Core Strategy Consultation on Strategy Directions 2008

Object

Representation ID: 19442

Received: 24/02/2009

Respondent: Environment Agency

It is encouraging that the 'Preferred Option' for the distribution of development follows the principle of sustainable development directing development towards existing service centres. This will reduce the reliance on the car reducing emissions and contributing to the improvement of air quality. It is encouraging that it is noted that there may be environmental impacts which will limit the potential for growth in settlements that may otherwise be suitable, such as Rye, Battle and the rural settlement of Robertsbridge, both of which have significant flood risk and land contamination constraints.
Recommendation 1:
Paragraph 5.61 - Include land contamination as a significant environmental constraint to development in Rye which coupled with the element of flood risk has the potential to result in unacceptable impact on the environment.

Object

Representation ID: 19443

Received: 24/02/2009

Respondent: Environment Agency

We are encouraged that Box 6: Location of Development on page 35 includes criteria (c), (d) and (e) which seek to ensure biodiversity, flood risk and resource efficiency potential are considered when determining the most appropriate locations for development. This is also further supported by (g), (h), (i) and (k) of the General Development Criteria and relates well to the Environment Chapter of the Strategy.
Recommendation 2:
Include environmental constraints in criterion (g) of the Preferred Strategy for Overal Spatial Development on page 29 to ensure that this is taken in to account when considering sites for development in the smaller rural settlements.

Object

Representation ID: 19462

Received: 24/02/2009

Respondent: Environment Agency

The Scope/Issues section of Chapter 6: Bexhill and the Hastings Fringes, does not address environmental constraints within this area particularly in relation to the flood risk, Sites of Special Scientific Interest (SSSI) and a Source Protection Zone (SPZ).
It is encouraging that the vision for Bexhill and Hastings on page 38 includes partnership working on environmental projects.
The Strategy promotes a new railway station at Glyne Gap (an area of flood risk) however subject to an adequate Flood Risk Assessment, we would have no objection in principle.

The siting of any development west of Bexhill would need to be informed by identified flood zones within the Strategic Flood Risk Assessment and other environmental designations.

Recommendation:
Ensure that environmental constraints such as flood risk, SSSIs and SPZs are included in the consideration of Bexhill and the Hastings Fringes for development potential.

Object

Representation ID: 19468

Received: 24/02/2009

Respondent: Environment Agency

The Environment Agency request that the history of industry at Rye Harbour is acknowledged and safeguarding the environment from, and the remediation of, land contamination is included as an environmental objective for the area. It must also be noted that any development on brownfield land in this area would need to be subject to an assessment of risk.
Recommendation 4:
Include an Objective in Box 14 on page 62 to read: "(ix) To protect the environment from the impacts of land contamination present at Rye Harbour".

Object

Representation ID: 19470

Received: 24/02/2009

Respondent: Environment Agency

The Preferred Strategy for Rye and Rye Harbour on page 66 c) (i) states by 2020 all of Rye will be defended to the recognised standard of 1 in 200 Year flood event. We consider that this is a reasonable statement however, the standard of defence does not automatically allow for further development and a Sequential Test as defined in PPS25 must be undertaken for sites within Flood Zones 2 and 3 to demonstrate that no reasonably developable sites are available on sites in areas at lower risk of flooding.

Comment

Representation ID: 19471

Received: 24/02/2009

Respondent: Environment Agency

Additional activities or developments in the Rother Estuary or Rock Channel will have to avoid any direct or indirect damage to the Site of Special Scientific Interest. Outside of the designated site, activities adjacent to in or on wetland habitats such as the Rother Estuary should avoid any loss of Biodiversity Action Plan Habitat such as inter-tidal mud or saltmarsh.

It should be taken into account that development in the Rock Channel or adjacent to the Old Rastrums site will only be acceptable if Government Guidance is followed that achieves a net gain for wildlife as a result of any significant development.

Comment

Representation ID: 19472

Received: 24/02/2009

Respondent: Environment Agency

As the Council supports the Living Landscape Project, the Local Nature Reserve at Rye Harbour and the principle of a strategic gap between the Rock Channel and Rye Harbour Developments it could do more to suggest how this strategic gap should be managed. Whereas at present the preferred option on for the Environment is to leave the question of habitat creation open to be determined at a later date.

Comment

Representation ID: 19473

Received: 24/02/2009

Respondent: Environment Agency

Whilst it is accepted that the Environment Chapter 12 does state that developments should not impact on priority habitats, it would be beneficial to clarify this point within Box 15 that is specific to Rye and Rye Harbour.

Object

Representation ID: 19474

Received: 24/02/2009

Respondent: Environment Agency

Box 15 - a) (ii) of the Preferred Strategy refers to the possibility of enhancing commercial shipping at the harbour by providing additional port activities adjacent to the existing Rastrum site. There is a need for major investment in the harbour infrastructure for the harbour to remain a viable port for shipping and further investment would need to be secured to enable additional port activities to take place. Recommendation 5:
Page 63 - paragraph 8.14 should be updated to include that investment is required for Rye Harbour to remain a viable port for shipping and further investment would be needed in order to enable additional wharf and industrial activities to take place.

Comment

Representation ID: 19475

Received: 24/02/2009

Respondent: Environment Agency

Paragraph 9.63 on page 79 considers the upgrading of holiday caravan and chalet developments, however we must note that it is unlikely that an extension to the occupancy of existing holiday caravans or chalets would be acceptable in areas of flood risk. We support the resistance to caravans and chalets to become permanent homes in areas of flood risk, and permanent single-storey mobile home accommodation is considered as 'highly vulnerable'.