that Walking and Cycle Links are integrated with other Rights of Way, Shared Space paths, Quite Roads with 20mph limits and are of common high quality standards, clearly signed that connect with other adjoining developments and projects. That Bus infrastructure is provided with routes negotiated and agreed prior to construction to ensure access to work and homes by public transport is available. Provision made to ensure vehicles park or lay-by in designated places by physical barriers or engineering at turning radius. Roads built to ESCC standards or higher and adopted.

Full text:

Agree: Agree: Vital that Walking and Cycle Links are integrated with other Rights of Way, Shared Space paths, Quite Roads with 20mph limits and are of common high quality standards, clearly signed that connect with other adjoining developments and projects. That Bus infrastructure is provided with routes negotiated and agreed prior to construction to ensure access to work and homes by public transport is available. Provision made to ensure vehicles park or lay-by in designated places by physical barriers or engineering at turning radius. Roads built to ESCC standards or higher and adopted.

Comment

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

Representation ID: 22534

Received: 18/02/2017

Respondent: Bexhill Wheelers

Representation Summary:

Agree: Agree: Vital that Walking and Cycle Links are integrated with other Rights of Way, Shared Space paths, Quite Roads with 20mph limits and are of common high quality standards, clearly signed that connect with other adjoining developments and projects. That Bus infrastructure is provided with routes negotiated and agreed prior to construction to ensure access to work and homes by public transport is available. Provision made to ensure vehicles park or lay-by in designated places by physical barriers or engineering at turning radius. Roads built to ESCC standards or higher and adopted.

Full text:

Agree: Agree: Vital that Walking and Cycle Links are integrated with other Rights of Way, Shared Space paths, Quite Roads with 20mph limits and are of common high quality standards, clearly signed that connect with other adjoining developments and projects. That Bus infrastructure is provided with routes negotiated and agreed prior to construction to ensure access to work and homes by public transport is available. Provision made to ensure vehicles park or lay-by in designated places by physical barriers or engineering at turning radius. Roads built to ESCC standards or higher and adopted.

Comment

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

Representation ID: 22733

Received: 20/02/2017

Respondent: S J Perry

Representation Summary:

I would urge you to only allocate the fewest possible dwellings in this Local Plan - and not to be revisited to add more in future allocations.

Always allow a 15-20 metre buffer between builds and trees/hedgerows. This it to protect individual trees, hedgerows, ecology areas, heritage assets (including those undesignated).

Green spaces and surrounding trees, hedgerows and shrubs should not just be a token here and there, but in walking distance of existing development.

Full text:

Bex 7
Object: this infilling is over development, especially in Bexhill-on-Sea and over-calculation of genuine housing requirement for local people in this specific area. It seems the calculation is to mitigate the migration-drivers, to take up pressure otherwise in the Rother District catchment area (eg historic parishes and/or AONB) and even to assist Hastings Borough directives for allocation. Although I fully agree with the reasons to resist development elsewhere - it does not give justice to negate the value of Bexhill-on-Sea environments and historic features which should also be retained. The whole area will be spoilt forever and I object to this development plan.

Land at Moleynes mead, Fryatts Way, Bexhill-on-Sea
If it goes ahead I would urge you to only allocate the fewest possible dwellings in this Local Plan - and not to be revisited to add more in a future allocation.

Minimum buffer to trees and hedgerows
Always allow a 15-20 metre buffer between builds and trees/hedgerows
Please stipulate that any tree which is within the boundaries of an individual property in a new development has a 15-20 meter genuine buffer boundary. This it to protect individual trees, hedgerows, ecology areas, heritage assets (including those undesignated). The details plans should also encourage either a Tree Preservation Order and/or Covenants that no tree should be harmed. If it is later deemed diseased or dangerous a full report should be submitted by the owner to the council and a replacement tree would be planted in the same place.
Reason. In the event of plans to build trees in the gardens the future occupants may wish to harm the tree if they find it inconvenient. This would be a loss to the environment and present wildlife corridors. (example can be cited at boundaries of Jarvis Brook Close in Bexhill-on-Sea, where most of the trees have gone - including trees planted by the developer - with loss of hedgerows and wildlife corridor).

