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

Showing comments and forms 1 to 16 of 16

Comment

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

Representation ID: 21942

Received: 18/12/2016

Respondent: Ms Val Hunnisett

Representation Summary:

Agree.

Full text:

Agree.

Comment

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

Representation ID: 22027

Received: 04/01/2017

Respondent: Mr Charles Coombes

Representation Summary:

Generally agree. Would like to see more than just pitches. Provision needed for a wide range of other outdoor activities.

Full text:

Generally agree. Would like to see more than just pitches. Provision needed for a wide range of other outdoor activities.

Comment

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

Representation ID: 22187

Received: 06/02/2017

Respondent: Mr Roger Fendall

Representation Summary:

There must be at least two entrances/exits to the site to avoid traffic building up on the A259. Indeed a roundabout entrance should be considered.
This is not an area where affordable housing should be sited.
The A259 is a major road and traffic flow must not be impeded by such a development.

Full text:

There must be at least two entrances/exits to the site to avoid traffic building up on the A259. Indeed a roundabout entrance should be considered.
This is not an area where affordable housing should be sited.
The A259 is a major road and traffic flow must not be impeded by such a development.

Comment

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

Representation ID: 22188

Received: 01/02/2017

Respondent: Beaulieu Homes (Southern) Ltd

Agent: Mr John Cornwell

Representation Summary:

The policy is ill-founded, unsupported by evidence and should be deleted.

1.There is no evidence this site has any viable future as a formal sport playing pitch.

2.There is no prospect of any private/public funding available to secure the future as a playing pitch;

3.The site is subject to persistent vandalism.

4.The mitigation proposal put forward in the application effectively remedies an identified deficit in provision for a major Bexhill Sports Club.

5.The Council is unable to demonstrate a five-year supply of housing land.

Policy BEX11 should be deleted and replaced by a revised Policy for up to 65 dwellings.

Full text:

Representations to the Public Consultation into the Rother Development and Site Allocations Local Plan Options and Preferred Options December 2016 on behalf of Beaulieu Homes (Southern) Limited in respect of Land at the Former Sidley Sports Ground, Bexhill-on-Sea.

Draft Development Plan Document (DPD) insofar as they affect land controlled by my client, Beaulieu Homes (Southern) Limited, at the Former Sidley Sports Ground, west of Buckholt Lane, Bexhill-on-Sea.

Specifically Beaulieu Homes (Southern) Limited wishes to object to the provisions of Proposed Policy BEX11 which proposes to allocate my client's land for playing pitches for formal sport. The draft policy is ill-founded, unsupported by any evidence and should be deleted. This land should be allocated for housing.
Beaulieu Homes (Southern) Limited purchased the site in 2013 following the site's previous owners, Sidley United F.C., going into administration. The Council also attempted to purchase the site at that time but was unsuccessful, and since that time has tired to use its other powers to achieve what it could not achieve at that time. The site was the subject of a planning application by my client (Ref: RR/2015/2304/P) which sought outline consent for up to 70 dwellings with fully developed proposals to provide a significant financial contribution for the mitigation of the loss of the sports ground on the application site. Three alternative mitigation
options were presented to the Council, each of which would have fully mitigated for the loss in line with Sport England requirements. Unfortunately the Council deliberately refused to engage with my client. The result was that's none of the mitigation packages offered were deliverable since the Council owned the facilities concerned, As a result that application was withdrawn.

Very recently a revised outline planning application on this site has been submitted by my client (Ref: RR/2016/3127/P). It seeks consent for up to 65 dwellings (based on a revised illustrative layout which seeks to address many of the issues raised by the then planning case officer) and also proposes a sports mitigation package which fully meets the Sport England requirements for the loss of the application site as a playing field, and on sites which are not owned by the Council. Specifically, the proposal is the funding of an Artificial Grass Playing Pitch at William Parker School in Hastings, The School itself is very keen to secure this funding and the proposal has the full backing of the Bexhill Rugby Club who use the School's facilities. This mitigation package rectifies a specific and identified deficiency in provision in the Council's own Playing Pitch Strategy and for a well established sports club with a recognised need. The mitigation package can be delivered and is not dependent on the Council fir its implementation, which the Council has made clear would not be forthcoming.

