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

Para 12.4: The 'residual requirements' e.g. 425 for Battle. In general terms how will these be met

If I have understood the table correctly, does this mean than an extra 1,044 additional homes need to be found, above those documented in the options and preferred options document of Dec 2016?

Is all of this development needed? Where are these people going to work?
I feel that the A259 needs a vast improvement or re-routing before any developments occur. the congestion at Little Common is making the use of 'Rat Runs' the norm and roads such as Sluice Lane and Herbrand Walk are at present NOT coping with the increased traffic.
If any of these developments go ahead and the demographic of Bexhill changes there will not be enough school places for additional pupils.
There needs to be a Green Barrier created between Hastings and Bexhill and Bexhill and Eastbourne.
The Pevensey Levels do this well at present and any encroachment onto this area of ecological importance should not be allowed.
Brownfield sites should be the first to be developed and for residential use, they would improve the urban environment and provide Affordable homes.

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


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

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

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

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

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

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

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

The Rother District Development and Site Allocations Local Plan

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

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

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

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

Q6 - Equestrian development - Support approach - as drafted

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

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

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

Q11 - External residential areas - Support proposed policy

Q12 - Extensions to residential gardens - Support proposed policy

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

Q14 - Boundary treatments and accesses -Support proposed policy

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

Holiday Sites - Support proposed policy

Q16 - Existing Businesses and Sites - Support proposed policy

Q17 - Landscape and AONB - Support proposed policy

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

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

Q20 - Drainage - Support the policy approach

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

Q22 - Environmental Pollution - Support policy approach

Q23 - Comprehensive Development -Support policy approach

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

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

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

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

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

Although rural areas need affordable housing, not all rural areas have public transport links or local amenities, this makes it hard to let as affordable rent so only suits shared ownership. Affordable Rent should only be allocated to rural areas where there is public transport links but again they need to be affordable.

Employment opportunities, there doesn't seem to be any requirement for developers to provide training or apprentices, or using local people to work on the development.

Older Persons and Specialist Housing for Older Persons, there isn't an indication of age groups between either Specialist or Sheltered. This needs to be defined.

The PC supports the principle of neighbourhood planning and the confirmation in 5.1 that once adopted, a NP has the same status as local plans. It is to be noted that the Robertsbridge NP has moved on to 'Stage 4'.

We have referred where we felt it relevant, to the lack of policies introduced in this DaSA, given that the opportunity has been taken to update and improve core policies adopted in the 2014 Core Strategy. We have referred to the lack of policy:
* to confirm the need for investment in the Green Infrastructure Network; and
* to assist in the reuse of contaminated land, which should require updating work being done on the RDC monitored Register of Contaminated Land.

We also feel that the Transport policies of the Core Strategy could be improved. For example TRI(iv) where it talks about capacity and capability of improvement, should specifically refer to such matters as station infrastructure, including on-site parking provision.

Also, there is little evidence of support for the maintenance and improvement of bridleways and footpaths, which are needed in the pursuit of improved health for all and improvement in leisure capacity. We suggest a policy which positively supports the development of improved footpaths and bridleways, ensuring that any new development has connections with the foot and bridle path network where this is possible.

NO and on reading the submissions of all parties I am convinced of thoroughness with which this application has been approached and the council's conclusions.

§5
Please note that Salehurst and Robertsbridge Neighbourhood Plan ('SRNP') is now at Reg 16 stage, with a consultation period running from 10 February to 24 March 2017.

§12.9
We are concerned about the wording in this paragraph, with regard to parishes that have made the considerable efforts in achieving their own Neighbourhood Plans. They should not suffer by Rother using this paragraph to approve other sites within the geographical scope of their Neighbourhood Plan which were properly dismissed as part of the review leading up to the Neighbourhood Plan. The second sentence should therefore contain a reference in the 'have regard to' of the existence of the Neighbourhood Plan and acceptance of its planning principles.

We believe that the opportunity has been missed to expand and improve generally the policies in the 2014 Core Strategy on Transport

We believe you could introduce a policy on the maintenance and improvement of footpaths and bridleways. Our Policy IN4.2 does this.

We would also wish to see specific support for improving such transport infrastructure. Particularly relevant to Robertsbridge, and other villages and towns with a rail station, is appropriate provision for car parking, acknowledging the problems created by commuter on-street parking, and use of other car parking spaces.

