Policy BEX1: Land at Levetts Wood and Oaktree Farm, Sidley, Bexhill

We object to the land between NBAR and the Combe Valley Countryside Park, highlighted on the plan attached, being included in the strategic gap, as highlighted in our representations in relation to development boundaries and the BEX1 allocation. This land is in our opinion well suited to employment use development.

The area is visually self-contained and free of both ecological and topographical constraints, being bounded on three sides by landscape features including a strong ridge line and ancient woodland, which would conceal development from view in both Bexhill and Hastings/St. Leonards. It would effectively limit development further into the proposed strategic gap beyond this point owing to the statutory protection offered to ancient woodlands.

We would also query the necessity of a policy of this nature in this location given that the gap between Bexhill and Hastings/St. Leonards is more than 3km and already largely protected by the Combe Haven SSSI covering 2.6km of this gap. We do not feel that there is sufficient justification to exclude this land from the development allocations given the land's potential as one of the best serviced employment use development sites in East Sussex.

It should be remembered that the urban extension to the north and the north east of Bexhill is so located because the settlement is constructed to the north by the High Weald AONB and to the west by the Pevensey Levels SAC. Given the above it seems unnecessary to constrain development in this area which is by virtue or natural constraints incapable of joining with the Hastings/ St. Leonards settlement.

We feel that inclusion of the land identified in the first paragraph in the local plan as part of a larger employment allocation designed to benefit fully from significant public infrastructure investment and absence of any identifiable development constraints on the site would be more in keeping with the principle of sustainable development and the general development principles set out in Saved Policy GD1 of the 2006 Rother District Local Plan, and would welcome a decision by the council to allocate the land for these purposes.

Elements of this policy are considered to be unsound as they seek to impose restrictions beyond those already determined at an outline planning permission stage and place unrealistic obligations on the objector as the developer of the site.
We would suggest the removal of all obligations to work specifically with Southern Water to deliver sewerage infrastructure to the site prior to occupation, as requiring the delivery of infrastructure through an organisation that have proven to be slow and reluctant to positively engage in the delivery of infrastructure would unduly slow
the delivery of development. This policy would also unfairly advantage Southern Water over providers of alternative sewerage infrastructure provision options such as on-site treatment plants, or the use of inset providers to deliver development on a more viable timescale. We consider there to be no planning justification for
requiring developers to rely on this provider who has failed to deliver infrastructure prior to occupation of developments.
We do not consider the policies current wording to be reflective of our current planning permission (ref:RR/2017/2181/P) for the land contained within the allocation. We consider it to be unjustified and inconsistent with national planning policy for the local planning authority to adopt planning policy inconsistent with existing planning consents. We consider the main issues with the present wording to be;
1. The increase in landscape buffers and exclusion of parts of the consented outline planning permission from
the BEX1 allocation, in particular the exclusion of the parts of the permission to the north of NEAR, resulting in a
reduction in the area allocated for employment uses within the plan. We consider this approach fundamentally
unsound as noted in paragraph 9.8 of the proposed DaSA submission. Significant progress in bringing forward
business land has been made since the construction of the link road and we cannot see any justification for
reducing the size of employment land allocations which benefit from the £130m link road investment.
2. The policy states that development will be predominately light manufacturing and offices, falling within Class B1, this contrasts with the planning permission with was granted to include B2 manufacturing uses, which has also been considered an appropriate use for the site subject to suitable screening in local planning policy dating back to 2006, including the North East Bexhill Supplementary Planning Document 2009. We suggest that the allocation is amended to incorporate B2 manufacturing uses to reflect the existing consent as the changes do not appear to be justified. It should be noted that this is one of the few B" manufacturing Locations within the entire Rother District.
3. We also note that the policy states that existing landscape boundaries should be retained and reinforced, including along the boundary with NBAR, as indicated on the Detail Map, we object to this policy amendment as it is not consistent with the outline planning permission and would lead to further reductions in the already finite
levels of business space available, despite a proposed increase in overall settlement size through additional housing allocations.
As such we would suggest that the allocation policy is amended to fully reflect the existing planning permissions and that additional employment land is allocated to meet the employment needs of residents living in the proposed additional housing therefore delivering, a more balanced mixture of development within the urban
extension.