The proposed site is not an appropriate location for a playing pitch. It is surrounded by medium density housing on all sides. Within the site the majority of the land is given over to the former playing pitch. The southern two thirds or so of the site is relatively flat but the ground rises to the north up towards Festival Gardens, making the playing pitch less than perfect. Since its vacation by Sidley United Football Club in 2013 the site has been subject to recurring vandalism.

Proposals for development which result in the loss of a playing field are subject to consultation with Sport England which has clear tests that must be successfully met before such development is allowed. Sport England would oppose the granting of planning permission for any development which would prejudice the use of whole or part of a playing field, unless an assessment has been carried out which confirms that there is an excess in playing field provision in the catchment area and the site has no special significance in the interests of sport, or significant mitigation measures can be put in place. The Council's policies in this area are set out in its Playing Pitch Strategy (2012-2018) and the Open Space Strategy, both of which form part of the Adopted Core Strategy Evidence Base, and are therefore directly relevant to this emerging Development and Site Allocations Local Plan. No new updated studies have been published by the Local Authority in the intervening period.

Following the Council's refusal to even consider the mitigation packages put forward in late 2015, the new planning application puts forward options which seek to deliver specific sports development programmes for Hastings Football Club and Bexhill and Hastings Rugby Club. Both Clubs are prominent in the area and attract a player base form across Rother district. They each run multiple senior and junior teams for both men and women. They have identified specific projects which will increase participation and help accommodate their existing and future fixtures and training programmes. The preferred option relates to William Parker School and Hasting and Bexhill Rugby Club because it is fully deliverable as the School controls the mitigation site. The other option relates to Hastings Football Club and Coombe Valley Park. Because the Council controls Coombe Valley Park it is clear that the option is not deliverable, though it meets the Sport England mitigation test.
Both William Parker School and the Hastings and Bexhill Rugby Club have the shared aspirations to install a synthetic tirf pitch at the school. This aspiration is long established and the rugby club have been in dialogue with the Rugby Football Union for match funding. However, they are unable to deliver the scheme for lack of funds. The financial contribution proposed of £350,000 from the development of the former Sidley Sports Ground for housing will deliver this facility. The synthetic pitch will result in a significant increase in the ability to fulfil formal fixtures and training, alleviating pressure on existing grass provision and enable juniors to play on appropriate sized pitches. Local clubs, the school and the wider community will benefit from the proposal which has been identified as a clear need within the area. The investment in the facilities, in a location which will benefit the wider community and existing clubs that utilise the site, can not be delivered by the Local Authority due to lack of funding. The long term and cumulative benefits associated with this mitigation package materially outweigh any benefits of the former Sidley sports ground remaining in its current unused state.

On this basis alone the Sidley Sports Ground site should be allowed to be developed for a much more appropriate use. The site is in private ownership and it has already been demonstrated that the site is not capable of being viable as a playing pitch. Even if the site ownership was secured by the Council it is clear that it would have no funds to make any effective use of the site. In the light of the above issues my client puts forward the following recommendations for the Council to consider:
Beaulieu Homes (Southern) Limited, therefore, strongly disagrees with the provisions of Proposed Policy BEX11, for the following reasons:

1. There is no evidence adduced either by the Council or any other party that this site has any viable future remaining as a playing pitch for formal sport. On the contrary, all of the available evidence points to the contrary;

2. There is no prospect of any private or public funding available to secure the future of the site as a playing pitch for formal sports;

3. The site is subject to persistent vandalism which will continue to undermine any efforts to retain the site in use as a playing pitch for formal sports.

4. The mitigation proposal put forward in the current planning application RR/2016/3127/P effectively remedies an identified deficit in provision for a major Bexhill Sports Club but on land not controlled by the Council and on which my client can therefore deliver. It also provides a significant additional facility to a large comprehensive school, so that the benefit is further enhanced. The mitigation proposals are fully in line with Sport England requirements.