Para 5 generally
We support Rother enabling parish and town councils pursuing their own Neighbourhood Plans, but question the ability of Rother to co-ordinate satisfactorily the outcomes of those NPs to secure sufficient housing development sites within their set timetable. Will Rother offer more help to local parish and town councils to secure that objective?

Para. 6.20
Rother should incorporate a new policy on solar energy, ie Policy DRM2 to encourage solar on industrial buildings, including retro-fitting, provided such installations do not have an adverse effect on the landscape, and generally do not adversely impact neighbouring users and do not result in the loss of Grade 1, 2 and 3a land.

We feel that the opportunity has been missed to support footpaths, bridleways and cycle paths. There should be a requirement for all large scale developments in Bexhill - say over 30 houses - to contribute specifically to the creation of urban cycle routes.

In the countryside also, support could be given to maintain, improve and create new footpaths.

As previously mentioned, paragraph 12.9 would appear to encourage additional development on site previously chosen by Rother, but now superseded in new plans. Mainly the change of sites will be in Neighbourhood Plans where alternative sites may have been chosen in place of those chosen earlier by Rother. Times change and places change. This paragraph shows that RDC are not fully engaging in the NP process and allowing villages/towns to make their own site selections and would suggest that RDC does not trust the NP process. This is against national policy and the NPPF.

I support Rother enabling Parish and Town councils pursuing their own Neighbourhood Plans, but question the ability of Rother to co-ordinate satisfactorily the outcomes of those NPs to secure sufficient housing development sites within the RDC set timetable. Will Rother offer more help to local Parish and Town councils to secure that objective? The NP liasion office at RDC left in 2016 and has not been replaced yet. Since then, there appears to have been very little support from Rother for NPs.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

Response to your consultation

The Marine Management Organisation (MMO) is a non-departmental public body responsible for the management of England's marine area on behalf of the UK government. The MMO's delivery functions are; marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing European grants.
Marine Licensing
Activities taking place below the mean high water mark may require a marine licence in accordance with the Marine and Coastal Access Act (MCAA) 2009. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object below the mean high water springs mark or in any tidal river to the extent of the tidal influence. You can also apply to the MMO for consent under the Electricity Act 1989 (as amended) for offshore generating stations between 1 and 100 megawatts in England and parts of Wales. The MMO is also the authority responsible for processing and determining harbour orders in England, and for some ports in Wales, and for granting consent under various local Acts and orders regarding harbours. A wildlife licence is also required for activities that that would affect a UK or European protected marine species.
Marine Planning

As the marine planning authority for England the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the mean high water springs mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of the mean high water spring tides mark, there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. On 2 April 2014 the East Inshore and Offshore marine plans were published, becoming a material consideration for public authorities with decision making functions. The East Inshore and East Offshore Marine Plans cover the coast and seas from Flamborough Head to Felixstowe. For further information on how to apply the East Inshore and Offshore Plans please visit our Marine Information System. The MMO is currently in the process of developing marine plans for the South Inshore and Offshore Plan Areas and has a requirement to develop plans for the remaining 7 marine plan areas by 2021.
Planning documents for areas with a coastal influence may wish to make reference to the MMO's licensing requirements and any relevant marine plans to ensure that necessary regulations are adhered to. For marine and coastal areas where a marine plan is not currently in place, we advise local authorities to refer to the Marine Policy Statement for guidance on any planning activity that includes a section of coastline or tidal river. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act and the UK Marine Policy Statement unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service soundness self-assessment checklist.
Minerals and waste plans and local aggregate assessments

If you are consulting on a mineral/waste plan or local aggregate assessment, the MMO recommend reference to marine aggregates is included and reference to be made to the documents below:
* The Marine Policy Statement (MPS), section 3.5 which highlights the importance of marine aggregates and its supply to England's (and the UK) construction industry.
* The National Planning Policy Framework (NPPF) which sets out policies for national (England) construction minerals supply.
* The Managed Aggregate Supply System (MASS) which includes specific references to the role of marine aggregates in the wider portfolio of supply.
* The National and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period including marine supply.
The NPPF informed MASS guidance requires local mineral planning authorities to prepare Local Aggregate Assessments, these assessments have to consider the opportunities and constraints of all mineral supplies into their planning regions - including marine. This means that even land-locked counties, may have to consider the role that marine sourced supplies (delivered by rail or river) play - particularly where land based resources are becoming increasingly constrained.