The objector believes that the plan identifying the development boundary tight to the northern side of NBAR is fundamentally unsound as is not consistent with existing saved general development plan policies, in particular criteria (vi) of policy GD1 , principle (v) of Policy DS1 from the saved policies of the 2006 Rather District Local Plan, Policy OSS2 of the Rather Local Plan Core Strategy 2014 and the existing planning permissions including outline planning permission (reference RR/2017/2181/P) covering the employment development of the existing BX3 allocation. In respect of policies GD1 and OSS2 the development boundary does not respect the topography of the sites surrounding the road and would result in the creation of a number of fields that are constrained by the road, topography and natural landscape features that are too small for commercial agricultural uses, failing to respect the objectives of this policies which require development to respect topographies and state that development boundaries will be reviewed in the DaSA following physical features, unless this may suggest a potential for development that is inappropriate.
In respect of policy DS1, principle (v) is that best use is made of existing infrastructure, including transport, community facilities, mains drainage and all other necessary service media given that the proposed development boundary would limit the utilisation NEAR, halving the volume of development that could be enabled by one of the largest public infrastructure projects in the area. It should be noted that NBAR has been constructed as the primary service corridor for the urban extension with strategic mains supplies and ducts designed to serve development on both sides of the road, installed during the construction of the road and that this corridor remains the natural gravity drainage corridor for Southern Water's foul drainage proposals. The proposed development boundary is directly in conflict with this policy by restricting the use of this infrastructure. Given the existing planning permissions, we propose that the development boundary is redrawn to the north of
NEAR so as to follow natural landscape features following the significant ancient woodland lined ridge that tops the valley through which the road has been routed as indicated on the plan attached.
The land to the north of NBAR identified on this plan is not subject to any Green Belt or Area of Outstanding Natural Beauty designations and is classified as primarily being within Flood Zone 1 and was predominately allocated as part of the BX3 employment allocation in the North East Bexhill Supplementary Planning Document 2009. It should however be noted that this plan also utilised the road as a development boundary on an alignment which was routed through the established ancient woodland on the ridge to the north of the of the present alignment.
To accord with national planning policy and avoid the ancient woodlands the developer amended the routing of NBAR to the south. Reducing the volume of land contained within the area between the road and the existing settlement considerably.
Given that parts of this land had previously been identified for development and there are no apparent development constraints, this land should be identified for development for a mixture of employment, leisure and sports facilities. Potential uses include the development of a mixed-use facility to accommodate several units suitable for small businesses to compliment larger employment uses on the BEX1 allocation and recreational facilities.

ROTHER DEVELOPMENT AND SITE ALLOCATIONS LOCAL PLAN - PROPOSED SUBMISSION
OCTOBER 2018

The Sussex Wildlife Trust (SWT) recognises the importance of a plan led system as opposed to a developer led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments are used constructively to make certain that this proposed submission plan properly plans for the natural capital needed within the district and ensures that any development is truly sustainable.

Where SWT is proposing a change to policy or the supporting text, recommended additions are highlighted in bold and deletions are struck through.

Amended text document attached:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31198

It is not clear when the Development and Site Allocations Local Plan (DaSA) may be submitted for examination, in terms of the transition period for the revised National Planning Policy Framework (2018NPPF). Therefore SWT will be assessing the compliance of the DaSA against both the 2018NPPF and the previous 2012NPPF.

PART A - DEVELOPMENT POLICIES

Policy DRM1: Water Efficiency

SWT strongly support this policy and the requirement for the higher standard of water efficiency.

Policy DCO2: Equestrian Development

We strongly support this policy and in particular, the inclusion of 'biodiversity' within part (iv).

Policy DHG7: External Residential Areas

SWT support the need for this policy but would like to see it strengthened to ensure a holistic approach when considering private external space and the district's Green Infrastructure network. As it stands we do not believe it is consistent with national policy in terms of the requirement for plans and policies to promote the preservation, restoration and re-creation of ecological networks (2012NPPF paragraph 117,2018NPPF paragraph 174).

Additionally, policy EN5 of the Core Strategy states that 'Biodiversity, geodiversity and green space will be protected and enhanced, but multi-agency working where appropriate, to: Maintain and develop a district-wide network of green infrastructure...' When considered early in the design stage of a development, gardens can be made to play a key component in a cohesive green infrastructure network. We therefore recommend that part (i) of the policy is amended as follows:

'...Appropriate and proportionate levels of private usable external space will be expected. For dwellings, private rear garden spaces of at least 10 metres in length will normally be required. Consideration should be given to orientation and permeability to ensure external space contributes positively to the district's green infrastructure network. In relation to flat developments and complexes, an appropriate level of useable communal amenity space should be provided...'