5 The Council is unable to demonstrate a five year supply of available and deliverable housing land, and this position is worsening rapidly. This site can be quickly developed for housing and make a significant and material contribution to this housing land shortfall. There is therefore a clear and present presumption in favour of this site being allocated for housing.

Proposed Policy BEX11 should therefore be deleted and replaced by a revised Policy BEX11 with the site allocated for housing for up to 65 dwellings.

I trust that the above representations are clear but if any matter requires further clarification please do not hesitate to contact me further.

Comment

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

Representation ID: 22246

Received: 20/02/2017

Respondent: AmicusHorizon Ltd (Rother Homes)

Representation Summary:

Yes agree but only if there is proof that this is sustainable and supported by the local community - allow some flex to change to residential if none of the above fits.

Full text:

Yes agree but only if there is proof that this is sustainable and supported by the local community - allow some flex to change to residential if none of the above fits.

Comment

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

Representation ID: 22569

Received: 19/02/2017

Respondent: Bexhill Wheelers

Representation Summary:

Agree: Important that playing fields are improved and kept for public use with a management structure that will maintain and secure this site. Buckholt Lane to be upgraded to a shared walking and cycling path. Ensure that Parking provision is away from the public highway so residents are not effected.

Full text:

Agree: Important that playing fields are improved and kept for public use with a management structure that will maintain and secure this site. Buckholt Lane to be upgraded to a shared walking and cycling path. Ensure that Parking provision is away from the public highway so residents are not effected.

Comment

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

Representation ID: 22724

Received: 20/02/2017

Respondent: Heart of Sidley

Representation Summary:

Sidley lacks open spaces and has felt this lack in particular since the loss of this sports ground. The local cricket team have to play on neighbouring town which has directly impacted children to participate as they cannot travel to training.

The football club has the same problem. Sidley has a high level of deprivation and a lack of community spaces has a huge detrimental effect on the area. This ground is centrally located and it is fundamental that sport opportunities are available.

If the ground is used for houses it will place a further drain on the local resources.

Full text:

Development & Site Allocations Local Plan - options & preferred options for public consultation

The Heart of Sidley formally supports the retention of Sidley Sports Ground as playing pitches as per the council's Playing Pitch Strategy. Sidley lacks community green open spaces and has felt this lack in particular since the loss of this sports ground. An immediate example is that the local cricket team now have to play on neighbouring town facilities which has directly impacted the ability for some local
children to participate as they cannot travel to the weekly training in these towns.

The local football club have the same problem and again local children are struggling to get involved and enjoy sport. The village of Sidley has a high level of depravation and a lack of community spaces has a huge detrimental effect on the area. This ground is centrally situated in Sidley and it is fundamental that local sport opportunities are available in an area where there is deprivation.

If the ground is used to build houses, rather than to provide desperately needed open green spaces it will place a further drain on the local resources. The GP's, local schools, dentists would be flooded with additional people needing their services and the small village of Sidley would suffer. We strongly feel that the ground needs to be restored to public ground, including local sports facilities to allow the village of Sidley to connect the community again and not only restore the lack of sporting facilities and opportunities for local people but allow the community to enjoy a rare piece of community land that would benefit all.

Comment

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

Representation ID: 22860

Received: 08/03/2017

Respondent: Sidley Cricket Club

Representation Summary:

Land at Sidley Sports Club should be retained for recreational/sporting use. Furthermore we ask that the cricket square is retained and not just for football. Sidley CC had played here for more 100 years and the facility was one of the best in East Sussex.

We have lost a number of teams due to the ground closure. Existing teams have been displaced to Hastings.

We have reviewed all the current options identified in this plan for cricket. Not one provides for a replacement facility equivalent to that which was provided here. The ground should be retained for cricket and football.

