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

I agree

Yes

The requirements will not get over much additional traffic, parking problems in Hobbs Lane and danger to children crossing Whitebread Lane.

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

FO15
BEC1

AONB - High Weald: site is within.

The policy needs to refer to the consideration of the site's AONB location.

The allocation needs to protect and enhance the character of AONB, in line the Management Plan, NCA and LCAs.

Landscape

VILLAGES WITH SITE ALLOCATIONS

Yes to all questions - Agree and support all of the village boundary and other policies.

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.

VILLAGES WITH SITE ALLOCATIONS page 219

The site has a low / medium potential to contain prehistoric, Roman and medieval remains. There are some areas of disturbance, but a planning application would be expected to include an archaeological assessment in line with para 128 of the NPPF.
-GREEN

Ecology

VILLAGES WITH SITE ALLOCATIONS page 219

Beckley Four Oaks

Yes

BEC1 - Land East of Hobbs Lane, Beckley.

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC2
Shows a large area set aside for amenity use, which is welcome, but the policy should set out more criteria so that it is also maximised for biodiversity enhancement and thus becomes multi-functional green space. This would be in line with the aims for Policy DEN4: Biodiversity and Green Space.

BRO1 - Land West of A28, Broad Oak
The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

Objection to Rother District Council's Development and Site Allocations Plan

I am Matthew Horton. I have lived in Beckley for twenty years. I wish to object to the sites selected in the village by Rother District Council ("RDC") provisionally for development for housing in the Development and Site Allocations ("DaSA") Local Plan - Options and Preferred Options.

I am a barrister (Queen's Counsel) specialising in town and country planning, among other practice areas. I own over one hundred acres of farmland and woodland adjoining the west side of King's Bank Lane. Part of my southern boundary adjoins Buddens Green, one of the proposed allocation sites.

I own also SHLAA site F02, which I bought many years ago when it was advertised for sale. My reason for purchasing it was that, with my knowledge of planning and development for housing, I knew that it was likely that further housing would be required in the village and I considered what is now known as SHLAA site F02 to be the most attractive location for such housing. Prior to my purchase, a number of other sites had been sold at auction. I considered that depending on the number of houses required m the future, F02 could be developed attractively with the eastern part of F08. Accordingly, I approached the owners of that land (who had purchased it at auction) and we agreed to seek to bring the combined site forward for development in the fullness of time. This objection is submitted therefore with their agreement as part of that process.

My objections are as follows:

(1) PROCEDURAL

(i) (a) Despite being a local resident and adjoining landowner to the Buddens Green site, I have not been informed by RDC of the proposals. I learnt of them through other residents and have now been given a copy of a letter dated 10 December 2016 to RJ Thomson Esq at his former address, Braeside House, in Main Street, notifying him of the proposals. To have failed to have notified me personally was procedurally improper and unfair.

(b) It seems likely that I am not the only resident of the village who has not been informed formally of the proposals. From the failure to inform me and others (if that is the case) it appears that the obligation to consult, imposed by Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012 has not been properly discharged and RDC must re-advertise and re-consult so that every resident of the village is informed of the proposals and of the right to make representations about them.

(c) The letter to Mr Thomson "encourages" but does not require those making comments "or use the Council's web-based consultation system", but states that "alternatively" comments may be sent "by post or via email. It further states, however, that such comments "should be submitted using the proper form which can be found on the Council's website or obtained at one of three 'deposit points' in Bexhill, Battle and Rye respectively". That requirement cannot be lawful. There may be persons who, for example for financial reasons or age, are not computer literate or do not have a computer, or are not able to travel to any of the three towns. In my opinion, comments in a letter sent by post, identifying the subject matter as commenting on the DaSA is a lawful representation which RDC must take into account. Not to take it into account would be procedurally unfair and render unlawful the consultation process.

Please inform me whether RDC accepts sub-paragraphs (a) to (c) above as correct or, if it does not, inform me of its reasons for not agreeing.

