Comment

Representation ID: 18870

Received: 15/02/2007

Respondent: Forestry Commission

Generally the themes seem to be comprehensive with the key issues well defined.

In the Profile 'Environment and Transport section' we suggest that you include the high proportion of woodland cover (as you note in 8.11 ), a large proportion of which is Ancient Woodland. The district has 7386.44ha of ancient woodland, which is the 5th highest amount of ancient woodland in any local authority in South East England. Ancient Woodlands, which are features of irreplaceable heritage and landscape value (the detail may be better placed in 8.11 ).

Comment

Representation ID: 18890

Received: 15/02/2007

Respondent: Persimmon Homes South East

Agent: Bell Cornwell

We consider that the themes do not properly reflect the need to provide in a timely manner, the strategic housing requirements. Our view is that there is a probability that the overall housing numbers for the Rother District will rise. In the meantime we consider that it will be unsound to proceed on the basis that the current Structure Plan figures will provide the basis for the Core Strategy. The Preferred Options stage of the Core Strategy should therefore either be delayed until the regional context becomes clear or it should be robust enough to possibly accommodate substantially higher levels of housing.

Comment

Representation ID: 18897

Received: 15/02/2007

Respondent: Wealden District Council

The common factors across the two Districts are mainly the High Weald AONB, The Pevensey Levels RAMSAR site and the catchment areas of the River Rother and Wallers Haven.

Comment

Representation ID: 18903

Received: 16/02/2007

Respondent: Councillor David Vereker

I submit you should be more realistic with the issues. It is not realistic to think the Council can provide all things to all people all the time. Whether you are considering Housing,
Prosperity, Transport the Environment or Infrastructure, emphasis must be placed on the
Have Nots, not the Haves. This section is too all embracing and assumes the Council can control things outside its powers.

Profile -this is largely facts and figures about which you know more than I; I have only been able to skim through the document.

In respect of the profile, I would not spend more time and effort than necessary on forecasting the future; there may well be scientific advances making money spent now, money wasted ie. wind turbines.

Comment

Representation ID: 18921

Received: 19/02/2007

Respondent: Rother Voluntary Action

Theme 1:It is not considered that either affordable housing or community support networks is the key issue. What is meant by balanced is unclear. It is not focused or well structured.
Theme 2: Prosperity cannot be guaranteed and is not achievable but you can create a range of opportunities, with an enabling environment.
Theme 4: Quality is not a theme or a key issue, and is the wrong one for the environment.
Theme 5: Community Infrastructure and Facilities is not a satisfactory theme, and appears a 'catch all’.

Comment

Representation ID: 18922

Received: 19/02/2007

Respondent: Rother Voluntary Action

The Key Issues and Themes should be rephrased as follows:
. Environmental Sustainability ...quot; Ensure that the urban and green environments are ecologically, socially and economically sustainable
. Social Sustainability ...quot; Ensure that we have peaceful and prosperous communities
. Economic Sustainability...quot;Enlarge and strengthen the economic base of the District
. Relevant and Sufficient Support Infrastructure ...quot; Ensure that the necessary infrastructure to support sustainable communities is in place. Key issues include education, health, water and energy
ª Transport and Accessibility ...quot; address the need for people to move around using alternatives to private cars.

Comment

Representation ID: 18923

Received: 19/02/2007

Respondent: Rother Voluntary Action

What is missing from the Rother in Profile is how Rother fits with Hastings, the whole of East Sussex and the South East in terms of its interconnectedness. 'Drivers for change’ may change over time. Drivers missing are those relating to energy, waste and recycling, social cohesion, household size, community and skills development. This section should be strengthened.

Comment

Representation ID: 18928

Received: 19/02/2007

Respondent: Rother Voluntary Action

An emphasis on quality throughout. It is agreed that short-term thinking clearly has been proved to have major long term disadvantages and costs. Quality will bring further quality and should be a central principle of the Core Strategy. By quality we do not mean preservation of the status-quo.

Comment

Representation ID: 18948

Received: 19/02/2007

Respondent: Rother Voluntary Action

Key issues today are transport, environmental issues, energy generation, health and the way communities relate to each other. They are also the centralisation of services, empowering communities, freedom of information and the explosion of information technology.

I believe the tone and structure of the core strategy misses how these current issues are converging to shape the look and feel of communities. Renewable and cheaper energy, healthier lifestyles and exercise, informed choice, devolved political power, environmental protection are dominant themes and have become as important as the traditional emphasis on housing, education and job creation.