Full text:

Yes we agree that land at Sidley Sports Club should be retained for recreational and
sporting use. Furthermore we would ask that the cricket square is retained and the area not put over to just use for football. Sidley CC had played at the sports ground for more 100 years and the cricket facility was one of the best in East Sussex. There were more than 45 matches played there in a season with training and coaching taking place at least 2 evenings a week. Membership of the Club totalled in excess of 80 people with participation from seniors, juniors, boys and girls. Due to the loss of this facility we now only play 9 home matches per season and membership is down around 30.

The closure of the ground means our two senior teams no longer exist as adequate facilities were no longer available for them to compete at the level which they were at.

Our old 3 eleven continues to play and ensures Sidley CC is still active, but is displaced from the local community having to play in the adjacent borough of Hastings. Playing in Hastings and not having facilities for practice means we can no longer offer coaching to develop players or the encourage young people of Sidley to participate in the sport of cricket even though we retain the ability and skills within the Club to do this.

We have been in contact with Rather Council and the Councillors with responsibilities for Sidley who are very supportive of our desire to return to play in the Sidley area. We have reviewed all the current options identified in this plan for cricket. Not one of the options provides for a replacement facility equivalent to that which was provided at the Sidley Sports ground. We believe that the ground should be retained with a configuration similar to that which it had so that cricket and football at senior level can continue to be played in Sidley.

Comment

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

Representation ID: 23042

Received: 17/02/2017

Respondent: Laurence Keeley

Representation Summary:

This should stay as a sports arena and have an indoor place for football, cricket, stool ball and other activities. One could incorporate some houses to help pay for the project. I can offer to put together a plan while the owner/developer may not want to go along with it, would the council be brave enough to create a vision for the community.


Additional supporting information was supplied which can be viewed here:

https://www.rother.gov.uk/icm/mediaaccess.cfm?CFID=1dec56da-d9cd-4a2d-a0a8-9e07aaec8afd&CFTOKEN=0&file=pdf/3/8/Keeley_L_Redacted.pdf

Full text:

This should stay as a sports arena and have an indoor place for football, cricket, stool ball and other activities. One could incorporate some houses to help pay for the project. I can offer to put together a plan while the owner/developer may not want to go along with it, would the council be brave enough to create a vision for the community.


Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28018

Comment

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

Representation ID: 23118

Received: 15/02/2017

Respondent: Mr Daniel Eldridge

Representation Summary:

Sidley Sports and Social Club should be allocated for playing pitches. This land offers an opportunity to provide additional playing fields, the need for which is identified in the recent Playing Pitch Strategy. 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 - this particular ground actually met the ground grading requirements for step 5 & 6 when it ceased being used in 2013. The town has no grounds which meet these requirements.

Full text:

We agree with the requirements of Policy BEX11 in that the land at Sidley Sports and Social Club should be allocated for playing pitches for formal sport. This land, which has been unused since 2013, 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 - this particular ground actually met the ground grading requirements for step 5 & 6 when it ceased being used in 2013. The town now has no grounds which meet these requirements or are able to meet the requirements.

Bringing this site back to use would enable the town to provide facilities for its football clubs to be able to progress and compete within the non-league pyramid and meet the 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 bring this ground back to use and 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 clubs' 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 safeguarded 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.

Comment

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

Representation ID: 23373

Received: 20/02/2017

Respondent: Sidley United Football Club

Representation Summary:

We formally support retaining Sidley Sports Ground as playing pitches.

We used to play at the Ground (shared with cricket club). Since closing, we have been forced to relocate to Hooe (5 miles away).

The loss of the ground was devastating. More than just football, the ground was a focal point for a thriving community.

There is a strong demand for football/cricket in the area but a shortage of adequate/appropriate facilities.

We consider there is no other viable alternative, other than the Sports Ground.

The Council's Playing Pitch Strategy highlights the significance/importance of the Ground and it is highly accessible/valuable.

