Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25807
Received: 22/07/2024
Respondent: Mr Dale Wheeler
I agree with the policy wording "...floor to ceiling windows, are discouraged...", however no mention is made of skylights / lanterns, which by their nature allow light to escape in an upwards as well as sideways direction.
Mitigation through technological approaches (blinds, shutters, tinted window films, electrochromic glass, etc) should always be a priority
I agree with the policy wording "...floor to ceiling windows, are discouraged...", however no mention is made of skylights / lanterns, which by their nature allow light to escape in an upwards as well as sideways direction.
Mitigation through technological approaches (blinds, shutters, tinted window films, electrochromic glass, etc) should always be a priority
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26033
Received: 23/07/2024
Respondent: Mrs Anne Newson
Reference to the initiative to obtain International Dark Skies Reserve status
Reference to the initiative to obtain International Dark Skies Reserve status
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26040
Received: 23/07/2024
Respondent: Mrs Anne Newson
This statement/policy below really doesn't work. Tranquillity and remoteness are inevitably negatively impacted, irretrievably harmed or simply lost for ever by development in remote areas. The ongoing maintenance of dark skies is not secure as there will be no future enforcements on subsequent additions or changes to lighting.
"The siting, layout and design of development must maintain and reinforce the sense of tranquillity of remote areas, especially locations within the High Weald National Landscape, through maintaining dark skies and avoiding unnecessary light pollution".
This statement/policy below really doesn't work. Tranquillity and remoteness are inevitably negatively impacted, irretrievably harmed or simply lost for ever by development in remote areas. The ongoing maintenance of dark skies is not secure as there will be no future enforcements on subsequent additions or changes to lighting.
"The siting, layout and design of development must maintain and reinforce the sense of tranquillity of remote areas, especially locations within the High Weald National Landscape, through maintaining dark skies and avoiding unnecessary light pollution".
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26157
Received: 23/07/2024
Respondent: Mr David Silk
Nature Recovery Network Terms of Reference.
Numerous local parishes working together to attain Dark Skies accreditation from the International Dark Skies Association.
Nature Recovery Network - Dark Skies project
Terms of Reference
Mission: the purpose of this initiative is to reduce light pollution and protect the dark skies across East Sussex parishes in the Rother and Wealden planning areas by becoming certified as a “Dark Sky Community” in 2026, improving quality of life for local people, protecting wildlife, saving costs and ensuring beautiful natural dark skies for future generations.
Why do we need this project?
• “Inappropriate or excessive use of artificial light has serious environmental consequences for humans and
wildlife”
. The UK Government states that artificial light “can be a source of annoyance to people, harmful to
wildlife and undermine the enjoyment of the countryside or the night sky, especially in areas with intrinsically
dark landscapes.”
• The High Weald National Landscape is home to some of the darkest skies in the South East but light pollution is
a growing issue.
3 Yet light pollution is the easiest type of pollution to fix because it is instantly reversible.
• Lower lighting levels will reduce power consumption (reducing costs to councils, businesses and households)
and will reduce CO2 emissions (contributing to climate emergency net zero goals)
We need to ensure that light is directed to where it is needed, on the ground, rather than upwards where it is wasted
and pollutes our dark night sky.
Project goal and framework
• To become certified as a “Dark Sky Community” by the end of 2026, the first in the High Weald
• DarkSky International (formerly the International DarkSky Association, or IDA) is the parent certification body,
so we have adopted the DarkSky programme guidelines
• The UK chapter is DarkSky UK, who will assess our application for certification - we regularly consult Dan
Oakley (a DarkSky UK reviewer) for advice and guidance
Certification criteria
In summary, each parish needs:
1. legally effective dark sky policy in District Council Local Plans and Parish Neighbourhood Plans (or equivalent)
2. a Lighting Plan to remediate public and private (commercial and domestic) light pollution
3. evidence of local community engagement and support
4. case studies to demonstrate application of dark sky policy
Scope
• Nine parish councils spanning two planning authorities have committed to this initiative:
o Rother: Battle, Brightling, Burwash, Catsfield, Crowhurst, Etchingham & Ticehurst
o Wealden: Mayfield & Wadhurst
o Four other parishes are supportive and are considering joining in due course
• These parishes are joining forces to:
o maximise the area covered by the dark sky certification
o align dark sky policies across the region
o share resources, experience, costs, best practices and lessons learned
o coordinate communication with our communities
o speak with a stronger voice with planning authorities
• Each parish is free to seek independent certification and can travel at its own pace: the convoy does not have
to travel at the speed of its slowest member
POLICY
DarkSky certification requires each parish to develop a comprehensive lighting management policy (LMP) that includes:
• Full shielding of all light fixtures emitting more than 1,000 lumens
• Limits on short wavelength (blue, more powerful) light through various technical standards (wavelength,
temperature or S/P ratio)
• Avoidance of over-lighting (restricting lighting to the task area)
• Adaptive controls such as motion sensors or timers
• Special measures for recreational / sports field lighting
The lighting policy must be legally effective. In the UK this means policy must be enshrined within district council Local
Plans and/or parish council Neighbourhood Plans as they develop.
