Comment

Representation ID: 25720

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of this policy

Comment

Representation ID: 27842

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

P369- ENV6: Sustainable Access and Recreation Management Strategy
Q192 – 193
Rye agrees

Comment

Representation ID: 28299

Received: 23/07/2024

Respondent: Natural England

We note that we have previously provided advice on this matter, in relation to earlier documents and
we summarise the advice that remains valid, below:
If the supporting evidence for the SARMS continues to shows that the vast majority of visitors to the
area come from outside the Folkestone and Hythe and Rother districts, and are tourists, attracted to
the area for the variety of recreational activities on offer; for there to be certainty as to the
effectiveness of any mitigation, it will need to be targeted at those visitors causing or likely to cause,
the disturbance based upon the evidence underpinning the SARMS.
Habitats Regulations Assessment (HRA): We note that the supporting HRA (April 2024) includes
the following recommendation:
"6.23 It is recommended that the Draft Dungeness Complex SARMS is reviewed and updated to
allow effective implementation of Proposed Policy ENV6. In particular it is recommended that the
governance and funding arrangements for the management of the Dungeness Complex SARMS
measures are formalised. This should include a body for delivery of the measures, a charging tariff,
a mechanism for collecting funds from affected developers, and a regular review process to inform
future reviews of measures. The tariff would be informed by consideration of the cost of
implementing the identified measures and the number of dwellings that are likely to be affected.
Since the SARMS is a joint exercise between Rother and Folkestone & Hythe, this exercise should
also be done jointly."
Whilst we support the need to review and update the 2017 SARMS work, the use of a mechanism
for collecting funds from affected developers would, for the reasons set out above, be of concern
with regard to HRA compliance.
Given the comments within the HRA accompanying the Local Plan consultation, Natural England
would advise that a greater degree of certainty is provided as to how the SARMS will be funded and
implemented to give certainty that the mitigation measures will be effective. We would be pleased
to continue working with the Council on this to help ensure these concerns are resolved.