Full text:

We are writing to formally support retaining Sidley Sports Ground as playing pitches.
We as a football club used to play at the Sports Ground and shared the facility with the local cricket club. Since the closing of the ground, we have been forced to relocate to Hooe Recreation ground, some 5 miles outside of the area.

Sidley United Football Club was formed in 1906 and for over 100 years have been at the very heart of the local community. Since the loss of our home we have lost this status and had to initially cease existing as a club before being able to reassemble at our new location in Hooe. There is no other viable space for us in Sidley at present. Sidley Sports Ground was what we deemed as our 'home' for a long period of time, and to many of us on the committee we still do consider the Sports Ground as our spiritual home.

The loss of the ground was devastating for all involved with the club. More than just the football side of things, the ground was a focal point for a thriving community who often frequented in the bar, which played an important role in fundraising and holding other social events for members of the local community.

There is a strong demand for sports and in particular football and cricket in the local area. There is a shortage of adequate and appropriate facilities for adults and youths and the Sidley Sports Ground provided excellent facilities - indeed it was the premium location for football in the area. If the planning application was successful then this valuable asset would be lost, depriving a large number of people the opportunity to partake in sports and recreation.

There is a lack of adequate facilities, specifically for football in the local area. As a club, we would require not only a large enough area for a full size football pitch, but changing rooms, toilets, refreshments areas and other spaces in order to be an operational football team in the town. We consider that at present there is no other viable alternative, other than the Sports Ground where we could accomplish this.

It has already been established that sport holds many benefits for people, from the physical side through to supporting on the mental health of individuals. We feel it is vitally important that local people have the opportunity to enjoy an appropriate sports field and reap the many benefits on offer by use of it.

There has been some suggestion that the landowner may provide some alternative support for sport in the local area if the application were to be successful. However as suggested above, we consider that there is a lack of appropriate space locally for the quality of facilities that we would need. The building of an astro-turf pitch or small scale football pitch would not suffice us, and nor would it be adequate for members of the local community.

As a club, we do not support the application for housing. We consider that if the application were to be granted, the chances of Sidley United returning to the local area and bringing members of the local community together would be virtually nil. We also consider that local residents would not benefit from the building of more houses in the area, as we are concerned that non-residents would purchase the properties, thus not actually benefiting local people.

We appreciate that the Council's Playing Pitch Strategy highlights the significance and importance of the Sports Ground and it is considered both highly accessible and valuable within the local District. We would like to reinforce that we agree with the Council in this regard and highlight the importance of retaining the Sports Ground as a sports field.

Comment

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

Representation ID: 23391

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

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.

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: 23500

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Transport Strategy & Economic Development
BEXHILL Page 128

Policy BEX11: Land at Sidley Sports and Social Club, Bexhill

Agree with policy BEX11, this will link with the proposed Bexhill Cycle Network, and the site should support access to this.

Full text:

Transport Strategy & Economic Development
BEXHILL Page 128

Policy BEX11: Land at Sidley Sports and Social Club, Bexhill

Agree with policy BEX11, this will link with the proposed Bexhill Cycle Network, and the site should support access to this.

Comment

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

Representation ID: 23553

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: 23626

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Archaeology

BEXHILL Page 128

-Policy BEX11: Land at Sidley Sports and Social Club, Bexhill

The site has high potential for prehistoric, Roman and medieval archaeological remains, so should be subject to archaeological assessment before being allocated.
-AMBER

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 BEX11: Land at Sidley Sports and Social Club, Bexhill

The site has high potential for prehistoric, Roman and medieval archaeological remains, so should be subject to archaeological assessment before being allocated.
-AMBER

Comment

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

Representation ID: 23720

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Ecology

BEXHILL Page 128

-Policy BEX11: Land at Sidley Sports and Social Club, Bexhill

Broadly yes, although it should be recognised that floodlighting could have additional impacts on biodiversity.

Full text:

Ecology

BEXHILL Page 128

-Policy BEX11: Land at Sidley Sports and Social Club, Bexhill

Broadly yes, although it should be recognised that floodlighting could have additional impacts on biodiversity.