Proposed Submission Core Strategy

Policy OSS3: Use of Development Boundaries
(vii) environmental considerations, including the need to conserve designated areas of national and local landscape, archaeological, geological, ecological or historical importance;
This may be addressing development control on designated nature conservation sites but it needs to be more explicit, or the term ecological may be referring to functionally related land to Natura 2000 sites (N2K) as it was used in the Shepway core strategy from the HRA, clarification is needed on this if that is the case.

Section 7.77 states "Environmental impacts need to be carefully addressed, such that landscape character is conserved, inappropriate fragmentation of the countryside avoided, important trees, woodlands and hedgerows retained, and where appropriate, supplemented by new landscaping, and wildlife habitats protected and encouraged."
But the subsequent policy OSS5: General Development Considerations does not incorporate this. Natural England would like to see this in policy wording.

Policy RY1: Policy Framework for Rye and Rye Harbour
The supporting text 10.20 raises a number of concerns and measures to address these issues
10.20 "It is acknowledged that there is a requirement for the sensitive management of tourism (from local sources and those further afield) in the Dungeness complex of internationally important wildlife sites. To retain their conservation status and preserve their integrity there will be requirement for effective management measures to be implemented and agreed with the
relevant stakeholders and agencies in parallel with the promotion of future tourism and recreational activity in the area around the Dungeness international sites. These may include increased wardening, dissemination of guidelines/advice to the public, screening of recreational activities, changes in site access/routing of footpaths or managing visitor numbers to areas of interest and will also involve the implementation of appropriate monitoring arrangements and the development of a sustainable access strategy to manage visitor numbers in order to ensure that increased recreational activity does not lead to an adverse effect on the integrity of the sites."
Policy RY1: Policy Framework for Rye and Rye Harbour
(viii) Maintain and enhance navigation on the River Rother and the viability of the Port of Rye as a working harbour, having particular regard to protecting the integrity of internationally designated habitats;
(ix) Promote green tourism initiatives, including careful management of the Rye
Harbour Nature Reserve, which protect the integrity, and where possible enhance the internationally important ecological interests;
Generally Natural England is satisfied with this policy and supportive text in relation to Rye Harbour, tourism and the N2K sites. We would just like clarity around the wording „enhance‟ for bullet (viii). Does this cover future development and expansion at the harbour? This could be made clearer perhaps.
Bullet (ix) should also contain some wording to hook in some of the measures that may be required to protect the N2K sites from tourism and recreation as outline in the supportive text 10.20.
Clarification is needed as to whether, within the Rye Harbour area, green tourism at Camber sands and Broomhill frontages are considered. These experience heavy usage from recreation and leisure pursuits and may require a suite of measures to address these issues should the impact increase towards significant levels.
Section 10.20 goes a long way to describing the type of monitoring and strategic approach required to protect the integrity of Natura 2000 sites in this and the neighbouring district of Shepway. A collaborative program would be the way forward on this and a policy hook in this policy on Rye, the general tourism policy and other related site policies that include designated sites needs to be included.
Finally in addition to the mention of Natura 2000 sites in relation to impacts from development and tourism it would be good to see a policy point here that is about enhancing these areas for their own value this may tie into the policy wording of the Romney Marsh BOA highlighted in the biodiversity policy but it would be good to provide a spatial reference in the plan.

Policy CO3: Improving Sports and Recreation Provision
(v) increasing access to the countryside by promoting improvements to the rights of way network, especially around the urban areas, particularly in reference to Pebsham Countryside Park;
This section of the policy above is welcome with improvement of access to the countryside from the urban area.

Policy CO3(vi) giving particular support for water-based recreation along the coast near Camber Sands and Bexhill, and at Bewl Water.
Section (vi) needs to incorporate sensitive recreation in-order to protect the biodiversity interest of these sites and the integrity of the N2K sites and SSSI. Again these issues are touched on in the supporting text but not translated in the policy.