I do not believe that the 5 themes of the core strategy reflect this strongly enough.

Comment

Representation ID: 18949

Received: 19/02/2007

Respondent: Rother Voluntary Action

The policy context is perhaps the weakest section of the document.

The section has not referenced the two Area Investment Framework strategies (East Sussex Economic Partnership and the Hastings and Bexhill Economic Alliance ).

What is not evidenced in this section is an analysis of the policy framework or conclusions as to what the current and future drivers and constraints are. This is perhaps the biggest omission in the document in that it is necessary to understand these priorities in order to understand how Rother fits into sub regional strategies.

It makes sense to frame the Rother LDF in a way that fits with these strategies. From the document it is not clear that this is being done.

Comment

Representation ID: 18950

Received: 22/02/2007

Respondent: Southern Water

Need to include efficient and sustainable use of infrastructure and protection of amenity.

Efficient/sustainable use of infrastructure an important component of sustainable development.

Three ways to achieve efficient and sustainable use of water and wastewater infrastructure:-

. co-ordinated whole site approach to large sites
. separation of surface water from foul sewers
. large site sewers to adoptable standards

Propose overarching policy to promote efficient/sustainable use of infrastructure, to be consistent with PPS1.

Need to consider amenity in relation to proposals adjacent wastewater disposal and treatment facilities, in accordance with Appendix A of PPS23. The Core Strategy should have such a policy.

Comment

Representation ID: 18965

Received: 22/02/2007

Respondent: Environment Agency

Key issues are:-

Tidal and fluvial flood risk
Conservation of river, and marine habitats
Water quality
Contamination -specifically the Rye Harbour area
Water resources
Sustainable construction and climate change

Comment

Representation ID: 18969

Received: 22/02/2007

Respondent: Rother Valley Railway

We consider that all the railways in the District should be shown. The map already shows the railway east of Hastings which is not a main line. For all railways to be shown the KESR coming over the District boundary from Tenterden through Northiam to Bodiam should be added, also the planned Robertsbridge/Bodiam RVR link.

Comment

Representation ID: 18973

Received: 23/02/2007

Respondent: Sport England

Need to ensure that existing sites and facilities used for sport and recreation are protected and enhanced. The need to meet the demand for housing and employment often results in pressures placed upon recreation facilities both natural and built.

Concern that theme only refers to protecting high quality environments. Not all sports facilities are high quality but may be the only facilities available. In those circumstances the objective should be to improve the quality of provision as part of any proposal.

Need to secure the provision of new sports and recreation facilities to meet the demands generated by new communities

Comment

Representation ID: 18976

Received: 26/02/2007

Respondent: Natural England

We would agree that Rother has outstanding environmental qualities. The high quality environment of the coastline and the Area of Outstanding Natural Beauty.

The High Weald geology and geomorphology descriptions are welcome but the visual descriptions could be expanded. It is designated as an Area of Outstanding Natural Beauty (AONB) for its rolling hills, small, irregular fields, abundant woods and hedges, scattered farmsteads and sunken lanes.

The historical context for the Pevensey Marshes/Pevensey Levels is welcome but it is considered that the visual landscape and wildlife descriptions could be expanded upon.

Comment

Representation ID: 18978

Received: 26/02/2007

Respondent: Natural England

The Romney Marshes:

We agree with the first 4 paragraphs but suggest expanding upon the Romney Marsh description.

Remove final paragraph from within the Romney Marsh character area as Combe Haven is in the High Weald (but outside the AONB) and Bexhill, Egerton Park Stream and Wallers Haven more in the Pevensey Levels area.

Comment

Representation ID: 18979

Received: 26/02/2007

Respondent: Natural England

Housing:

There is no mention of energy consumption by the existing housing stock. Domestic energy stock makes a considerable contribution to the overall emissions of greenhouse gases. Suggest a description within this section or in the section on climate change.

E. Environment:

We would agree that Rother has a high quality environment, and suggest that the website address of the High Weald AONB Unit is added for information. Also suggest including Natural England's website address for further information on Nature Conservation sites

Alterations to paragraph on International Nature Conservation sites for clarity. Pevensey levels is listed as a Ramsar Site under the Ramsar Convention for Wetlands.

Comment

Representation ID: 18981

Received: 26/02/2007

Respondent: Natural England

Dungeness is a Special Area of Conservation (SAC) under the European Habitats Directive and important for its range of habitats (including the plants and invertebrates of the wetlands, shingle ridges and beaches and a large great crested newt population)

Dungeness to Pett Level is classified as a Special Protection Area (SPA) for its birds (overwintering Bewick Swans, shovellers and breeding little terns(?) and artic terns and Mediterranean gull ) under the European Birds Directive.