(ii) There are no diagrammatic layouts of the housing proposed on each site proposed for housing by RDC. Both sites are of limited size, adjoin existing development and require the creation of an internal access road; their ability to accommodate physically the number of dwellings allocated on each site cannot be judged without diagrammatic layouts. Because the justification for the total number of dwellings proposed on the two sites together is stated in the DaSA to be "to meet the development targets set out in the Core Strategy", it is critical to be confident that the twenty dwellings for Beckley can be accommodated satisfactorily physically on the sites proposed. The lack of such layouts invalidates therefore the DaSA for failing to provide sufficient detail to enable a proper assessment to be made by the public.

(2) SUBSTANTIVE OBJECTIONS

Without conceding that the proper legal requirements relating to public consultation have been observed, I set out below my substantive objections, which the summary objections lodged on 20 February 2017 by email on RDC's forms provided on its website. This letter and those forms should be read together:

(i) Overall context - Non Site Specific Issues

(a) The DaSA is based on the Core Strategy which is stated by RDC to "set the vision and overall targets for Rother District to 2028". It follows that in the DaSA the "vision" referred to should be identified so that a judgement may be made as to whether development of the sites proposed would accord with that vision. Nowhere in the DaSA is that vision identified, let alone the manner in which the development of the two sites would accord with it.

(b) Based on my examination of the Core Strategy, although it is invidious to be unduly selective, I suggest that the following precepts are key components of the vision which should guide the choice of sites for housing and the manner of their development in Beckley / Four Oaks.

The distinctive characteristics of the village and its countryside setting should be recognised and respected (Core Strategy paragraph 5.7 and 7.7).

To increase the overall prosperity of the village should be a "key local objective" (Core Strategy paragraph 5.3). The design of any new development should include "an appropriate high quality response to local context and landscape" (Core Strategy paragraph 12.40).

(c) The existing character of Beckley / Four Oaks.

As its name recognises, historically Beckley / Four Oaks comprised two separate settlements, Beckley to the west and Four Oaks to the east, but it is usual now to refer to them as one settlement known as Beckley. Most of the development in both is linear in character along Main Street (B2088) and Whitbread Lane (the A268).
The original settlement of Beckley is medieval in origin and centred on the parish church. It has a number of very fine listed buildings. Four Oaks is less distinguished, although it has some charming older buildings, although their setting has been harmed by more modern buildings, the design of which has ignored entirely the local vernacular style, for example the Garage Door Shop, Tamarisk and the pairs of 1970s semis on the north side of Main Street leading to the mini roundabout on the Rye Road (the A268 known as Whitbread Lane).

In an appeal decision in 2005 (APP/U/1430/A/04/1149785 - the "2005 Appeal decision") an appeal by a local resident, Mr Goodwin, against the refusal by RDC of planning permission for housing on the open land immediately to the west of Buddens Green, the Inspector stated (Decision Letter ("DL") para. 23) that "Beckley may not rank amongst the most highly attractive villages"; he stated also, however, that "it is not without considerable charm" and that many of its houses are "in a pleasing Wealden vernacular style". He identified as "[a] most distinctive and attractive feature of the village... the open spaces along Main Street stating that "they prevent an unrelieved ribbon of development, and provide views from the roadside into the surrounding countryside". He considered that to fill such a gap would "substantially harm the countryside and the landscape quality of the AONB'" (DL paragraph 24). He emphasised also that such harm would result not only from occupying the "road frontage" but from extending "well back from the highway" (DL para. 25).

(d) It is clear from the foregoing that the gaps and views referred to above are distinctive of Beckley / Four Oaks and any vision for development in the village should respect those characteristics. It is also clear that more recent development in a non-vernacular style in Four Oaks has detracted from the charm of the village and should be redressed when the opportunity arises.

(ii) Extent to which the current DaSA has had regard to the context described above.

* The DaSA emerged in 2013 from RDC's earlier Strategic Housing Land Availability Assessment ("SHLAA") published in 2010 following a site identification consultation exercise in 2008 pursuant to which development sites could be proposed by the public. Fourteen sites were put forward in Four Oaks. All but one were rejected; the exception was site F012 which comprised a field known locally as Bushy Field, owned by a local resident, Mr Goodwin, together with an adjoining area of open land, owned by the Beckley Parish Council behind the Buddens Green development. In the SHLAA, the site was described inaccurately as "land to the rear of Buddens Close" and was stated to be "'suitable and developable". No mention was made of the Inspector's judgement in the 2005 appeal decision that to develop the gap in which the site is situated would substantially harm the street scene, the countryside and the AONB.