Policy DHG11: Boundary Treatments

We support the inclusion of this policy, but feel that it needs to better reflect the requirement in paragraphs 109 of the 2012NPPF and 170 of the 2018NPPF for planning policies and decisions to contribute to the establishment of coherent ecological networks. Connectivity and permeability are key components of a coherent ecological network. We ask that the following amendment is made to criterion

(ii) to ensure that permeability is maintained and where needed increased:

'(ii) the proposed boundary treatment, by virtue of design, height and materials or species, is consistent with the character of the locality and ensures permeability for biodiversity'

Policy DEC2: Holiday Sites

SWT strongly support the inclusion of criteria (ii) however it needs to be amended as below to ensure that it is in line with the requirement in the NPPF to create net gains to biodiversity and promote the conservation and enhancement of priority habitats and species (paragraph 109, 2012NPPF and paragraphs 170 and 174, 2018NPPF).

'(ii) conserve or and enhance sensitive habitats and species;'

Policy DEN2: The High Weald Area of Outstanding Natural Beauty (AONB)
We support the inclusion of this policy, however SWT is concerned about the use of 'scenic beauty' rather than 'natural beauty'. Paragraph 6.32 of the plan correctly states that the term 'natural beauty' includes conservation of flora, fauna and geological and physiographical features, along with for the High Weald, priority habitats such as ghyll woodland. We are concerned that the term 'scenic beauty' does not encompass the biodiversity element in such clear terms and suggest that the policy is amended:

'All development within of affecting the setting of the High Weald AONB shall conserve and seek to enhance its landscape and scenic natural beauty, having particular regard to the impacts on in character components, as set out in the High Weald AONB Management Plan...'

Policy DEN3: Strategic Gaps

We strongly support the inclusion of a strategic gaps policy, however are disappointed that there is no acknowledgement within the policy or supporting text of the roles that these gaps play in terms of natural capital provision and green infrastructure (GI).

RDC's Green Infrastructure Background Paper (August 2011) demonstrates the numerous opportunities for GI enhancement across the district and many of the focus areas marry well with the strategic gaps protected in policy DEN3. It therefore seems inconsistent to disregard the contribution these areas do and could make to GI and natural capital, in particular in relation to the requirements of Core Strategy Policy EN5(i).

The 2018NPPF states in paragraph 171 that 'plans should: ...take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries'. Similarly in paragraph 174 that 'To protect and enhance biodiversity and geodiversity, plans should: promote the conservation, restoration and enhancement of priority habitats, ecological networks...' (paragraphs 114 and 117 of the 2012NPPF). The
Strategic Gaps could clearly contribute to these policy requirements and hence we encourage RDC to assess the value of these gaps in terms of natural capital assets and their place within the district's GI network.

In order to be both effective and consistent with National Policy, we recommend the following additions are made to the policy:

'...Within the Gaps, development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must:

(i) Be unobtrusive and not detract from the openness of the area

(ii) Conserve and enhance the benefits and services derived from the area's Natural Capital

(iii) Conserve and enhance the area as part of a cohesive green infrastructure network...'

SWT is also not clear what 'exceptional circumstances' constitutes in policy DEN3 and therefore question the policies effectiveness. This should be clarified in the supporting text. Alternatively the policy could be made more prescriptive including criteria on how exceptional circumstances might be judged.

Policy DEN4: Biodiversity and Green Space

We strongly support the inclusion of this policy and in particular the recognition of irreplaceable habitats which has been added since the regulation 18 version of the DaSA. However SWT does not feel that DEN4 is currently consistent with national policy and in particular paragraphs 170 and 171 of the 2018NPPF.

We note that paragraph 6.39 refers to the need for development to produce net gains to biodiversity, but this is not sufficiently reflected in policy DEN4 or Core Strategy policy EN5. The 2018NPPF is direct in its requirement for planning policies and decisions to ensure measurable net gains to biodiversity are delivered in line with the Government's 25 Year Plan for the Environment. As such, the policy wording needs to be strengthened.