These sites form part of a commitment globally and by member states of the European community to protect the habitats of threatened species of wildlife. All the international Nature Areas are also designated SSSIs.

Comment

Representation ID: 18982

Received: 26/02/2007

Respondent: Natural England

Sites of Special Scientific Interest (SSSI):

Sites which have been notified as Sites of Special Scientific Interest (SSSIs) are the country's very best wildlife and geological sites. Notification as a SSSI gives legal protection to the best sites for flora, fauna, geological or physiographic features in England. Natural England now has responsibility for identifying and protecting the SSSIs in England under the Wildlife and Countryside Act 1981 (as amended by the Countryside and Rights of Way Act 2000 and the Natural Environment and Rural Communities 2006 ).

Comment

Representation ID: 18983

Received: 26/02/2007

Respondent: Natural England

Ancient Woodlands:

â€~Rother in Profile’ needs to formally recognise Ancient Woodland through appropriate LDF Policies. South East England has 40% of England’s Ancient Woodlands and Rother District has 7386.44ha of ancient woodland, which is the 5th highest amount of ancient woodland in any local authority in South East England. Ancient Woodlands are features of irreplaceable heritage, wildlife habitat and landscape value. We support Rother District Council in their efforts to produce a revised ancient woodland inventory and encourage an entry into the profile document and policies within the core strategy. See also Forestry Commission comments.

Comment

Representation ID: 18984

Received: 26/02/2007

Respondent: Natural England

Climate Change agenda and use of resources:

We support the sentiments expressed in these paragraphs. Rother District’s inhabitants are proportionally higher emitters of greenhouse gases than other areas in Sussex (see Defra’s figures). A combination of renewable energy including microgeneration projects such as wood biomass, solar and wind turbines or district heating systems), energy efficiency and more use of public transport (eg between Bexhill and Hastings) could lead to reduced emissions. A section on Renewable energy appears in many other strategies in the area.

Comment

Representation ID: 18985

Received: 26/02/2007

Respondent: Natural England

Infrastructure programmes:

The LDF should adopt the standards for the targets for the provision of Green Infrastructure and planned urban extensions to meet Accessible Natural Greenspace Standard (ANGST) â€" raised in the previous Local Plan and the Woodland Trust Woodland Access Standards Recent research (McKernan, 2006) shows that Rother has 5% of households meeting all the ANGST standards, with 85% of households meeting one of the ANGST standards. Green infrastructure should be given equal weight to the other infrastructure required to develop the expanding and new sustainable communities.

Comment

Representation ID: 18986

Received: 26/02/2007

Respondent: Natural England

Green infrastructure has great potential to deliver health and recreational benefits to the local community. New woodland planting in advance of development allows the environment to begin to mature as the rest of the development occurs. Plans for retaining existing trees and woodlands will particularly help people develop a positive attitude to development areas.

Open space should also include semi natural areas with biodiversity gain which are not impacted by sports pitches or play grounds. Increasing evidence strongly suggests that both physical and mental health is improved through contact with nature.

Comment

Representation ID: 18987

Received: 26/02/2007

Respondent: Natural England

Natural England recommends that people living in towns and cities should have:

• an accessible natural green space less than 300 metres (in a straight line) from home
• Statutory Local Nature Reserves provided at a minimum level of one ha per thousand people
• at least one accessible 20 ha site within 2km of home; one accessible site of 100ha within 5km of home; and one accessible site of 500 ha within 10km of home.
Many local authorities have since incorporated these targets into their local plans, these would be example targets for Rother District Council development framework.

Comment

Representation ID: 18988

Received: 26/02/2007

Respondent: Natural England

Natural England recommends that there is 1ha of accessible natural green space per 1000 existing people and this target has since been adopted by the Audit Commission as a Quality of Life indicator and the green space standards have also been included as a benchmark in Government guidance on open space strategies. For new developments there may be an additional requirement for greenspace to ensure designated site protection this assumes the existing greenspace standards already meet the Natural England standards.

Comment

Representation ID: 18989

Received: 26/02/2007

Respondent: Natural England

Support the inclusion of the High Weald AONB Management Plan and suggest that the Sussex Biodiversity Action Plan is also included as the Rother District has such an important range of habitats and species that need safeguarding.