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

Option 2

Option 2 Residential Development.
Access to A259 in place. For east or west movement.
Existing main bus route on A259
Brownfield site.
No proven demand for other Option proposals

This is a Brownfield site that should be developed for residential use ONLY. Along with Barnhorn Green improvements will be needed to the A259. Playing pitches maybe a good idea but who will use them?
There is little or no demand for a hotel or eco lodge park or a Business Park.

In view of the pressure for new housing the Option 2 for Northeye should be considered and adopted.

I have lived at Northeye for 15 years. I was attracted to how quiet it is here, the countryside and walks, quiet road with low traffic and space for my children to play which is a precious commodity. I in no way support the suggestion of the UAE becoming an institutional centre as I would not have purchased my house here if it was still being used that way. It un-nerves me when you say that depending on demand will depend on how it will be used. You should elaborate as what you are suggesting exactly especially with rumours that have been banded around in the last year. This would make my house virtually unsaleable and would greatly de-value it. I wouldn't feel safe living here or letting my children out to play. I would seek compensation if this was to go ahead. I would be very sad to see housing go ahead as this would change our living status totally with busy roads, playing areas for children would be built on, our outlook ruined by fields being replaced with houses, the quiet would go and the privacy we currently have would be gone as we use our front gardens. We have amazing wildlife with rabbits on our gardens, owls, wood peckers, badgers, foxes and bats that all come to our gardens. You keep taking our countryside and building on it and we will lose our semi rural way of life which is why I moved here. The other two options would be preferred and create much needed jobs. You are already allowing Barnhorn Green to go ahead with many houses, plus planning is in for another 30 houses on Barnhorn Road and so I can't see how Little Common can possibly take being developed even more. School? Doctors? Traffic? What do you propose to do to ease the traffic as it has doubled since the bypass opened? How are you going to manage entering the road from Barnhorn Road? How are you going to manage the traffic out onto Coneyburrow Lane which is already dangerous and worse with traffic using it as a cut through now at 60MPH? We have asked on numerous occasions to have bollards erected on Barnhorn Road so that we can cross safely to the bus stop but have always been refused, the sheer volume of traffic now makes it even harder to cross and is dangerous. There must surely be some consideration if housing goes ahead to keeping our area similar and by building further into the campus than opposite Wartling Drive.The question of design of the properties should be sympathetic to what is already here as the new houses I have seen being built are eyesores! There are protected trees on this land and I also hope that the wildlife people look into badger sets etc to protect our animals. It is sad that you are taking away so much land in Bexhill to build houses and affordable housing is a fast as no developer will sell houses cheap if they don't have to. Affordable is take the price right back to ten years ago and then that is affordable.

Employment led development on campus style business park to generate quality highly skilled, highly paid employment.

Option 3 or 4, as this allows for at a time in the future to change to housing needs. This would depend on future transport infrastructure provision which is unlikely to be delivered in the next 20 years.

I note and agree with your comments about this being a sensitive area to consider. Of the 4 options you present I believe the third, tourism orientated, one would give the widest benefit to the community as a whole. It would also have the least negative impact on the surroundings in terms of congestion and pollution. Tourism would sit neatly within Rother's principal objectives, and accords with our own personal aspirations and achievements nearby. Alternative suggestions might be an Ornithological centre in view of the nature reserve, or even a vineyard on the site of our old hop garden.

We prefer the Option 2 (Residential-led redevelopment)

Comments on Project BX101 Northeye.

The housing development of Northeye should become one of the preferred sites for building to the West of Little Common provided the North Bexhill Access road is first extended through to the A259 allowing easy access to Eastbourne, Ravenside, Hastings and St Leonards and, of course, the Conquest Hospital.

These comments are submitted as a joint response from the Spindlewood Drive Action Group (SPINDAG) and thus represent the majority views of a large number of local residents (c 400) living in and around the Spindlewood Drive proposed development area.

Of the 4 options proposed for BX101, Option 1- employment and redevelopment - is one of the better overall solutions. This is because there is a burning need for locally based employment around Bexhill and Little Common in particular and is especially relevant now that Barnhorn Green is proceeding with its 342 properties with little prospect of direct employment on that site.