SWT is also concerned about the effectiveness of paragraph 6.43 of the supporting text. Whilst we fully support the need for up to date ecological information to inform planning decisions, the text restricts this to major development, designated sites, priority habitat and protected species. The 2012NPPF is clear in paragraph 165 that all planning decisions should be based on up to date information about the natural environment. Additionally, in SWT's experience supporting text does not carry the same weight as policy in planning decisions and is instead more often used to explain the reasoning of the policy wording. We
therefore request that the requirement in paragraph 6.43 is also included in the policy.
Part (ii) should not include the caveat of 'seek to', especially in relation to international sites. This is not legally sound given the strong requirements of the Habitat Regulations. It is also contrary to the requirement in paragraph 174 of the 2018NPPF (117 of the 2012NPPF) for plans to promote the conservation, restoration and enhancement of ecological networks of which designated sites of biodiversity value make a key component.

Given the abundance of ancient woodland within the district, SWT feel that it is remiss of RDC not to include specific policy wording on this irreplaceable habitat. We acknowledge that ancient woodland is briefly referenced in Core Policy EN5, but would like to see it included in DEN5. In particular the requirement for a buffer of at least 15 metres between any development and ancient woodland as per Natural England's standing advice. We note that this requirement is included in the policy wording for some of the allocations in the plan - BEX9, BRO1 and NOR2. Therefore for consistency, this requirement should be included in this policy so that it can be applied to windfall applications which will not have site
specific policy criteria in the DaSA.
Part (iv) of the policy has a requirement for larger developments of more than 2 hectares or 50 dwellings to produce a Green Infrastructure masterplan. Looking at the allocation section of the DaSA, SWT is concerned that very few meet this requirement. We therefore recommend that the criteria is extended to require smaller developments to deliver towards Rother's Green Infrastructure network. This is in line respectively with paragraphs 114 and 170 of the 2012 and 2018NPPFs.

SWT is concerned that part (v) of the policy is not clear enough in terms of what applicants need to do in relation to the SARMS. The SARMS has been created to ensure that there is no significant adverse effect on the Dungeness Complex SPA from increased recreational pressure. The HRA of the Pre-Submission DaSA states in paragraph 5.10 that 'the implementation of the Strategic Access and Recreation Management Strategy (SARMS) for the Dungeness Complex is fundamental to ensuring that the recreation pressures are
effectively managed to maintain the integrity of the Natura 2000 sites.' Therefore it seems that in order to be legally compliant, all developments which will result in an increase in residents within the SARMS area must contribute to the delivery of the SARMS. SWT does not believe that this will be the outcome of policy DEN4 as it is currently written and therefore do not believe it to be effective. We recommend that the wording of part (v) is strengthened and that additional supporting text is included to ensure applicants are clear as to what is required of them.

As noted above, SWT request the following amendments to policy DEN4:

'Development proposals should be informed by up to date ecological information and support the conservation of biodiversity and multi-functional green spaces in accordance with Core Strategy Policy EN5 and the following criteria, as applicable:

(i) proposals where the principal objective is to conserve or enhance biodiversity or geodiversity will be supported in principle;

(ii) development proposals should seek to conserve and enhance the biodiversity value of
international, national, regional and local designated sites of biodiversity and geological value; irreplaceable habitats (including ancient woodland and ancient or veteran trees); and Priority Habitats and Species, both within and outside designated sites. Depending on the status of habitats and species concerned, this may require locating development on alternative sites that would cause less or no harm, incorporating measures for prevention, mitigation and (in the last resort) compensation. For ancient woodland, a buffer of at least 15 metres from the development will be required.

(iii) in addition to (ii) above, all developments should retain and enhance provide net gains for biodiversity in a manner appropriate to the local context, having particular regard to locally present Priority Habitats and Species, defined 'Biodiversity Opportunity Areas', ecological networks, and further opportunities identified in the Council's Green Infrastructure Study Addendum.

(iv) larger developments of more than 2 hectares or 50 dwellings (whichever is the smaller) should produce a Green Infrastructure masterplan as part of their proposals. All development should conserve and enhance Rother's green infrastructure network.

(v) all developments within the strategy area of the Dungeness Complex Sustainable Access and Recreation Management Strategy should have regard to the measures identified in that Strategy and will be required to contribute to its implementation, this may be a financial contribution at the discretion of the Local Planning Authority.'

Policy DEN5: Sustainable Drainage
SWT strongly support the inclusion of this policy, however we suggest it is strengthened to make sure it is robust enough to ensure no significant effect on the Pevensey Levels SAC in terms of hydrology. In particular, whilst criterion (v) is welcome, it does not go far enough to provide certainty that the SuDS features will be maintained in perpetuity. Similarly criterion
(vi) should include specific reference to source control features. We recommend that the policy it is amended as follows:

(v) 'applicants should demonstrate that arrangements are in pace for on-going maintenance of SuDS over the lifetime of the development. For schemes within the Pevensey Levels Hydrological Catchment Area, a specialist management company should be in place before the first occupation on sites. Step-in rights for the Local Authority may be required to ensure the SuDS continue to be managed in the event of failings of the management company in place.'

