Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 24755
Received: 31/05/2024
Respondent: Sedlescombe Parish Council
The BNG formula is a blunt instrument which fails to measure true BNG increases as it focuses on grass hedgerows and tress and fails to include other more effective true habitat creation. The BNG formula treats concrete with the same score as improved grass which is nonsense. A BNG of 20% can only be supported by a strong needs evidence base otherwise the statutory 10% is the default. It is unlikely in Rother given the high level of trees, grassland and hedges that there will be a need greater than 10%. It would be better to have the 10% gain and then supplement that policy with specific qualitatively better biodiversity improvements (some examples are hibernacula, insect hotels, simple log piles to promote invertebrates)
The desire to include improvements in the natural environment is supported but there is work required in its delivery.
Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25155
Received: 11/07/2024
Respondent: Mrs Emma Weller
The snappy punchline of 'Green to the core' and 'Live well locally' is a bold attempt to show a commitment to protecting rural communities and local ecology but your HELAA land allocation of CAT0001 and potential site CAT0016 in Catsfield fly in the face of these claims/promises.
The proposal of 60 new houses (some proposing to be built on protected AONB land) in this small rural village (doubling the size of the main village), is absolutely shocking and I object strongly to these sites being included for allocation in this plan.
These proposals would not only destroy ancient woodland, biodiversity and protected wildlife habitats, they would also severely impact the lives of local residents with increased pollution and a serious decline in the already insufficient utilties and local infrastructure.
The snappy punchline of 'Green to the core' and 'Live well locally' is a bold attempt to show a commitment to protecting rural communities and local ecology but your HELAA land allocation of CAT0001 and potential site CAT0016 in Catsfield fly in the face of these claims/promises.
The proposal of 60 new houses (some proposing to be built on protected AONB land) in this small rural village (doubling the size of the main village), is absolutely shocking and I object strongly to these sites being included for allocation in this plan.
These proposals would not only destroy ancient woodland, biodiversity and protected wildlife habitats, they would also severely impact the lives of local residents with increased pollution and a serious decline in the already insufficient utilties and local infrastructure.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25260
Received: 12/07/2024
Respondent: Richard Bailey
Agent: DHA Planning
Please see attached representation, existing and proposed sites plans.
Please see attached representation, existing and proposed sites plans.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25290
Received: 12/07/2024
Respondent: Sussex Ornithological Society
Please see attached representation.
Please see attached representation.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25414
Received: 16/07/2024
Respondent: Denbigh Properties Ltd
Agent: DHA Planning
Please see attached:
- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan
Please see attached:
- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25645
Received: 20/07/2024
Respondent: Battle for Trees
See Battle for Trees response attached
See Battle for Trees response attached
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25704
Received: 21/07/2024
Respondent: Sussex Wildlife Trust
SWT supports this policy.
SWT supports this policy.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25986
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The general principles of the policy are in line with The Environment Act 2021. We do note however that the 30-year maintenance requirement is not embedded within the policy, and we believe that it should be as a matter of completeness. We will comment on the minimum requirement below.
The general principles of the policy are in line with The Environment Act 2021. We do note however that the 30-year maintenance requirement is not embedded within the policy, and we believe that it should be as a matter of completeness. We will comment on the minimum requirement below.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26027
Received: 23/07/2024
Respondent: Woodland Trust
Support the policy that BNG should be set at a 20% minimum, delivered onsite as a preference and if offsite, then in line with the LNRS.
Support the policy that BNG should be set at a 20% minimum, delivered onsite as a preference and if offsite, then in line with the LNRS.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26106
Received: 23/07/2024
Respondent: Catesby Estates
If implemented this policy is likely to particularly impact the viability and deliverability of smaller sites where the opportunity to deliver the necessary BNG onsite is more limited resulting in the need to pay for offsite credits.
Consequently, at this stage we are concerned that policy GTC8 is not underpinned by appropriate evidence, including that the approach taken will be viable, and is therefore not “justified” (NPPF, paragraph 35).
We note that under policy GTC8, all qualifying development proposals must deliver at least a 20% measurable biodiversity net gain. Whilst we support the principle of achieving net gain, there is no apparent evidence of the Council understanding the implications of what a 20% uplift would require, nor any justification as to why provision above the mandatory 10% requirement is sought.
In February 2024, Planning Practice Guidance (PPG) was updated to advise plan-makers that they should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration is also needed to be given as to how the policy will be implemented (Paragraph: 006 Reference ID: 74-006-20240214).