If option 1 were chosen, a pedestrian and cycling link connecting BX101 and BX120 via BX47 and BX60 should be provided to connect to Coneyburrow Lane. This would, of course, be of great benefit to the residents, is environmentally friendly and would avoid unnecessary car access via the A259.

Option 2 - residential - is less desirable. It might be that this option might have to be considered if the overall Bexhill target set by RDC of 3100 properties is unlikely to be met. This may not become obvious for a few years and until firm plans and property numbers are known for sites such as

1. BX120 - the possibility of more residential houses on this site
2. BX124 - the possibility that more than 450 properties may be built here (Options 2 and 3)
3. The number of small and large site windfalls achieved during the period 2016 - 2021 may well exceed those envisaged by RDC in the Housing Land supply document as @ 1/4/2016.
4. It may well be that once these figures are known, any large scale residential development in or around Little Common may be rendered redundant.
Option 2 is not ideal however because of the impact this will have on the infrastructure of Little Common as a whole which will already be struggling with the impact of Barnhorn Green and other proposed smaller sites along Barnhorn Road and Cooden Sea Road. These could well result in a total of 400 new properties in a very small radius and thus no further large scale residential developments should be contemplated around Little Common including BEX9 (BX116) as well as BX101.

There is an option 5 however - a combined mixed site solution of options 1 and 2 . For example, 3-50 residential houses together with employment and redevelopment. This just might be the best solution of all.

Conclusion

Options 1 and 2 should be considered with preference give to option 1 but there might also be a compromise of a mixed site development combining options 1 and 2 but with only small scale residential development.

Large scale residential development of BX101 should be avoided at all costs to reduce the impact on Little Common's lack of suitable infrastructure.

This question relates to Northeye BX102 which is considered a brownfield site and has always had some development on it.
In view of the council's need to identify housing areas this would seem a good place to develop as there is already some housing there at present, so that options 2 would seem the least contentious. Our only concern relates to access to the site and the further demands made on the A259. This would give residents easier access to Eastbourne than to Bexhill and Hastings and surely this is not what the town would want. This development could isolate new residents and some thought would need to be given to this as well as the effect on the road

As stated in my answer to Q27 I see good potential for development of this site, which offers open space and flexibility in its design, and also offers scope for expansion. This derelict brownfield site is just the sort of place we should be seeking to re-develop, it would enhance the immediate local area and save green space where possible. It is true that improved access to the A259 would be needed - a mini-roundabout might be the least disruptive to passing traffic on the A259.

Of the options offered in the DaSA document I would suggest Option 2, Residential-led, but perhaps with some light industry which might offer very local employment opportunities to new residents.

Option 1 would create too much additional day-long traffic on the A259, coming & going in both directions, and doesn't help RDC with its aim of providing more housing.

Options 3 & 4 would not seem to offer much benefit in terms of housing or employment to the RDC population.

Some residential development could be attractive to workers who need to travel west to their work, thus reducing traffic loading in Little Common. Furthermore, if a bypass were ever to be built linking the NBAR to the A259 near the Lamb Inn, as has been widely promoted, one can imagine great scope for further development to the south of such a bypass, linking a Northeye development with a means of bypassing the whole of Bexhill via a link to the NBAR and Bexhill-Hastings Link Road.

We would support any of the suggested options if the northern part of the site is incorporated into such a use or used separately for playing pitch/open space purposes.

This land offers an opportunity to provide additional playing fields, the need for which is identified in the recent Playing Pitch Strategy for Rother and Hastings.

The town of Bexhill is in desperate need of facilities to support the local football clubs who currently compete in the Southern Combination Football League. As part of the national non-league pyramid clubs must meet strict ground grading requirements - these cannot be met by our club who currently play at Little Common Recreation Ground as permission will not be granted to make the improvements required as the Recreation Ground is public open space and cannot be developed any further. The opportunity to develop the land at Northeye to provide a pitch and facilities which would enable ground grading requirements to be met could prove vital in order to provide Bexhill with a facility that meets the club's needs to be able to progress and will also provide excellent opportunities for those living in the town.

