Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

Please see attached representation, existing and proposed sites plans.

Although the last criteria mentions protecting habitats, I think that putting in birdboxes etc should be specifically mentioned as historic buildings are often used as nesting sites for species such as swifts and swallows etc. When buildings are upgraded, these nesting sites are often lost.

Comments added to HER2

Please see attached comments from Burwash Parish Council.

Please see attached comments by Historic England on the Rother draft Local Plan 2020-2040 (Regulation 18), including representations on:

Policy GTC1
Policy GTC2
Policy GTC6
Policy LWL1
Policy HER1
Policy HER2

Requirement for Development Management policies

Draft Local Plan evidence base documents

Full submission attached.

Please see attached document for the full submission from Westfield Parish Council.

Chapter 3 – Green to the Core
Proposed Policy GTC1: Net Zero Building Standards
Operational Energy (A)(i)(c) - A maximum space heating demand for new buildings (small scale housing) of 15 kWh/m2 per year.
What is small scale housing? 15KWh/m2 per year is passivhaus standard – do you think this is possible for the majority of housing? If small scale housing is only a subset of most of the houses to be built, what is their target for space heating demand?

Proposed Policy GTC2: Net Zero Retrofit Standards
What proportion of dwellings to be retrofitted do you think this will impact? Surely most do not need planning permission?
It has been stated that the current level of demolition and subsequent replacement through new build contributes five times more greenhouse gases than air travel. While unsure of the evidence for this statement, is RDC satisfied that their policy promotes retrofit strongly enough?

Proposed Policy GTC3: Construction Materials and Waste
Do you know if developers currently have designs that use a Design for Disassembly approach or is that something that needs to be promoted to architects?

Proposed Policy GTC4: Water Efficiency
Will this policy be able to keep up with potential future reductions in water usage? The RIBA (Royal Institute of British Architects) 2030 Climate Challenge promotes 75l/p/day potable water usage.
Would the policy benefit from an “update” statement as GTC1 (A, i, d) does?

Proposed Policy GTC6: Renewable and Low Carbon Energy
Why does this policy not include criteria about improving biodiversity e.g. making areas into small nature reserves and that any biodiversity improvements should be retained at the end of life of the site?

Proposed Policy GTC7: Local Nature Recovery Areas
Will planners use local Biodiversity Audits (such as Crowhurst has) to help identify areas as important?
Could iii) “it directs Biodiversity Net Gain to where it can be of most benefit” be used by developers to increase BNG offsite from developments, even to non-local areas?

Proposed Policy GTC8: Biodiversity Net Gain
How confident are you that the 20% min BNG will be allowed?

Proposed Policy GTC9: High Weald National Landscape (AONB)
Should there be more to the sentence “To support the integrity and importance of the High Weald NL and conserve and enhance its important landscape and scenic beauty the following policy approaches have been explored:” at the end of para 3.64 on p60?

Chapter 4 – Live Well Locally
Proposed Policy LWL2: Facilities and Services

This policy states that developments in village areas should be within safe walking or cycling distance of a range of seven specified local amenities. The Crowhurst developments are within range of three of the listed facilities. The policy then states that where a development does not comply, it should be within walking distance of a suitable bus stop, with transport to an area containing these facilities. In our case these facilities (food shop, GP surgery etc) are accessible in Battle or Hastings via the station or the flex bus. We suggest amending the policy to include these transport hubs.

Chapter 5 – Development Strategy and Principles
Proposed Policy DEV2: Comprehensive Development and Master planning

If a developer subsequently reneges on specified aspects of an approved planning application, e.g. by reducing the affordable housing element, will the Council consider voiding the approval?

Proposed Policy DEV3: Development Boundaries

With reference to paragraph 5.119, can you confirm how, when and in what circumstances village development boundaries may be reviewed?

Proposed Policy DEV5: Development on Small Sites and Windfall Development

Parishes are currently not able to control identification of sites of less than five dwellings through the neighbourhood planning process. Paragraph 5.132 states that it is likely that future neighbourhood plans will be able to identify smaller sites, with no site size threshold. Does this equally mean that small sites considered unacceptable through the neighbourhood plan process would have a presumption for planning permission to be refused?

Proposed Policy DEV6: Strategic Green Gaps

Policy DEV6 refers repeatedly to the vulnerability of the various strategic gaps including between Crowhurst and Hastings/Saint Leonards. How firm is your intention to maintain the strategic gap?

Chapter 11 – Environmental Management
Proposed Policy ENV1: Coastal, Water and Flood Risk Management
Does criteria ii) include during construction of new developments when vegetation that would normally slow water run-off may have been removed but any required flood alleviation has not yet been put in place? (even though this is mentioned in ENV2 (vii))?

Proposed Policy ENV2: Sustainable Surface Water Drainage
Why is only flood risk and not contamination/pollution mentioned in criteria (vii)?

Proposed Policy ENV5: Habitats and Species
Should ancient and veteran trees also be protected by TPO’s if development is taking place near them?
Will developers also be encouraged to use local Biodiversity Audits as information?

Chapter 12 - Heritage
Proposed Policy HER2: Traditional Historic Farm Buildings
Although you mention nesting birds in para 12.29, should it be specifically mentioned in the policy as conversion of farm buildings often ends up blocking access to birds’ nesting sites inside?
Will conversion to residential proposals also have to meet sustainable location criteria as farm buildings are often at a distance from other buildings?