(vi) within the Pevensey Levels Hydrological Catchment Area, unless demonstrably inappropriate, SuDS designs should incorporate at least two stages of suitable treatment, one of which should be a source control feature unless demonstrably inappropriate; and...'

Policy DEN7: Environmental Pollution

SWT strongly support the addition of biodiversity into this policy since the regulation 18 consultation version of the DaSA.

PART B - SITE ALLOCATION POLICIES
General Comments

As stated in our regulation 18 consultation response, SWT are encouraged to see that the site selection criteria included consideration of ecological constraints and opportunities and that designated sites/sites of high biodiversity value are excluded from allocation. However, again we note that this assessment is based on desktop information rather than on the ground ecological information which is disappointing.

We note that the requirement for ecological surveys has been removed from policies IDE1 and MAR1 since the regulation 18 consultation. However this now means that there is no policy wording in the DaSA that requires decisions to be based on up to date information on the natural environment as per paragraph 165 of the 2012NPPF. If our amendment regarding up to date ecological information is not accepted for policy DEN4, then we request that all site allocation policies include the following wording:

'Proposals should be informed by up-to-date ecological information'

SWT is concerned that the DaSA is inconsistent in its approach to the protection of irreplaceable habitats and in particular ancient woodland adjacent to allocations. Seven allocations include land adjacent to ancient woodland, however only three of these - BEX9, BRO1 and NOR2 - include a requirement for at least a 15 metre buffer between the ancient woodland and the development boundary as per Natural England's standing advice. The detailed maps for allocations BEX1, BEX2, BEX3a and BEX3b include an indicative ancient woodland buffer, but the requirement for this is not specified within the associated policy wording. This is not acceptable. The policy for any allocation that includes or is adjacent to ancient woodland should include a requirement of a buffer of at least 15 metres. We recommend that similar wording to that included in BRO1 is used:

'provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), between the edge of development
and the ancient woodland'

Policy BEX1: Land at Levetts Wood and Oaktree Farm, Sidley, Bexhill

SWT supports a plan-led planning process and acknowledges that site allocation BEX1 is included in the adopted North East Bexhill SPD. However we question whether the district's natural capital can absorb the level of development proposed around the edges of Bexhill. In particular sites BEX1, BEX2, BEX3a, BEX3b and BEX3c should be considered holistically to ensure that any development takes account of the ecosystem services currently being provided by these areas. The cumulative impact of these allocations should also be considered in terms of the green infrastructure enhancements that could be provided. We recommend that a GI strategy that covers all of these allocations is developed.

We support the inclusion of criteria (v) and (vii) however we question why the policy does not specifically require a buffer of at least 15m between the development and the adjacent ancient woodland. This would be consistent with paragraphs 118 and 175 of the 2012 and 2018NPPF, Natural England's standing advice and other similar site allocation policies within the DaSA such as BEX9. Suitable wording should be added to the policy:

'provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), between the edge of development and the ancient woodland'

Policy BEX2: Land at Preston Hall Farm, Sidley

We support the inclusion of criteria (iv) and (viii) however we question why the policy does not specifically require a buffer of at least 15m between the development and the adjacent ancient woodland. This would be consistent with paragraphs 118 and 175 of the 2012 and 2018NPPF, Natural England's standing advice and other similar site allocation policies within the DaSA such as BEX9. Suitable wording should be added to the policy:

'provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), between the edge of development and the ancient woodland'

Policy BEX3: Land at North Bexhill - Infrastructure

Whilst SWT remains concerned about the level of development proposed for Bexhill, we do support the inclusion of an overarching policy on infrastructure. We question why this policy does not include allocations BEX1 and BEX2 which are functionally linked with allocations BEX3a, b and c. In particular, the area for housing in the south part of BEX3c appears to be directly adjacent to BEX2. The NPPF is clear that Local Planning Authorities should take a strategic approach to the creation of ecological networks and green infrastructure and as such this policy should apply more widely.