Our club has for many years prided itself on providing opportunities for the youth of the town to participate in organised football training and matches and currently has fifteen youth teams (under 6's to Under 18's) which feed into our two senior and Under 21 teams. As a club, we can no longer progress at our home ground at Little Common Recreation Ground and have been threatened with relegation due to our ground grading (this will be enforced at the end of the 2017/18 season by the FA) - this will have a catastrophic impact on our club and on the town as a whole as there are no facilities in the town that can currently sustain Step 5 & 6 football. Members will therefore leave and travel to the neighbouring towns of Hastings and Eastbourne in order to compete at the highest level possible.

We will therefore support any proposals which allow land to be earmarked for playing pitch purposes in order to develop a facility that would meet the strict ground grading requirements of the Football Association and allow local clubs to not only progress but also provide the best sporting opportunities for those living within the town of Bexhill.

Of the 4 options proposed for BX101.

Option 1- employment and redevelopment - is one of the better overall solutions. This is because there is need for locally based employment around Bexhill and Little Common in particular and is especially relevant now that Barnhorn Green is proceeding with its 342 properties with what would appear to be very little employment opportunities in the immediate area or relevant increase in local infrastructure i.e school places, nursery school provider or gp surgeries.

Option 2 is not ideal because of the impact this will have on the infrastructure of Little Common as a whole which will already be struggling with the impact of Barnhorn Green and other proposed smaller sites along Barnhorn Road and Cooden Sea Road. These could well result in a total of 400 new properties in a very small radius and thus no further large scale residential developments should be contemplated around Little Common including BX116.

There is an option 5 however - a combined mixed site solution of options 1 and 2. For example, 30-50 residential houses together with employment and redevelopment. This just might be the best solution of all.

Conclusion

Options 1 and 2 should be considered with preference given to option 1 but there might also be a compromise of a mixed site development combining options 1 and 2 but with only small scale residential development.

Large scale residential development of BX101 should be avoided at all costs to reduce the impact on Little Common's lack of suitable infrastructure.

Of the 4 options proposed for BX101, Option 1- employment and redevelopment - is one of the better overall solutions. This is because there is a burning need for locally based employment around Bexhill and Little Common village in particular and is especially relevant now that Barnhorn Green is proceeding with its 342 properties with little prospect of direct employment on or near that site.

If option 1 were chosen, a pedestrian and cycling link connecting BX101 and BX120 via BX47 and BX60 should be provided to connect to Coneyburrow Lane. This would, of course, be of great benefit to the residents, is environmentally friendly and would avoid unnecessary car access via the A259.

Option 2 - residential - is less desirable. It might be that this option might have to be considered if the overall Bexhill target set by RDC of 3100 properties is unlikely to be met. This may not become obvious for a few years and until firm plans and property numbers are known for sites such as

1. BX120 - the possibility of more residential houses on this site
2. BX124 - the possibility that more than 450 properties may be built here (Options 2 and 3)
3. The number of small and large site windfalls achieved during the period 2016 - 2021 may well exceed those envisaged by RDC in the Housing Land supply document as at 1/4/2016.
4. It may well be that once these figures are known, any large scale residential development in or around Little Common village may be rendered redundant.

Option 2 is not ideal however because of the impact this will have on the infrastructure of Little Common village as a whole which will already be struggling with the impact of Barnhorn Green and other proposed smaller sites along Barnhorn Road and Cooden Sea Road. These could well result in a total of 400 new properties in a very small radius and thus no further large scale residential developments should be contemplated around Little Common village including BEX9 (BX116) as well as BX101.

There is an option 5 however - a combined mixed site solution of options 1 and 2. For example, 30-50 residential houses together with employment and redevelopment. This just might be the best solution of all.

Conclusion

Options 1 and 2 should be considered with preference given to option 1 but there might also be a compromise of a mixed site development combining options 1 and 2 but with only small scale residential development.

Large scale residential development of BX101 should be avoided at all costs to reduce the impact on Little Common village's lack of suitable infrastructure.