After reading through your Development and site Allocation Local Plan either we have missed the correct heading or you have not included several important facts.

A. All Planning in depth Ecological Applications must include a full Ecological survey and report that covers all resident protected Species of Wildlife.

B. To encompass a full in-depth Survey takes several months not an hour and a half walk over. Listening gear with directional microphones are essential to number and track Common Shrews and Mini Shrews. Crested Newts and the other two Species all are now protected in law need careful surveying and as we all know it is not permitted to build within a thousand meters of a Great Crested Newts Breeding Ponds.

C. Wildlife In the flesh live alongside humans very happily, but Badly installed Bird ' boxes only feed Cats as the fledglings flutter to the ground and we have yet to see one so called Bat box that is in use Just figments of someone's imagination.

D. Although at 38 and 39 in your Glossary you mention Habitats it is not concerned with the sites depicted in other parts of your publication. An owner of a site that contains Resident and daily visits by populations of protected species of Wildlife is in law required to ensure the future welfare of the animals involved Badger safe alternative foraging and long term safe setts.

Slowworms and Common Lizards safe foraging and Hibernacula. Bats must be correctly catered for. Plus the fact The Ecologist must make out a correct true Annual Report available for all to see.

Additional supporting information was supplied which can be viewed here:

I have included 3 examples of items we have contacted Rother District Council regarding our very serious concerns, we own a site at Preston Hall Farm that contains a very large Badger Sett. We went to the Consultation and informed Persimmon Homes that

(a) The Badgers were not being correctly catered for.

(b) The Slowworms had not even been surveyed alongside all other legally protected Species of Wildlife.


Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28019

Under the community land trust plan I believe there should be 20/25 houses in every village.

We used to have young people in the villages. There were teams for football, cricket, stool ball and some other activities, but now most villages are full of older people. The young ones move out as there are no houses for them. Village homes are sold to retirement folk.

Ashburnham, for example, could take 29 houses by the planned village hall, add £10,000/£15,000 to each one, there's the new hall paid for.

Dallington, where there is a traveller's site for one, there could be 20 homes there. It's called cold Harbour, I believe, the same for Brightling and Mountfield. We should invite every parish council to find a site to build for the local people. If there are no young people they will turn up if the homes are truly affordable, create a few work places in the villages and re-establish farming. It could be done. There is no need to look for developers saying what they want to build. Rother should tell them what to build.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28018

Neighbourhood Plans.

The DaSA expects all neighbourhood plans to have completed regulation 14 by end
August 2017. This is unachievable and the date needs to be considerably extended.

Sedlescombe has the best experience having completed the regulation 14 twice
and has a good understanding of RDC's requirements and timescales. RDC has very
limited resources to service Neighbourhood Plans. It should be noted that a
neighbourhood plan does not carry weight at regulation 14 for planning applications and should not therefore be considered to carry weight in the site assessment process through the DaSA.

It is highly unlikely that a number of parishes will have achieved regulation 14 by September as some have barely commenced their plans. 4 out of the 8 months now available will be taken up with sea scoping and regulation 14 consultation periods leaving just 4 months for the highly complex and detailed work of preparing the draft plan and submission version let alone the call for sites and site assessment work and evidence gathering. The LPA needs to put significant resources into supporting the emerging Neighbourhood plans by funding additional officers through the grants made available by central government to LPA'S for supporting neighbourhood plans to ensure as many as possible meet the LPA'S deadline.

SPORTS AND RECREATION FACILITIES

Sedlescombe sports field has been incorrectly referred to as Oakland Park. Currently the field is run by the Sedlescombe Sports Association (SSA) whose mandate is to promote a wide variety of sports not to simply place all control with one sport. The DaSA documents suggests control be given to the Sedlescombe Rangers which is outside the DC'S gift and responsibility. This would be contrary to the mandate of the SSA and beyond the terms of the SSA'S Sedlescombe lease with the Parish Council who is the ultimate owner. In addition a very small percentage of the rangers is made up of children from Sedlescombe.

Rother District Council DaSA Local Plan, Options and Preferred Options
Site Allocations in Battle

Strutt & Parker's planning department are instructed to respond to the Development and Site Allocations (DaSA) Local Plan, Options and Preferred Options on behalf of the owners of Netherfield Place Farm, which is located at Netherfield. Our comments are in relation to the allocation of housing sites in Battle.