Green spaces
Green spaces and surrounding trees, hedgerows and shrubs should not just be a token here and there, but in walking distance of existing development in Bexhill-on-Sea. this should be factored into the Local Plan as a resource for leisure, a visual amenity and retaining all wildlife corridors.

Comment

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

Representation ID: 22909

Received: 09/02/2017

Respondent: MRS MARIAN RIGBY

Representation Summary:

This is a serious problem for residents in this area.

We are extremely concerned that we may lose our peace and privacy if dwellings are planned to overlook our bungalow as in previous applications.

However we are mindful of the need for more housing. The type of housing planned would be of utmost importance for existing residents. There is talk of elderly people downsizing to allow larger properties being made available for families so perhaps sheltered housing for the elderly would be appropriate for this site.

There is absolutely no room for additional parking, cars etc.

Full text:

This is my response to the above application for 22 dwellings. I live at 33 Fryatts Way, bungalow situated at the end of Fryatts Way.

This application is once again (referring to previous applications for 44 & 33 dwellings) a serious problem for residents in this area.

We are extremely concerned that we may lose our peace and privacy if dwellings are planned to overlook our bungalow as in previous applications. My husband is disabled and I am his full time carer.

However we are mindful of the need for more housing. The type of housing planned would be of utmost importance for existing residents. There is talk of elderly people downsizing to allow larger properties being made available for families so perhaps sheltered housing for the elderly would be appropriate for this site.

There is absolutely no room for additional parking, cars etc.

Comment

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

Representation ID: 23134

Received: 16/02/2017

Respondent: Mrs J Field

Representation Summary:

Mrs Field objects to the proposed Policy BEX7 specifically (ii) which says the existing dwelling, Moleynes Mead, is retained.

Mrs Field disputes that Moleynes Mead is "considered" to be a non-designated heritage asset. Historic England concluded that the building would not be added to the statutory list.

In dismissing the appeal for 35 dwellings the Inspector noted the Council considered Moleynes Mead to be a heritage asset but no mention of the building was made in the SHLAA assessment which considered the site suitable for 40 dwellings.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28028



Full text:

Mrs Field is the owner of Moleynes Mead.

Mrs Field objects to the proposed Policy BEX7 specifically (ii) which says the existing dwelling, Moleynes Mead, is retained, for the following reasons.

Mrs Field disputes that Moleynes Mead is "considered" to be a non-designated heritage asset. Historic England considered whether the building merited listed status and an Advice Report on 14 July 2015 concluded (followed by formal notification by Historic England on 24 July 2015 that the building would not be added to the statutory list).

Conclusion

After examining all the records and other relevant information and having carefully considered the architectural and historic interest of this case, the criteria for listing are not fulfilled. For this reason Moleynes Mead is not recommended for listing.


REASONS FOR DESIGNATION DECISION

Moline's Mead, 11 Ellerslie Lane of 1924 by G Blair Imrie for Dr H E Leigh Canney, is not recommended for listing for the following principal reasons:

* Architectural interest: in scale and ambition a relatively modest example of the Domestic Revival style, with few interior features of note:
* Date and innovation: the domestic planning and architectural design are not innovative for their date, and the design had no influence in the field of domestic architecture;
* Historic interest: While Dr Leigh Canney is of note as an early C20 medical reformer, he is little-known outside this specialised field and cannot as such be considered nationally important;
* Alterations and historic setting: the infilling of the loggia and remodelling of the garage have compromised the overall appearance of the building, while the erection of garages, stabling and other ancillary building in the grounds have had an impact on the historic setting of the house.

In the preamble to the policy it is suggested a dismissed appeal accepted the principle of development on the site but the "reasons of refusal focused on poor design and layout and loss of a heritage". In dismissing the appeal for 35 dwellings on the site on 13 July 2015 prior to the findings on the building's suitability for listing the Inspector noted the Council considered Moleynes Mead to be a heritage asset but no mention of the building was made in the SHLAA assessment which considered the site suitable for 40 dwellings. Paragraphs 29, 30 and 35 of the decision letter are relevant and are reproduced below.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28028



Comment

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

Representation ID: 23387

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

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.'