* In reliance on the SHLAA, Mr Goodwin submitted a further application in 2016 which officers informed him they could not support, whereupon he withdrew it but has subsequently submitted a further application for a reduced number of dwellings.

* I and many others, relying on the 2005 appeal decision, have objected to that application. The application has yet to be determined, but I assume that it will be refused, since, in the DaSA, RDC, in identifying land south of Buddens Green (Ref. F012a) as a preferred site for some eight dwellings, states that "a western extension is not considered appropriate, as this area has been recognised, via appeals, as providing an important, characteristic open gap along the road frontage, with view's over it"

* Although, therefore, in contrast to the SHLAA, the DaSA has taken account of the 2005 appeal decision by excluding the open land to the west of Buddens Green, it has failed to understand that decision correctly by continuing to propose development on that part of the gap behind Buddens Green. That failure is part of a wider failure by RDC to evaluate correctly the contribution of the whole gap to the surrounding countryside and the AONB. This is elaborated further in section 2(iii) below.

(iii) Site specific reasons for objecting to the proposed allocation south of Buddens
Green (F012a).

The area proposed for housing is visually an important part of the gap
identified in the 2005 appeal decision as to be protected from development.
The whole of the proposed area can be seen from the footpath to the east
and from King's Bank Lane to the west over the field gate opposite Royal
Oak Close. It is a beautiful rural view which would be ruined by built
development.

To develop the area for housing would conflict with the Inspector's
judgement in the 2005 decision that "development in depth extending well
back from the highway" would be "greatly at odds -with the predominantly
frontage development in the vicinity"' (see DL para. 25).

The development would be harmful to the enjoyment of walkers on the
footpath by reason of its built form and light pollution.

The development would devastate the rural outlook to the south from the
existing Buddens Green dwellings.

The development would create an oppressive sense of enclosure to those
existing dwellings.

The inclusion of the existing green to the north of the Buddens Green
dwellings is entirely unnecessary. That green has matured into a most
attractive amenity space for the existing residents and should be excluded
from the proposed allocation just as the existing dwellings have been
excluded.

The proposal "to incorporate... as open amenity land" that part of the open
land to the west of the proposed housing conflicts with the 2005 appeal
decision which recorded that (DL para. 11) "it has been used as farm land
in the past and there is no substantial evidence to support assertions that if
is unsuitable for such use". The activities and paraphernalia associated
with an amenity use would jar with the idyllic rural vista from Main Street
to the south, of which the land forms part.

Given that Buddens Green enjoys already a green of its own and given that
the existing village recreation ground lies a short distance to the west and is
accessible both from Main Street and King's Bank Lane, even if the
dwellings were to be built, there is no need for the land to the west to be
allocated as amenity land. Furthermore, via the footpath to the east, access
can be gained readily to the Forestry Commission woodland to the south.
It is not stated whether the proposed dwellings should be "affordable" (as
the existing dwellings are). There is, however, no need for such provision on this site. Such provision can be provided as part of a proposed development of affordable and market housing on site F02 and part of F08 on the SHLAA map. This proposal is the subject of the pre-application advice process at the present time. It is described further in section 2(vi) below.

-Answers to question 55 in the DaSA:

Question 55: For the reasons set out above, I disagree with Policy BEC2. It should be deleted in its entirety and replaced by a policy providing for the provision of the housing requirement for Beckley Four Oaks on SHLAA sites F02 and part of FOS.

(iv) Site specific reasons for objecting to the proposed allocation of land east of Hobbs Lane (F015) (the "Manroy site").

* This allocation conflicts with the RDC's previous approach to identifying further land for housing in Four Oaks which consistently sought sites "central to the village" (see e.g. SHLAA comments in supporting site F012).

* The allocation includes land which was part of site F06 in the SHLAA. In rejecting that site the comment in the SHLAA was:

* Accessibility to local facilities and set-vices is relatively poor at this end of the settlement compared to other available sites which are more centrally located and closer to local services... Unacceptable impact on the landscape character of the AONB. Not suitable for housing.