Policy RA1 of the adopted Core Strategy identifies a need for 1,670 additional dwellings in a number of villages during the Plan period 2011 to 2028. Following the deduction of existing commitments, a residual requirement of 800 dwellings is identified for the villages, to come forward through site allocations (paragraph 12.13). It was noted that these site allocations would be made in the DaSA and/or Neighbourhood Plans.

The DaSA provides a breakdown of how the housing requirement for the rural areas will be distributed to each village. Provision is made for 115 dwellings in Netherfield during the Plan period, to include 48 on new site allocations. We note that this figure coincides with the total number of units identified on positively-assessed sites in the 2013 SHLAA, and does not necessarily preclude additional sites that have been assessed positively since then. If the Neighbourhood Plan allocates sites instead of the DaSA, a flexible approach must be taken to the proposed housing requirement because it would otherwise restrict the Neighbourhood Plan Forum to identifying only those sites that were positively assessed in the 2013 SHLAA. Such a flexible approach would accord with the need for the Core Strategy housing requirements to be achieved as 'a minimum'.

The draft DaSA that is subject to the current consultation does not include allocations for Netherfield at all and instead relies on the Battle Neighbourhood Plan for allocations. To rely on a Neighbourhood Plan, which has made no progress at all in the two years since the area was designated, would put a question mark over the ability of the Local Plan to deliver the requisite number of dwellings during the Plan period. Eight other Neighbourhood Plans are being relied upon in this way - albeit two have made sufficient progress that their delivery can be relied upon (Salehurst & Robertsbridge NP, and Sedlescombe NP).

The draft DaSA states that all the Neighbourhood Plans need to be in place at approximately the same time and that "it is vital for all communities to have plans in place as soon as possible" (paragraph 55). It is however impossible to control this process, and the council are placing an unreasonable amount of responsibility on the Neighbourhood Forums, who are under no obligation to produce their plans within a certain timescale. The timing for the delivery of the plans is very much dependent on the resources available to each Neighbourhood Forum and the process falls outside of the Council's control.

It is therefore paramount that the Council prepares for the inclusion of sites within the DaSA where they fall within designated Neighbourhood Plan Areas. These sites can always be withdrawn at a later date should the identified Neighbourhood Plans progress at an appropriate pace, as is being proposed by Wealden District Council and which is an appropriate contingency strategy.

The inclusion of housing site allocations in the DaSA for Netherfield would not preclude their replacement with policies contained in a Neighbourhood Plan, should one be produced at some point during the plan period. In any case, the community would be able to contribute to the identification of appropriate site allocations in the DaSA and the process would therefore not conflict with the main purpose of the Localism Agenda which is to include local communities in key planning decisions in their area. To exclude allocations in the DaSA from the Battle area (including Netherfield) could result in insufficient residential development taking place during the plan period, leaving the Council with a housing land supply shortage when assessed against objective needs. The need to adequately meet the housing requirements for the Battle area in the DaSA is paramount because of the threat of speculative applications being submitted as a result of the Council being unable to demonstrate a five-year housing land supply.

Site Proposal

Netherfield Place Farm contains a significant area of land to the south east of the main settlement confines, and includes the triangular piece of land located at the junction between the B2096 and Netherfield Road (see enclosed plan). An area measuring 2 hectares is proposed for allocation for approximately 48 dwellings, fronting onto Netherfield Road (see enclosed plan).

Access would be achieved from Netherfield Road, as close to the junction with Darvel Down as possible to ensure good pedestrian connectivity shops and services, including the primary school and post office.

The site could be well screened from the wider landscape by reinforcing the southern boundary of the site with a dense tree buffer. Landscape impact is the only potential constraint to the site, but this can easily be mitigated with additional planting and sensitive design.