We live at 14 Ticehurst Avenue and have our concerns regarding the developments outlined.

We strongly feel that the tourism led redevelopment with a high quality eco development and park hotel, would not be suitable for the area as there is a lot of children on the estate, who enjoy to play on the estate and this could jeopardise the safety of the area with unknown people constantly driving through.

We feel that if a development has to take place the most suitable plan would be, 115 residential dwellings, as this would keep in the place the community feel. Our strong concern is that Barnhorn Road, the A259 would need to be dramatically improved as the congestion of traffic is horrendous, since the bypass has been built. It can take up to 20 minutes to get from Ticehurst Avenue to Little Common village most days.

Of the 4 options proposed for BX101,
Option 1- employment and redevelopment - is one of the better overall solutions. This is because there is need for locally based employment around Bexhill and Little Common in particular and is especially relevant now that Barnhorn Green is proceeding with its 342 properties with what would appear to be very little employment opportunities in the immediate area or relevant increase in local infrastructure i.e school places, nursery school provider or g.p surgeries.
Option 2 is not ideal because of the impact this will have on the infrastructure of Little Common as a whole which will already be struggling with the impact of Barnhorn Green and other proposed smaller sites along Barnhorn Road and Cooden Sea Road. These could well result in a total of 400 new properties in a very small radius and thus no further large scale residential developments should be contemplated around Little Common including BX116
There is an option 5 however - a combined mixed site solution of options 1 and 2. For example, 30-50 residential houses together with employment and redevelopment. This just might be the best solution of all.
Conclusion
Options 1 and 2 should be considered with preference given to option 1 but there might also be a compromise of a mixed site development combining options 1 and 2 but with only small scale residential development.
Large scale residential development of BX101 should be avoided at all costs to reduce the impact on Little Common's lack of suitable infrastructure.

Of the 4 options suggested, Option 1 (employment based) is the most attractive on the surface. This is what Little Common needs above all else rather than residential development due to the obvious lack of suitable infrastructure around Little Common (including lack of job opportunities). Being a brownfield site, this location should be developed come what may since it should be preferred over and above greenfield sites such as Spindlewood.

Another possible option would be a shared development combining a small residential area with employment based development thereby instantly providing the opportunity for the new residents to obtain work right on their door step (as well as other residents of Northeye).

To open up local job opportunities even further, a pedestrian and cycle path could also be provided from Barnhorn Green to Northeye.

The proposed BX101 is a better overall solution with Barnhorn Green proceeding with 342 properties. If option 1, were chosen with a pedestrian and cycling link connecting BX101/BX120 via BX47/BX60 could connect to Conneyburrow Lane giving less pollution and being friendly to the environment reducing car usage.

BX 101 however, is not ideal for the local community as the prospect of the large number of new dwellings in a small area would have a great impact on the A259/Little Common residents. With all the proposed new dwellings up to 400 properties around Little Common including (BEX9)(BX116)(BX101), large scale developments should not go ahead. Little Common does have the infrastructure to support large scale developments.

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

BX101
BEX11 - Options 1 & 2

European designated sites - Pevensey Levels Ramsar site: supporting habitat.

Our records show that, this site may form functional habitat for the bird species of the Ramsar and therefore detailed surveys/survey data will be required. If the site is confirmed as supporting habitat, it is given the same level of protection as the Ramsar.

Designated sites - Pevensey Levels SSSI; within 'Impact Risk Zone' (IRZ) for the SSSI.

If the allocation is likely to have a significant effect on the SSSI (e.g. from run-off and pollutants entering the ditch network harming the botanical, invertebrate and bird interest of the SSSI), appropriate mitigation measures need to be specified.

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.

Wastewater Treatment

As you are aware. Southern Water is the statutory sewerage undertaker in Rother District. In line with paragraph 162 of the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG), we have updated our site-by-site assessment of the sites with 20 or more dwellings identified in the draft Development and Site Allocations Local Plan (DaSA) to determine whether capacity in the local sewerage network is sufficient to meet the anticipated demand.