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: 23437

Received: 20/02/2017

Respondent: Natural England

Representation Summary:

BX 64, BEX7
Designated sites - Pevensey Levels SSSI hydrological catchment area.

Development proposals within the Pevensey catchment should include SuDS that deliver multiple benefits for the water environment, wildlife and people, and to achieve the greatest benefits, SuDS should be joined up at a landscape scale.
Note: Natural England would welcome the opportunity to work with the lpa and other partners to achieve this, and implement the related policies in the Rother District Local Plan.

Full text:

BX 64, BEX7
Designated sites - Pevensey Levels SSSI hydrological catchment area.

Development proposals within the Pevensey catchment should include SuDS that deliver multiple benefits for the water environment, wildlife and people, and to achieve the greatest benefits, SuDS should be joined up at a landscape scale.
Note: Natural England would welcome the opportunity to work with the lpa and other partners to achieve this, and implement the related policies in the Rother District Local Plan.

Comment

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

Representation ID: 23495

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Transport Strategy & Economic Development
BEXHILL Page 128

-Policy BEX7: Land at Moleynes Mead, Fryatts Way, Bexhill

BEX5, 6, 7, 9, 10 will be taken into consideration when a cycle network for this part of the town is being developed.

Full text:

Transport Strategy & Economic Development
BEXHILL Page 128

-Policy BEX7: Land at Moleynes Mead, Fryatts Way, Bexhill

BEX5, 6, 7, 9, 10 will be taken into consideration when a cycle network for this part of the town is being developed.

Comment

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

Representation ID: 23548

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

Full text:

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

Comment

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

Representation ID: 23621

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Archaeology

BEXHILL Page 128

-Policy BEX7: Land at Moleynes Mead, Fryatts Way, Bexhill

The site has a medium potential to contain prehistoric, Roman and medieval remains, but areas are likely to be disturbed. The current house on site appears to have been constructed in the 1920s and may be of some architectural merit. Any planning application would be expected to include an archaeological assessment in line with NPPF.
-GREEN

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.

BEXHILL Page 128

-Policy BEX7: Land at Moleynes Mead, Fryatts Way, Bexhill

The site has a medium potential to contain prehistoric, Roman and medieval remains, but areas are likely to be disturbed. The current house on site appears to have been constructed in the 1920s and may be of some architectural merit. Any planning application would be expected to include an archaeological assessment in line with NPPF.
-GREEN

Comment

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

Representation ID: 23714

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Ecology

BEXHILL Page 128

Yes

Full text:

Ecology

BEXHILL Page 128

Yes

Comment

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

Representation ID: 23810

Received: 20/02/2017

Respondent: Mr Bryan Longley

Representation Summary:

The requirement of Policy BEX7 should be amended to 11 dwellings.

One source of income into Bexhill coffers is the wealth/disposable income of retirees from Greater London - likely to increase as pressure on the Capital grows. Many such entrants to the community have, in the past, gravitated to the area of Ellerslie Lane/Fryatts Way. And, it might be assumed, would continue to do so.

The need, when considered in the wider context of Bexhill prosperity is, I suggest, for 11 dwellings of some 8,000 square feet; not for 22 of half that size.

Full text:

I do not agree with the requirement of Policy BEX7 and would wish it to be amended by reducing the number of dwellings to 11 (eleven) in number.

I feel sure that I anticipate RDC broad policy correctly in assuming that such developments as the above not just within 'Core Strategy' objective, but within the broader ambitions for the Bexhill community; I nonetheless draw attention here to that broader responsibility. in doing so, I apologise for my inability to access the correct form on my computer and hope that this letter wont be dismissed because of this omission.

One source of income into Bexhill coffers is the wealth and disposable income of retirees from Greater London - a number which is likely to increase as pressure on the Capital grows. Many such entrants to the community have, in the past, gravitated to the area of Ellerslie Lane and Fryatts Way. And, it might be assumed, would continue to do so assuming that the attraction of the area is maintained.

The need, when considered in the wider context of Bexhill prosperity is, I suggest, for 11 dwellings of some 8,000 square feet; not for 22 of half that size.