• In March 2024 Wealden District Council issued a Draft Local Plan Consultation (Reg 18) containing a new dark
sky policy NE10 which:
o “will ensure lighting associated with new development does not harm the quality of dark night skies,
nor contribute to sky glow, glare and light spillage or impact biodiversity and local character”
• In April 2024 Rother issued a Draft Local Plan Consultation (Reg 18) containing a new policy LAN3: Dark Skies
o “The siting and design of development must maintain and reinforce the sense of tranquillity of
remote areas… through maintaining dark skies and avoiding unnecessary light pollution”
• The Nature Recovery Network dark skies project is fully supportive of the Local Plan dark sky goals
• The High Weald National Landscape has published a 2024-2029 Management Plan6
o The Plan sets out two specific dark skies objectives (DS1 and DS2)
o The Plan is likely to be adopted by District Councils throughout High Weald inc Rother and Wealden
• Parish councils should now develop or update dark sky policies into their Neighbourhood Plans (or parish
policy in the absence of a Neighbourhood Plan), making reference to planning authority Local Plans, High
Weald National Landscape Management Plan dark skies policy, and other guidelines such as:
o Institute of Lighting Professionals (ILP) Guidance GN017
o ILP / Bat Conservation Trust Guidance Note GN08/23: “Bats and Artificial Lighting at Night”8
o International DarkSky Community Program Guidelines 2018 Updated September 2023 9
o High Weald National Landscape Lighting Technical Advice Note (expected summer 2024)
• We will engage Rother and Wealden District Councils to:
o provide documentary confirmation that parish dark sky policies will be taken into account in planning
decisions
o create local case studies of successful enforcement of dark sky policies by the planning authorities,
showing how the policy has prevented or reduced light pollution
PLAN: Lighting Management Plans
DarkSky certification will require each parish to develop a Lighting Plan that addresses:
• Public lighting
o A lighting inventory (ie asset register) confirming whether publicly owned lighting (eg street lamps)
conforms with the Lighting Management Policy (LMP)
o A plan to ensure publicly owned lighting will conform to the Policy within 5 years
• Private lighting
o A plan to reduce light pollution from commercial and domestic sources
o To achieve this we will:
§ identify the light polluters in each parish (eg shops, businesses, stations, schools, pubs,
households etc)
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§ hold events for businesses to explain the dark sky benefits and understand any issues and
difficulties they face in reducing light pollution (eg security or insurance constraints)
§ approach households to provide education on the benefits of dark skies, the existence of
district and parish council dark sky policy, with a request to remediate their lighting
§ identify local “dark sky friendly” lighting suppliers whose names can be provided to
businesses and households
• A sky brightness measurement programme that evidences reduction in light pollution
o Before and after photos (North York Moors submitted 100+ photos) evidencing reduction in light
pollution
o We might repeat light surveys prior to applying for certification
Parish councils will be responsible for producing the publicly owned lighting asset register and the Lighting Plan for
public lights. Local volunteer groups will be responsible for the Lighting Plan for commercial and domestic lighting.
It may be appropriate to engage third party specialists to assist with the technical aspects of the Lighting Plan. We may
also decide to purchase more hand held SQM light meters to allow more dark sky meter surveys at the same time.