1.18 Comparatively, the Draft Plan states that a higher level is justified because “opportunities to deliver this off-site, if necessary, are available locally” and because “the viability of development is unlikely to be unduly impacted in most cases”. The Plan is accompanied by an Environmental Management Background Paper (2024), which refers to a justification for a 20% net gain (dated September 2020) and a viability assessment (dated June 2022) prepared by the Kent Nature Partnership. Neither of these documents relate to Rother District, nor meet the requirements of the PPG.
If implemented this policy is likely to particularly impact the viability and deliverability of smaller sites where the opportunity to deliver the necessary BNG onsite is more limited resulting in the need to pay for offsite credits.
Consequently, at this stage we are concerned that policy GTC8 is not underpinned by appropriate evidence, including that the approach taken will be viable, and is therefore not “justified” (NPPF, paragraph 35).
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26242
Received: 17/07/2024
Respondent: Burwash Parish Council
Good.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26516
Received: 22/07/2024
Respondent: Tunbridge Wells Borough Council
TWBC support the approach taken by
RDC towards mandatory Biodiversity Net
Gain and qualifying applications but
would encourage RDC to seek gains for
biodiversity from all appropriate
development through schemes of
mitigation and enhancement
proportionate to the development
See attached document
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26532
Received: 18/07/2024
Respondent: Wealden District Council
Support for draft policies relating to BNG, while underlining the importance for councils to work collaboratively. This includes the recommendation for qualifying sites to deliver a minimum of 20% net gain. The need to work collaboratively with the Sussex Nature Partnership as part of this process.
Please see full representation below.
Climate Change and Biodiversity Net Gain (BNG):
WDC supports the provisions set out in these policy areas, and this reflects the joint working
we have undertaken so far. We are pleased to note the importance placed on climate
change mitigation and adaptation, which fully supports the transition to a net zero economy
and resilient future in terms of tackling changing climate across Rother district. The climate
change policies within draft Rother Local Plan are rightly put at the forefront of the
document and cover similar themes to WDCs emerging Local Plan in terms of achieving net
zero, reducing energy consumption for existing buildings, sustainable design and
construction, water efficiency and supporting renewable and low carbon energy schemes.
These policies are supported by WDC.
We also note that Proposed Policy GTC8 (Biodiversity Net Gain) recommends that all
qualifying developments should at least deliver a minimum of 20% BNG within the district
using Defra’s Statutory Biodiversity Metric. This again reflects the stance of WDC in terms
of its own emerging Local Plan policy (Policy NE2).
Paragraphs 3.48 and 3.49 of the draft Rother Local Plan set out that this higher level of
BNG is justified as there are opportunities available to deliver this off-site, if necessary, locally.
It also states that the viability of development is unlikely to be unduly impacted in
most cases. This paragraph also confirms that further evidence is being collated by the
district, in collaboration with the Sussex Nature Partnership and neighbouring local planning
authorities to justify going above the 10% mandatory requirement, and this is noted with
interest. We would like RDC to note that WDC has undertaken its own viability evidence1 on
this issue and this came to conclusion that there would be very little difference in the impact
between meeting 20% BNG or a lower net gain of 10% or 15%.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26583
Received: 29/07/2024
Respondent: Stephen Nicholls
I support the policy, but again for all development. If these ideas are good, then developers must not
have the ability to bypass them by building less houses to get around the requirement.
Please see attached submission.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26695
Received: 23/07/2024
Respondent: Devine Homes PLC
Agent: Nexus Planning
See attached submission (specifically page 4) for comments on Policy GTC8.
Please see attached full submission from Nexus Planning on behalf of their client Devine Homes regarding the Local Plan and HELAA Site SAL0012: Land at Bishops Lane, Robertsbridge
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26767
Received: 23/07/2024
Respondent: Rurban Estates Limited
Agent: DHA Planning
Please see "RDC Reg 18 Reps - Rurban Estates Ltd - Land east of Summerleas" attachment, specifically section 2.7.
See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26794
Received: 23/07/2024
Respondent: Catesby Strategic Land Ltd and Rurban Estates Limited
Agent: DHA Planning
Please see attachment "RDC Reg 18 Representations - High House Farm", specifically section 2.7.