Policy BEX3a: Kiteye Farm and adjoining land

We support the inclusion of criterion (vii) however we question why the policy does not specifically require a buffer of at least 15m between the development and any adjacent ancient woodland. This would be consistent with paragraphs 118 and 175 of the 2012 and 2018NPPF, Natural England's standing advice and other similar site allocation policies within the DaSA such as BEX9. Suitable wording should be added to the policy:
'provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), between the edge of development and the ancient woodland'

Policy BEX3b: Land west of Watermill Lane
SWT questions why the policy does not specifically require a buffer of at least 15m between the development and any adjacent ancient woodland. This would be consistent with paragraphs 118 and 175 of the 2012 and 2018NPPF, Natural England's standing advice and other similar site allocation policies within the DaSA such as BEX9. Suitable wording should be added to the policy:

'provision is made for the retention and future management of a buffer zone of semi-natural habitat, at least 15 metres wide (which does not include residential gardens), between the edge of development and the ancient woodland'

Policy HAS1: Combe Valley Countryside Park

SWT strongly support the inclusion of this policy and in particular the requirements in relation to the SSSI and LWS. However as stated previously, the 2018NPPF is much clearer in the necessity for development to provide net gains to biodiversity (paragraph 170). Therefore in order to be consistent with national policy, the caveat of 'where practicable' should be removed from criterion (ii) as follows:

(ii) provide for the proper conservation and, where appropriate, management of the Site of Special Scientific Interest and the Local Wildlife Site within it and creates net gains for biodiversity within the Park, where practicable; and...'

Policy HAS4: Rock Lane Urban Fringe Management Area

We strongly support the inclusion of this policy and in particular the strong development boundary and the support of improvements to biodiversity interest. SWT is concerned by the level of urban sprawl that has occurred around Hastings and would object to anything further, this policy is therefore welcome.

Policy BRO1: Land west of the A28, Northiam Road, Broad Oak

SWT strongly supports the requirement in criterion (v) for a buffer of at least 15 metres to protect the adjacent ancient woodland. This is consistent with Natural England's standing advice and respectively paragraphs 118 and 175 of the 2012 and 2018NPPF.

Policy CAM1: Land at the Former Putting Green Site, Old Lydd Road, Camber
We support the inclusion of criteria (vi) and (vii) and the associated supporting text in paragraphs 11.67 and 11.68. However we are concerned that criterion (vii) is not clear enough in regards to what 'contributes towards implementation' actually means and therefore is not effective. We recommend that the wording is strengthened.

We also recommend that Figure 46 includes the location of the SSSI so that applicants have a clearer idea of where the constraints and opportunities lie. Most of the other detailed maps include the location of environmental features such as ancient woodland, so it seems inconsistent for designated areas to be missing.

Policy CAM2: Land at the Central Car Park, Old Lydd Road, Camber
SWT supports the inclusion of criteria (v) and (vi), this is an improvement from the regulation 18 version of the policy. However again we are concerned that part (vi) is not clearer enough. As per our comments for policy CAM1 we also recommend that Figure 47 includes the locations of the various environmental designations in the vicinity of the allocation.

Policy FAC1: Land at the Former Market Garden, Lower Waites Lane, Fairlight Cove

SWT supports the inclusion of criteria (iv) within this new allocation policy, however we are concerned that the contribution this site makes to the area's green infrastructure network has not been fully considered.

Policy NOR2: Land South of The Paddock/Goddens Gill, Northiam

We strongly support the inclusion of part (iii) within this new allocation policy and in particular the specification of the buffer being at least 15 metres wide in line with Natural England's standing advice.

Policy RHA1: Land at Stoneworks Cottages, Rye Harbour

It is not clear to SWT why policy RHA1 and the associated supporting text does not contain any reference to the SARMS. Given the proximity of the allocation to the SPA and the specific policy wording in CAM1 and CAM2, this seems very inconsistent. A seventh criterion should be added which requires a contribution to the SARMS as demonstrated in the allocation policies for Camber.

Policy WES4: Land between Moor Lane and the A28, Westfield

SWT note that since the regulation 18 consultation the allocation of this site has changed from open space to allotments. SWT do not object to this change, but we do question why the requirement for ecological improvements to be implemented in accordance with the Hasting Fringes Biodiversity Opportunity Area and the Rother Green Infrastructure Study has been removed. Allotments can contribute to both GI and ecological networks and as such we request that the criteria is reinstated.

We hope our recommendations are adopted to ensure that the policies within the DaSA are as robust and effective as possible. SWT would be happy to discuss any of the above points with RDC. We do wish to attend the Examination in Public to ensure our views are given due consideration.