PEOPLE: community engagement
DarkSky certification requires us to demonstrate community engagement and support. This will be achieved through a
variety of means over the course of the project, including:
• Annual dark sky festivals
o High Weald National Park will organise an annual festival coordinated across region for the years
2024-6 (and beyond), building on the success of the 2023 festival
• Dark Sky walks
o Each parish could host their own local dark sky walks to engage and educate members of the local
community, either as part of, or independently of, the annual dark sky festival
o The High Weald National Landscape can provide a best practice template for how to organise and
conduct a dark sky walk
• Community events
o Each parish could participate in community events such as the Wadhurst Farmers Market to spread
the message, gather evidence of community support, hand out leaflets, recruit volunteers etc
• Published articles
o Each parish could publish periodic articles on different topics such as impact on bats, roosting gulls at
Bewl, cost / CO2 savings, dark sky friendly lighting suppliers, before/after photos etc
o It might be helpful to produce these centrally for distribution to all parishes for publication in village
magazines, “Wild About” face book groups, mailing lists etc.
• Schools
o Inclusion of dark sky education in schools’ curricula
o Engagement of pupils in dark sky festivals and community engagement activities
• Letters of support
o We will seek “letters of support” to evidence community engagement from schools, pubs, shops,
Astronomy Societies etc. North York Moors National Park obtained 100+ letters of support.
• “Public Pledges”
o North York Moors National Park created a “public pledge” so members of the public could register
support for dark skies, ultimately gathering 1200+ public signatures/post codes
• Leaflets
o We will continue to produce leaflets that can be provided to members of the community to spread
the message, to persuade existing light polluters to adopt more suitable lighting
o These could include simple guidelines for residents and businesses to encourage policy compliance,
with pointers to local “dark sky friendly” lighting suppliers
o Leaflets could be provided to new residents as part of welcome packs or via estate agents
• Online presence
o High Weald National Landscape will promote the Dark Sky Festivals on its website and through its enewsletter
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o Parishes should promote dark sky policy on council websites with links to High Weald and local
resources
o Volunteer groups should promote dark skies through local Facebook pages and newsletters
• Signage
o Once certified, DarkSky International requires us to erect signage indicating we are a Dark Sky
Community
Primary responsibility for community engagement within each Parish will be managed by local volunteers such as the
village “Wild About” (or equivalent) groups.
Governance
We have created a centralised data store (with a folder for each parish) to lodge supporting evidence such as:
• Policies
• Lighting Plans
• SQM light meter readings
• Before/after photos
• Letters of support
• Community engagement activities, meetings, attendance metrics etc
Dark Sky representatives in each parish will meet periodically to communicate progress, share information and
experience, coordinate activities, share and resolve issues etc. The parish Dark Sky Lead could be a councillor, a parish
clerk or a volunteer.
Critical success factors
A parish planning to join the Dark Sky Community will need to ensure that critical success factors are in place:
1. A parish councillor to lead the policy approval process and to sponsor development of a Parish Lighting Plan
2. A group of local volunteers to organise activities such as surveys, festivals, walks, publications, social media
updates, schools contacts etc
Funding
The High Weald National Landscape has secured 3-year funding (2024-26) from the Sussex Lund fund to cover dark sky
festival expenses such as website costs, printed materials, event guidance and risk assessments etc. To provide access
to this funding a “Partnership Agreement” has been developed by High Weald National Landscape which will be signed
between Sussex Lund and each parish council / “Wild About” group (or equivalent).
Additional funding may required in due course for:
• printed leaflets
• venue hire & refreshments
• external speakers
• specialist expertise
Additional funding may be sought from parish councils, grant-giving trusts such as Sussex Lund, or fees from sales of
tickets to events. We may wish to consider meeting the funding needs of multiple Parish funding needs through a
coordinated grant application.
Dark sky case studies
There are now a number of dark sky communities around the world and in the UK, so this is a proven framework and
we are following in the footsteps of others. These include:
• South Downs National Park was certified as a Dark Sky Reserve in 2016
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• North York Moors National Park was certified as a Dark Sky Reserve in 2020 and has launched a local “Dark Sky
Friendly Village” scheme
• Kielder Observatory was certified as a Dark Sky Park in 2013
Risks
1. If all parishes seek certification as a bloc, there is be a risk that if one parish fails all parishes may fail – this risk
will be mitigated through individual certification applications if necessary
2. Some commercial and domestic owners of light pollution sources may refuse to adopt better lighting on
grounds of cost, security concerns etc