That assessment reveals that additional local sewerage infrastructure would be required to accommodate the proposed development, involving making a connection to the local sewerage network at the nearest point of adequate capacity.

a) Insufficient capacity (Northeye)

A lack of capacity is not a fundamental constraint to development however new or improved infrastructure would need to be provided in parallel with the development.

Connection to the sewerage network at the nearest point of adequate capacity is the mechanism by which the development can provide the local infrastructure required to service the sites. Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is insufficient. Planning policies and planning conditions, therefore, play an important role in ensuring that development is co-ordinated with provision of necessary infrastructure.

Unless planning policies support delivery of necessary underground sewerage infrastructure there is a risk that it will not be delivered in parallel with the development, leading to an unacceptable risk of foul water flooding in the area to both new and existing residents. This situation would be contrary to paragraph 109 of the NPPF, which requires the planning system to prevent both new and existing development from contributing to pollution.

It is likely that investment would be required to deliver additional wastewater treatment capacity. This strategic infrastructure, such as extensions to wastewater treatment works, can be planned and funded through the Price Review process, and coordinated with new development. Last year's (2015) price determination will fund the investment programme for the period to 2020. There will be another price review in 2019, covering the investment period 2020 to 2025. Adoption of development plan documents provides the planning certainty required to support investment proposals to Ofwat, the water industry's economic regulator.

We have therefore proposed policy provision below to secure delivery of necessary local sewerage infrastructure in parallel with development. Our proposed policy provision would be in line with paragraph 157 of the NPPF which states that Local Plans should 'plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this framework', and paragraph 177 of the NPPF outlines that it is important to ensure that planned infrastructure is deliverable in a timely fashion.

Furthermore, it is important to give early warning to prospective developers regarding the need to connect off-site, as it could add to the cost of development. Early warning will facilitate delivery of the necessary infrastructure as this infrastructure requirement can then be incorporated into the planning process at an early stage.


b) Proximity to treatment works (Northeye)

A few of the sites identified in the DeSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks; during secondary treatment; and particularly from sludge treatment, transfer and storage'.

c) Underground Infrastructure (Barnhorn Green Expansion)

Although not strictly a planning policy requirement, where appropriate we would also seek recognition of the need to protect underground infrastructure that cross the site so that this is not built over, and it can continue to fulfil its function. Easements would be required to allow access for future maintenance and upsizing. We have noted which sites this may apply to as an early warning to potential developers.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

Barnhorn Green Expansion

(Please note that Southern Water requires access to the existing outfall. The need for easements will therefore need to be taken into account in the layout of the site).

Northeye

We request additional criteria for this policy relating to utility infrastructure:

* A connection is provided to the local sewerage system at the nearest point of adequate capacity, in collaboration with the service provider.

This site is in close proximity to Wartling Drive, Bexhill Wastewater Pumping Station.

* The masterplanning of the site should take account of nearby wastewater pumping stations to minimise land use conflict.

Transport Strategy & Economic Development
BEXHILL Page 128

-Preferred Site: Northeye (Former United Arab Emirates - Technical Training Project), Bexhill (Ref: BX101)

The four options for development proposed at this site would all, to some degree, generate additional traffic, impacting on the nearby A259, which currently suffers from significant traffic congestion in peak hours.

However, with Bexhill being a key growth area for the County, it is recognised that the development of this site will support local economic growth. In terms of the options presented, development options 1 (employment led) & 2 (residential led) would be more favourable, but it would be essential that any policy associated with this site includes the need to accommodate improvements to the A259 to provide a suitable access onto the strategic road network along with providing transport choice for pedestrians, cyclists and public transport users, as in alignment with Core Strategy policy TR1.

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

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

Preferred Site: Northeye (Former United Arab Emirates - Technical Training Project), Bexhill (Ref: BX101)

Much of the site is likely to be heavily disturbed, but there are some areas of potential survival of archaeological remains, including some potential for waterlogged remains.
-GREEN

Ecology
BEXHILL Page 128

-Preferred Site: Northeye (Former United Arab Emirates - Technical Training Project), Bexhill (Ref: BX101)

Options 1 or 4 are preferred from an ecological perspective