See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Catesby Strategic Land Ltd and Rurban Estates Limited.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26840
Received: 23/07/2024
Respondent: Wates Developments Ltd
Wates recognises that England is one of the most biodiversity depleted countries in the world and that step-change is required in order to reverse the decline. The Government's 10% increase in BNG, imposed through the Environment Act, will ensure that development sites will enhance biodiversity post their completion and ensure that this enhancement is managed. The Council seeks to double this requirement to 20%. We consider this approach to be unnecessary and unsound. Firstly, the Council has not assessed the viability of this approach. As noted in our response elsewhere, viability is already extremely challenging in Rother and further burden on the development industry will only lead to less development coming forward. Secondly there is no evidence that there is a specific need in Rother to enhance biodiversity by this level. As such, it is our view that the 10% minimum should be enshrined in the Local Plan. However, we accept that the Plan should be looking to go beyond this 10% and we suggest that the 10% is set out as a minimum figure with the Plan making it clear that it is envisaged that where possible and viable that this would be exceeded.
See attached documents containing from Wates Developments containing:
1) The Consultation Response;
2) A Vision Document for HELAA Site BAT0014: Land at
Almonry Farm, North Trade Road, Battle; and
3) A Transport Note for HELAA Site BAT0014.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26879
Received: 19/07/2024
Respondent: Cantium Land and Development Ltd
Agent: Bloomfields
Please see attached comments objecting to Proposed Policy GTC8: Biodiversity Net Gain.
Please see attached comments in support of HELAA site BRE0002, and objecting to Proposed Policy GTC8: Biodiversity Net Gain.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26901
Received: 22/07/2024
Respondent: Brede Parish Council
Very much in support of this
Full submission attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26988
Received: 22/07/2024
Respondent: Northiam Parish Council
Support this policy.
See attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27014
Received: 23/07/2024
Respondent: Rurban Estates Limited
Agent: DHA Planning
See "RDC Reg 18 Reps - Rurban Estates Ltd - Watermill Lane" attachment, specifically section 2.7.
See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27047
Received: 22/07/2024
Respondent: Westfield Parish Council
See point 40 in the attached submission.
Please see attached document for the full submission from Westfield Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27204
Received: 22/07/2024
Respondent: Taylor Wimpey Strategic Land
Agent: Stantec UK Ltd
See attached representations regarding:
- Proposed Policy GTC8: Biodiversity Net Gain
See attached representations regarding:
- Proposed Vision - Chapter 2 of the draft Local Plan
- Proposed Development Strategy - Chapter 5 of the draft Local Plan
- Proposed Policy GTC1: Net Zero Building Standards
- Proposed Policy GTC5: Heat Networks
- Proposed Policy GTC8: Biodiversity Net Gain
- Proposed Policy LWL1: Compact Development
- Proposed Policy HOU2: Affordable Housing
- Proposed Policy HOU2: HOU12: Self-Build and Custom Housebuilding
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27281
Received: 23/07/2024
Respondent: Trustees of Steellands Farm
Agent: Mr Geoff Megarity
The general principles of the policy are in line with The Environment Act 2021. We do note however that the 30-year maintenance requirement is not embedded within the policy, and we believe that it should be as a matter of completeness. We will comment on the minimum requirement below.
Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27355
Received: 22/07/2024
Respondent: High Weald AONB Unit
Policy GTC8: Biodiversity Net Gain
We would wish to see specific reference made to the High Weald AONB, suggested additional text:
“Within the High Weald AONB, BNG proposals should be informed by a robust
understanding of the habitat typologies and systems of the High Weald, in order that they
are designed to provide a genuine positive contribution to local biodiversity and habitats.
Proposed enhanced or new habitats should function as a meaningful part of the wider
connected High Weald habitat mosaic, with reference to the components of natural beauty
set out in the AONB Management Plan, and should support the Nature Recovery principles
set out in the AONB Management Plan.
See attached full representation
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27389
Received: 22/07/2024
Respondent: Catsfield Parish Council
BNG is a good idea which flows from ideas in the Environment Act 2021, although the software is still not fit for purpose. Natural England have not yet produced templates for some kinds of development, such as solar farms. Rother need to list all exceptions unambiguously to BNG - working on what are already exceptions.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27456
Received: 22/07/2024
Respondent: Home Builders Federation
See points 25 to 34 of the attached submission regarding Policy GTC8 covering multiple points of the policy.
Please see the attached full submission from the Home Builders Federation.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27500
Received: 23/07/2024
Respondent: Rurban Estates Limited
Agent: DHA Planning
See section 2.6 of the attached response.
See attached document for the representation.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27530
Received: 23/07/2024
Respondent: Westcott Leach Ltd
Agent: DHA Planning
See section 2.6 of the attached representation.
See attachment for the full representation.