* In the Rother District Council Local Plan 2006, the northern end of Hobbs Lane was allocated for employment uses. Such uses still predominate and the appropriateness of those uses has been confirmed in recent years by allowing redevelopment for those purposes on the western side of the Lane.

* It is necessary to continue to safeguard land for such uses in this location. The importance of being able to accommodate employment uses in the village must increase as the population increases. It follows that to release the land for housing is contrary to the cardinal principle of sustainability which central government and local policy requires to be respected in taking all decisions relating to the use and development of land. The sustainability principle requires the safeguarding of the employment needs of present and future generations.

* To permit housing in this location merely perpetuates the approach to development in Beckley / Four Oaks which distributes it on small plots and enclaves without any regard for the overall character of the settlement and the desirability of providing a heart to the village where residents can congregate and interact. With the closure of the Royal Oak pub and retail outlets in Main Street to the east, the need for such a heart is all the greater, highly popular though the Rose and Crown pub is at the western end of the settlement. It is envisaged that the development favoured by the owners of F02 and part ofFOS would complement that pub by providing a green open space and a village shop in an environmentally acceptable manner. The size and location of the Manroy site makes it entirely unsuitable for that purpose.

- Answer to Question 54 in the DaSA:

It follows that I disagree with Policy BEC1. It should be deleted since it is not appropriate to provide any housing on the site. Far more satisfactory provision can be made on SHLAA sites F02, together with part of site F08.

A policy should be introduced to provide for that.

(v) Proposed development boundaries in the DaSA.

Answer to Question 56

It follows from my answers to Questions 54 and 55 that I do not agree with the proposed development boundary for Beckley Four Oaks shown on Figure 73 of the DaSA. Neither of the proposed amendments should be adopted but a new amendment should be made to incorporate SHLAA site F02 and that part of SHLAA site F08 which adjoins the southern boundary of site F02.

(vi) The justification for amending the settlement boundary for Beckley by incorporating SHLAA site F02, together with part of SHLAA site F08.

* In the SHLAA, site F012 was favoured as being "relatively central to the village, close to existing services and in a sustainable location". The same characteristics apply to the proposed alternative location. In the SHLAA, however, F012 was described incorrectly as not having views over it (from Main Street) that "extend into the open countryside". The 2005 appeal decision establishes that there are such views and that they are to be prized and protected. The decision establishes also that site F012 comprises part of an important gap on Main Street which, together with the adjoining open land to the rear (south) of Buddens Green, should be safeguarded as open land.

* The reasons given in the SHLAA for opposing site F02 and F08 as sites for housing do not withstand critical scrutiny. In particular:

* The description of the existing pattern and form of development in Beckley Four Oaks as being "ribbon development interspersed with gaps between cluster of development" applies to development along Main Street. It does not apply to development along Whitbread Lane.

* The development site F02 would merely extend the existing uninterrupted line of development along Whitbread Lane from the mini roundabout at the junction with Main Street. The extension would halt at the point where the thirty mile an hour speed limit on that section ofWhitbread Lane ceases.

* The opposite side of Whitbread Lane along that stretch of the lane is already developed with housing. F02 is largely screened from view from Whitbread Lane by a mature native hedge. In any event, the landscape quality ofF02 is manifestly modest and greatly inferior to F0 12.

* The part of F08 proposed for inclusion with F02 as a housing site does not it extend well into the countryside". That description in the reason in the SHLAA for rejecting F08 plainly applies to the western section of F08 which is not proposed for inclusion with F02 as a housing site. Similarly, the frontage of F08 on Main Street is not proposed for inclusion.

* Development of F02 and the relevant part of F08 would be a logical consolidation of existing development along Main Street and Whitbread Lane. By virtue of being behind that development, it would not change the existing street scene in Main Street to a material degree and certainly, subject to proper control over layout and design, would not be harmful. It can be designed and laid out so as to have the appearance of traditional village housing which has been provided gradually rather than having the appearance of a housing estate. If access is taken through the Garage Door site, it would enhance the conservation area by removing the ugly buildings on the frontage of that site and replacing and repositioning it with a building which respects the village vernacular.

* The size of the site is such that it can provide the full complement of dwellings (affordable and open market housing) planned in the village and can accommodate green open space accessible to the public and a local shop and cafe if desired.