We look forward to reviewing your Authority's response to these representations in due course.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28061

Q.6 DISAGREE IN PART: THE 18 MONTH MARKETING CAMPAIGN IS TOO LONG AND SITES SHOULD BE CONSIDERED ON THEIR INDIVIDUAL MERITS.
Q.7 DISAGREE IN PART: THE POLICY IS DISCRIMINATORY AGAINST EQUESTRIAN ACTIVITIES IN RURAL AREAS AND SHOULD NOT GO TOWARDS PREVENTING PEOPLE FROM OWNING HORSES.
IT WOULD APPEAR THAT ROTHER DC HAS NOT UNDERTAKEN A COMPREHENSIVE SURVEY OF 'BRIDLEWAYS' IN THE ROTHER AREA, AS CATSFIELD FOR ONE HAS FEW BRIDLEWAYS.
PROPOSED SITES SHOULD BE CONSIDERED ON THEIR INDIVIDUAL MERITS.
Q.67 AGREE: IN THE ABSENCE OF ANY OTHER SITES PARISH COUNCIL CONSIDER THE 'PREFERRED' SITES ACCEPTABLE
Q.68 DISAGREE IN PART: THE DENSITY OF HOUSING FOR THIS SITE IS TOO HIGH. PARISH COUNCIL IS CONCERNED WITH THE IMPACT OF THE ADDITIONAL VOLUME OF CARS AND PROVISION OF CAR PARKING SPACES. THE VILLAGE LACKS THE INFRASTRUCTURE TO ACCOMMODATE THIS LEVEL OF EXTRA HOUSING I.E. THE PRIMARY SCHOOL IS OVERSUBSCRIBED. ACCESS TO THE SITE IS NOT GOOD AND ON A ROAD (THE GREEN) WHICH HAS EXISTING PROBLEMS WITH SPEEDING AND DANGEROUS OVERTAKING. LIGHTING NEEDS TO BE TAKEN INTO CAREFUL CONSIDERATION TO PREVENT URBANISATION OF THE VILLAGE.

AFFORDABLE HOUSING: PRIORITY SHOULD BE GIVEN TO VILLAGE RESIDENTS AND THEIR FAMILIES.
Q.69 THOUGH PLANNING PERMISSION HAS BEEN GRANTED, PRIORITY SHOULD BE GIVEN TO VILLAGE RESIDENTS AND THEIR FAMILIES WHEN CONSIDERING AFFORDABLE HOUSING.
Q.70 AGREE AS PROPOSED.

ROTHER AND HASTINGS PLAYING PITCH STRATEGY
PARISH COUNCIL HAS REVIEWED THE COMMENTS AND RECOMMENDATIONS IN RELATION TO THE CATSFIELD RECREATION GROUND AND HAS THE FOLLOWING COMMENTS:
THE PLAYING FIELD IS SUITABLY ADEQUATE AND WELL MAINTAINED FOR ITS TYPE OF USE - TRADITIONAL VILLAGE SPORTS. PARISH COUNCIL IS VERY DISAPPOINTED THAT THE REPORT HAS BEEN PRODUCED ON A SEVERE LACK OF UNDERSTANDING OF THE USE OF THE PLAYING FIELD. A LOT OF TIME AND MONEY IS SPENT ON MAINTAINING THE GROUND. IT IS NOT TOO LONG AGO A NEW PAVILION WAS BUILT, WHICH HAD TO MEET FOOTBALL LEAGUE STANDARDS.
THE PLAY AREA HAS ALSO ONLY RECENTLY BEEN COMPLETELY REPLACED WITH NEW EQUIPMENT. THE FACT THAT THE PHOTOGRAPH BEING USED TO PROMOTE THIS POLICY IS OF THE CATSFIELD PLAYING FIELD AND PAVILION MUST GIVE SOME CREDIBILITY TO THE FACILITIES. FOR A SMALL SERVICE VILLAGE CATSFIELD HAS GOOD RECREATIONAL / SPORTS FACILITIES. THE PLAYING FIELD HAS RESTRICTIONS IN THAT IT IS ALSO BISECTED BY A PUBLIC FOOTPATH. ROTHER DC DO NOT SEEM TO UNDERSTAND THAT THE CATSFIELD RECREATION
GROUND IS NOT JUST A PLAYING / SPORTS FIELD - IT IS A RECREATION GROUND OPEN TO THE PUBLIC AS WELL.

Development and Site Allocation Local Plan
"DaSA" Consultation and General Observations

As indicated above I write with reference to the Local Plan Consultation and because the forms supplied by Rother do not cover the points set out below, I summarise my views like this:-

1. A proper Bexhill By-Pass is required before further large scale development is given planning permission locally,

2. Bexhill companies, firms and individuals are effectively excluded from involvement with large scale development in the town, to the detriment of everyone who lives here.

