Core Strategy Consultation on Strategy Directions 2008

Comment

Representation ID: 19739

Received: 30/01/2009

Respondent: RSPB

Figure 4. Environmental Designation - The council needs to take a hierarchical approach in presenting areas of conservation importance. International sites need to be clearly highlighted to ensure appropriate protection and avoid ambiguity. Table 2 - The strategy needs to be developed further to provide habitats and species space to naturally adapt to climate change trends.
Protection and enhancement of priority habitats and species should also be highlighted as a challenge, as increased development and transport infrastructure have far reaching impacts on wildlife and an effective mitigation strategy will have to be undertaken to safeguard the districts important environmental assets. Alternative wording could be to "ensure that development and economic growth does not conflict with protection and enhancement of the District's unique wildlife and habitats"

Comment

Representation ID: 19740

Received: 30/01/2009

Respondent: RSPB

5.7 -Recreational and environmental pressures associated with housing and infrastructure could lead to an adverse effect on the Natura 2000 sites (Pevensey Levels Ramsar site and Dungeness to Pett Level SPA site).
The provision of alternative green space and access management measures on the European sites will provide a mitigation strategy in order to offset recreational impacts. The capacity of natural receptors (Natura 2000 Sites) to absorb additional pollutants produced from new development will have to be carefully assessed and mitigated. The Appropriate Assessment will need to demonstrate that mitigation methods will prevent adverse effects on Natura 2000 sites, before housing numbers adopted.

Comment

Representation ID: 19741

Received: 30/01/2009

Respondent: RSPB

It is essential that full regard is given to climate change and sea level rise when allocating major development, especially residential, around the coastal areas of the district. Areas of particular concern are Rye Harbour and Camber, which have significant and moderate levels of flood risk.
Preferred Option
Our preferred option would be to direct maximum development away from designated conservation sites and flood risk areas. Option 3 would seem to be the best choice to achieve this requirement. Until an Appropriate Assessment is undertaken that can demonstrate no adverse effect to the integrity of Natura 2000 sites no option can be endorsed.

Comment

Representation ID: 19742

Received: 30/01/2009

Respondent: RSPB

Bexhill Hastings Link Road
The Core Strategy should avoid all direct land take from Combe Haven or Marline Valley Wood SSSI and any assessed impacts mitigated against.

Comment

Representation ID: 19743

Received: 30/01/2009

Respondent: RSPB

Growth Options
If the area North West and West of Bexhill is allocated for development then this could have the potential for an adverse affect to the ecological integrity of Pevensey Levels Ramsar site and the important wildlife populations that it supports. The main likely pressures will be from recreational disturbance, hydrology, and pollution, and before these sites are allocated an Appropriate Assessment will have to be undertaken as a requirement of the Habitats Regulations.
It would also be against national policy to develop on ancient woodlands.
We would strongly support the proposals for the Pebsham Countryside Park and other open space, which if managed correctly would help to reduce increased recreational disturbance to designated sites from new development identified in the Core Strategy.

Object

Representation ID: 19744

Received: 30/01/2009

Respondent: RSPB

Hastings Fringes
We realise that the housing allocation options in this area are limited, however we do not feel it is acceptable for direct land take from Marline Valley Woods or Combe Haven SSSI sites, as it seems to appear in your preferred strategy. The Natural Environment and Rural Communities (NERC) Act 2006 states that "every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity". This is in addition to local authorities existing duties under the Wildlife and Countryside Act1981 to take reasonable steps, consistent with the proper exercise of their function, to further the conservation and enhancement of SSSIs

Object

Representation ID: 19745

Received: 30/01/2009

Respondent: RSPB

Rye and Rye Harbor
The recreational and environmental pressures associated with the proposed housing in the Core Strategy could, alone or in-combination with other proposed housing development in surrounding areas, lead to an adverse effect on the surrounding Natura 2000 sites. 8.30 - An additional consideration is that the proposed development site is within 3km of Dungeness to Pett Level SPA and even closer to Walland Marsh SSSI.
We are also deeply concerned with the proximity of Dungeness to Pett Level SPA site to the proposed development activities in the Rye Harbour area. The preferred option for employment directly conflicts with the strategy to safeguard the integrity of Dungeness to Pett Level SPA.

Comment

Representation ID: 19746

Received: 30/01/2009

Respondent: RSPB

In order to offset the cumulative effects of housing within the Rother District on surrounding European Sites of conservation importance, it will be necessary for local authorities to work closely together, particular with regard to the delivery of new or enhanced open space. Integrated natural open spaces will be required to mitigate residential disturbance to European sites of conservation importance from new housing developments identified in the Core Strategy. A clear mitigation framework is required which provides:
• an evidence base for quantifying the current and predicted recreational impacts on Natura 2000 sites arising from policies in the Plan
• justification for proposed mitigation measures and standards
• methods for securing funding (ex. developer contributions)
and details of capital works or enhancement measures necessary

Comment

Representation ID: 19747

Received: 30/01/2009

Respondent: RSPB

It would be good practice to state the present known condition of the designated sites (SSSI condition) so increased protection can be warranted. This protection should extend to bio-diversity outside of designated sites. Need to maintain all networks of habitat. Concern over impact from recreational disturbance to designated sites and the species that they support. Green open spaces will reduce recreational disturbance to local designated sites. Increased access management to Natura 2000 sites may also form part of the mitigation.
12.23 .
We would strongly support and commend option 2, and see this as the correct way forward. Local Development Frameworks should identify important areas for habitat restoration/re-creation, by means of appropriate policies and maps. The RSPB are currently mapping potential restoration areas, which could be used to fulfill this requirement.

Comment

Representation ID: 19749

Received: 30/01/2009

Respondent: RSPB

The Preferred Option for Biodiversity and Green Space.
The Core Strategy needs to recognise the environmental trends resulting from climate change and ensure provision for natural systems, habitats and species to adjust to this. Of particular relevance to the District are the effects of climate change on coastal habitats. .
A further policy needs to be established to ensure land management is in step with naturally functioning processes and systems and aligns with objectives for biodiversity conservation and other strategies.
Brownfield sites of particular conservational importance should be identified and given the appropriate level of protection.