Sustainability Appraisal for Core Strategy Consultation on Strategy Directions

Comment

Representation ID: 20449

Received: 29/01/2009

Respondent: Natural England

The description of the baseline characteristics (set out in section 3.3) should include reference to the loss of SSSI area, as this is an important condition of the current state of the natural environment in the District.

The baseline characteristics (section 3.3) should also refer to the provision and quality of green space in the District. It is expected that the 'Green Network Strategy' will provide input to the District's green infrastructure evidence base.

Comment

Representation ID: 20450

Received: 29/01/2009

Respondent: Natural England

Natural England recommends more explicit inclusion of nature conservation and landscape character in the SA Objectives, to better emphasise the value of these to environmental sustainability. The following Objectives could be amended as follows
•SA Objective 14 - Conserve and enhance biodiversity by protecting both designated and non-designated but locally important species and habitats.
•SA Objective 15 - Protect and enhance the high quality natural and built environment, including landscape and townscape character and particularly the protection of the High Weald AONB.

Comment

Representation ID: 20451

Received: 29/01/2009

Respondent: Natural England

The SA recognises that strategic open space between Bexhill and Hastings will largely be managed for public enjoyment rather than for biodiversity benefits. In planning for green infrastructure in the District, the draft Core Strategy should set out a strategy for assessing both the quality and quantity of green and open space. Natural England recommends that any audit of green space in the District incorporate measures to assess, and targets to enhance, the quality of green space.

Support

Representation ID: 20452

Received: 29/01/2009

Respondent: Natural England

Natural England commends the SA for clearly recognising that the draft Core Strategy is likely to result in a net loss of biodiversity (para. 6.2.48).

Comment

Representation ID: 20453

Received: 29/01/2009

Respondent: Natural England

Natural England expects this assessment to provide weight to recommendations to mitigate against losses due to development by providing for opportunities for biodiversity enhancement throughout the draft Strategy, to restrict planned growth to allocated sites, commit to not encroaching on strategic open spaces, and to monitor and set ambitious targets for air pollution and water consumption associated with new development (including transportation infrastructure).

Comment

Representation ID: 20454

Received: 29/01/2009

Respondent: Natural England

The impact of development growth on soil sealing and compaction in Rother should be highlighted in the SA, and included in the evidence base and the monitoring targets. As a non-renewable resource, soil should be monitored and the impact from development should be assessed, in order to maintain biodiversity, geodiversity, and mitigate flood risk.
•The significance of avoiding soil sealing through the preferential development of brownfield land should be mentioned in the assessment of SA Objective 9 Improve efficiency in land use and encourage the prudent use of natural resources (p.73).
•Soil sealing and compaction measures should be added to the SA monitoring targets (Table 8.1), for example, under the Prudent Use of Natural Resources priority (pg.88).

Comment

Representation ID: 20455

Received: 29/01/2009

Respondent: Natural England

The assessment of options for Rye states that option 2 "is generally more positive than option 1 for environmental matters" (pg.49). Unless there is evidence that option 1 will in some respects be more positive than option 2 for environmental matters, this should be reworded to reflect that option 2 is (not generally, but wholly) more positive than option 1 for environmental matters. This clearer wording will better reflect the difference between the two options.

Comment

Representation ID: 20456

Received: 29/01/2009

Respondent: Natural England

Natural England would like to see a greater number of environmental and biodiversity measures in the proposed mitigation measures in Table 7.1:
•Overall:
Add 'design' to the mitigation measure to incorporate "sustainable construction [and design] in overall strategy" (3rd bullet). The design of development is as significant to its sustainability as is its construction.
•Bexhill:
Add a mitigation measure for a commitment in the draft Core Strategy to protect the strategic gap between Bexhill and Hastings and to minimise and monitor greenfield development.
•Environment:
In identifying 'priority habitats' emphasis should not be given solely to protected or designated sites or species, but additionally to undesignated habitats, namely BAP priority habitats and species.

Comment

Representation ID: 20457

Received: 29/01/2009

Respondent: Natural England

It may be helpful to link the SA Objectives with the 'Priority' column in Table 8.1 (p.87), to indicate with greater clarity the targets that will be used to monitor each SA Objective.

In Table 8.1, the priority 'Landscape Quality' target should be more specific, and could be amended to, for example: Maintain and improve from current levels the condition of Rother's landscape character areas, as indicated in the Landscape Character Assessment for the District. The Landscape Character Assessment provides the evidence base for assessing the impact of the Core Strategy on landscape character, but is not itself an actual target.

Comment

Representation ID: 20458

Received: 29/01/2009

Respondent: Natural England

The inclusion of a map of the District in the SA report would provide the reader with improved context for understanding the issues discussed.