Taking these two points in turn:-

1. DaSA Appendix A refers to residential targets for Bexhill for the period 2011-2018. The overall target is 3,100 dwellings of which 2056 have been agreed or approved. Rother appears to have received a demand from Central Government to construct or permit the construction of a specific number of dwellings in our local authority district and in particular the town of Bexhill. This demand, at least in part, seems to be a cure for the housing crisis resulting from uncontrolled immigration over the last 20 years. The relationship between National and Local Government should be based on mutual support and respect of each other's role in society. If Westminster withholds support and at the same time demands action by Local Authorities to rectify Westminster's failures it will be completely unacceptable to established residents throughout the UK. Locally the major road system is completely inadequate. A great deal of preliminary work was carried out with a view to constructing a proper Bexhill and Hastings by-pass but the proposals were suddenly cancelled twenty years ago.

The major coastal road through Bexhill and Hastings, the A259, was inadequate in the 1990s. As we approach the 2020s the local arterial road system is so clogged that the suggestion in DaSA for Site BX116 is for the new road link to the proposed 160 dwellings is to avoid the A259. Instead of that obvious route, the access recommended is along the wholly inadequate alternative of Spindlewood and Meads Road into the middle of Little Common.

Rother must respond to Westminster's demand for more housing in Bexhill by reminding the Government that it has failed to provide a by-pass for the town and that until that is done there can be no further large scale development locally.

2. Whenever a reasonably sized development site becomes available in Bexhill, it seems that the developers and builders are from outside the area. This operates to the great disadvantage of local residents and in particular local businesses. A developer from elsewhere has no lasting interest in Bexhill, beyond the desire to ensure that the exercise produces as much profit as possible. This inevitably results in high density standardised housing with rooms of an inadequate size.

Local architects, builders, electricians, plumbers and so on tend not to be involved with new residential sites. Nor can people commission the construction of their own homes. If, for example, the site identified in DaSA BX 116 is considered suitable for development, at some time in the future, it would be best if the land is earmarked for division into reasonably sized plots to be sold individually. In that way Bexhill's architects, builders and tradesmen will be gainfully employed to the advantage of the town, and all who live here.

Taylor Wimpey South East (TWSE) has land interests at "Land at Blackfriars, Battle" which is allocated for mixed use development under Saved Local Plan Policy BT2.

The DaSa reviews site allocations from the existing Local Plan and proposes new site allocations. However, the DaSa only reviews existing Local Plan site allocations/proposes new site allocations within settlements that are not subject to a Neighbourhood Plan Development Order. In these areas, it is assumed that sites will be allocated within the Neighbourhood Plans themselves.

Chapter 5 of the DaSa states:

given the need to be able to demonstrate that the DaSA and neighbourhood plans will together provide sufficient sites to meet the Core Strategy's requirements for housing and employment land, all the plans need to be in place at approximately the same time. Indeed, in view of the current pressure on housing land supply, it is vital for all communities to have plans in place as soon as practicable.

The Council will continue to support the efficient preparation of neighbourhood plans and encourage the early development of sustainable and deliverable sites in order to help contribute to both local and the District-wide housing land supply. It is not clear how RDC intends to ensure that Neighbourhood Plans are adopted at approximately the same time as the DaSa is adopted.

Whilst we acknowledge that Neighbourhood Plans will play an important role in allocating housing sites for development, and their purpose is to allow the local community to play an active role in allocating sites for development, we are concerned that, should Neighbourhood Plans not be approved prior to or alongside
the adoption of the DaSa, a "policy vacuum" will occur.

The absence of any housing allocation policies for settlements such Battle, which is expected to deliver a significant proportion of RDC's housing requirement (475-500 dwellings), could undermine RDC's ability to meet its Core Strategy housing requirement, and maintain a 5-year housing land supply, in accordance with the National Planning Policy Framework (NPPF). In this regard, it is noted that Battle Town Council does not appear to have progressed its Neighbourhood Plan since the initial Survey and Call For Sites in February 2016.

Further consideration needs to be given to the relationship between the DaSa and Neighbourhood Plans, to ensure effective policies are in place to support the delivery of housing within the plan period.
 

Soils

A policy is needed in this section, regarding the need to protect the soils of 'best and Most Versatile' land.