Policy LHN6: Gypsies, Travellers and Travelling Showpeople Criteria
Site allocations will be made and/or planning permission granted for Gypsy, Traveller and Travelling Showpeople sites, when all of the following criteria are met:
(i) The site is not located in a nature conservation designated area, in an area at risk from flooding (flood zones 3a & 3b or a functional floodplain), in close proximity to a Source Protection Zone or significantly contaminated land;
(ii) The site should not result in an unacceptable visual or landscape impact, especially in the High Weald AONB taking account of proposed landscaping or screening;
Natural England supports the above policy and in the additional point (i) this should include the functional land that is integral to the Natura 2000 sites in that area of the Romney Marsh.
Functional land is areas of land that overwintering birds use outside the boundaries of the designated site and are therefore functionally related to the site. We can provide more detail on these areas.

Perhaps the role of environmental stewardship could be mentioned in the supportive text of this policy. Environmental Stewardship is an agri-environment scheme that provides funding to farmers and other land managers in England to deliver effective environmental management on their land.
Funding and advice through Environmental Stewardship is helping land managers to conserve, enhance and promote the countryside by:
■ looking after wildlife, species and their many habitats;
■ ensuring land is well managed and retains its traditional character;
■ protecting historic features and natural resources;
■ ensuring traditional livestock and crops are conserved; and
■ providing opportunities for people to visit and learn about the countryside.
Underlying these benefits, Environmental Stewardship is helping the natural environment to adapt to climate change, for example, by reducing greenhouse gas emissions, providing and protecting carbon storage, and helping to manage flooding.
These agri-environment schemes provide crucial financial support to help landowners in the sustainable management of their land both within the designated sites and outside. There are a substantial number of agreements in the Rother areas, around 40 - 50 agri-environment schemes, across the wider area of Romney Marsh, Walland Marsh, Pett Levels and Brede Valley alone. A core element of Natural England‟s work is setting up new schemes

Policy RA3: Development in the Countryside
Proposals for development in the countryside will be determined on the basis of:
(iii) allowing the creation of new dwellings in extremely limited circumstances,
including:
(a) agricultural dwellings in accordance with PPS7 Annex A;
(b) the conversion of traditional historic farm buildings in accordance with Policy RA4;
(c) the one-to-one replacement of an existing dwelling of similar landscape impact; or
(d) as a 'rural exception site' to meet an identified local affordable housing need as elaborated upon in Chapter 15 - Local Housing Needs;
(iv) ensuring that extensions to existing buildings and their residential curtilages, and other ancillary development such as outbuildings, fences, enclosures, lighting and signage, would maintain and not compromise the character of the countryside and landscape;
(v) ensuring that all development in the countryside is of an appropriate scale, will not adversely impact on the on the landscape character or natural resources of the countryside and, wherever practicable, support sensitive land management.
Any new dwelling, extension, conversion in the countryside (as mentioned in iii and iv) has the potential to impact on protected species, sites or habitats and provide an opportunity for biodiversity gain, therefore all these proposals should be referred to and considered in accordance to the last bullet point (v) found in Policy RA4 together with our comments on additional text which are set out below.
Bullet (v) needs to be more explicit about natural resource, either define this in the supporting text or in the policy, we are assuming this covers designated sites but is unclear.

Policy RA4: Traditional Historic Farm Buildings
Traditional historic farm buildings will be retained in effective and appropriate use, and proposals for their reuse and/or subsequent alteration should:
(iv) Ensure proper protection of existing wildlife and habitats.
We are assuming that existing wildlife refers to protected species that may be present in the building or using the site, therefore we would suggest either including protected species in the bullet point or in the supporting text, and this bullet should not only cover their protection but enhancement of species and supporting habitats.

Policy EC6: Tourism Activities and Facilities
Proposals relating to tourism activities and facilities
This policy requires the key addition of how tourism activities and facilities will be managed in terms of pressure on the environment and particularly the Dungeness/Rye Bay / Romney Marsh suite of internationally designated sites. As mentioned, in the supporting text for this policy, the Rye Harbour section (10), the chapter on the environment (17) all require refer as to how tourism pressure will be managed to ensure no adverse impacts on the sites this needs to be translated into policy not just supportive text.