Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
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Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 1: Do you have any comments on the supporting Sustainability Appraisal (SA/SEA) that is published alongside this document?
Representation ID: 23522
Received: 20/02/2017
Respondent: East Sussex County Council
Waste Planning
Objective 16 of the Sustainability Appraisal is to "Reduce waste generation and disposal, and achieve the sustainable management of waste." The objective and baseline only make reference to Household waste and the Joint Waste Management Contract. There does not appear to be any reference to Commercial & Industrial or Construction, Demolition or Excavation Waste which accounts for approximately three quarters of the tonnage of the waste generated within the County. In DaSA preparation, consideration should be given to the potential waste generated in all forms, noting the link between Household and Commercial & Industrial waste management.
Waste Planning
Sustainability Appraisal
Objective 16 of the Sustainability Appraisal is to "Reduce waste generation and disposal, and achieve the sustainable management of waste." The objective and baseline only make reference to Household waste and the Joint Waste Management Contract. There does not appear to be any reference to Commercial & Industrial or Construction, Demolition or Excavation Waste which accounts for approximately three quarters of the tonnage of the waste generated within the County. In the preparation of the DaSA consideration should be given to the potential waste generated in all forms, noting the link between Household and Commercial & Industrial waste management.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?
Representation ID: 23523
Received: 20/02/2017
Respondent: East Sussex County Council
Waste Management
Policy HAS5: Combe Valley Countryside Park
In the vicinity of the Waste Transfer Station, our view is that the area of hardstanding directly east of the compressor and workshop containers and west of Freshfields should be excluded from the Country Park. The compressor and workshop containers will be situated here for many decades (for as long as leachate requires management) and the area is currently required for staff and contractor parking and major servicing of plant and machinery.
NB If required a location plan can be provided to ensure that the correct area of land is identified.
Waste Management
Policy HAS5: Combe Valley Countryside Park
In the vicinity of the Waste Transfer Station, our view is that the area of hardstanding directly east of the compressor and workshop containers and west of Freshfields should be excluded from the Country Park. The compressor and workshop containers will be situated here for many decades (for as long as leachate requires management) and the area is currently required for staff and contractor parking and major servicing of plant and machinery.
NB If required a location plan can be provided to ensure that the correct area of land is identified.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?
Representation ID: 23524
Received: 20/02/2017
Respondent: East Sussex County Council
Flood Risk Management
We are concerned that the evidence base for the assessment of flood risk is not well documented. The SA makes reference to assessments and a Strategic Flood Risk Assessment (2008) but there is no up-to-date report setting out the evidence base. We are aware that the District Council has undertaken flood risk assessments on some sites as we have provided advice. For the Lead Local Flood Authority, to be reassured that local flood risk has been appropriately assessed in the context of proposed site allocations, the District Council should provide the necessary evidence to support the DaSA.
Flood Risk Management
Strategic Flood Risk Assessments
As an initial comment we are concerned that the evidence base for the assessment of flood risk is not well documented. The Sustainability Appraisal makes reference to assessments and a Strategic Flood Risk Assessment conducted in 2008 but there is no up to date report setting out the evidence base and analysis. We are aware that the District Council has undertaken flood risk assessments on some sites as we have provided advice to District Council officers. For the Lead Local Flood Authority (East Sussex County Council - ESCC) to be reassured that local flood risk has been appropriately assessed in the context of proposed site allocations across the plan area, the District Council should provide the necessary evidence prior to, or when the Pre-Submission version of the DaSA is published.
We are happy to work with District Council on these matters and suggest that we meet shortly after the consultation has closed to discuss these matters in detail.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?
Representation ID: 23525
Received: 20/02/2017
Respondent: East Sussex County Council
Flood Risk Management
The policy approach taken is supported, subject to the following comments:
Para 10.65-replace "is likely to be" with "will be"
Para 10.66-replace "Where relevant" with "Wherever possible"
New Para-introduce new text which sets out the policy objective of "daylighting" culverts as part of the development process in order to manage flood risk - this aligns with the objectives of the East Sussex Local Flood Risk Management Strategy.
Policy DEN5 is supported but an additional criterion is requested which identifies the need to manage the flood risk impacts of the construction phase of development on the sub catchment.
Flood Risk Management
Sustainable Drainage page 99
The policy approach taken by the District Council is supported by the Lead Local Flood Authority (ESCC), subject to the following comments:
Para 10.65 - replace "is likely to be" with "will be"
Para 10.66 - replace "Where relevant" with "Wherever possible"
New Para - introduce new text which sets out the policy objective of "daylighting" culverts as part of the development process in order to manage flood risk - this aligns with the objectives of the East Sussex Local Flood Risk Management Strategy.
Policy DEN5 is supported but an additional criterion is requested which identifies the need to manage the flood risk impacts of the construction phase of development on the sub catchment.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 94: Do you agree with the recommendation regarding the development boundary at Brede and Cackle Street? If not, please explain how you wish the development boundary to be applied to this sett
Representation ID: 23526
Received: 20/02/2017
Respondent: East Sussex County Council
Flood Risk Management
Section 16 Other Villages with Development Boundaries in the 2006 Local Plan p317
We support the review of development boundaries in light of environmental constraints and risks and their removal where it is considered appropriate on sustainability grounds.
Flood Risk Management
Section 16 Other Villages with Development Boundaries in the 2006 Local Plan p317
We support the review of development boundaries in light of environmental constraints and risks and their removal where it is considered appropriate on sustainability grounds.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 1: Do you have any comments on the supporting Sustainability Appraisal (SA/SEA) that is published alongside this document?
Representation ID: 23527
Received: 20/02/2017
Respondent: East Sussex County Council
Landscape
SUSTAINABILITY APPRAISAL/STRATEGIC ENVIRONMENTAL ASSESSMENT (SA/SEA) Page 16
The SEA fully covers the landscape issues and opportunities for the district and the landscape policy context.
Landscape
SUSTAINABILITY APPRAISAL/STRATEGIC ENVIRONMENTAL ASSESSMENT (SA/SEA) Page 16
The SEA fully covers the landscape issues and opportunities for the district and the landscape policy context.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?
Representation ID: 23528
Received: 20/02/2017
Respondent: East Sussex County Council
Landscape
This would need to be subject to assessment of the characteristics of a particular landscape area and a sensitivity/capacity assessment of that landscape to absorb this development. The open levels/river valleys and undeveloped coastal areas would be very sensitive visually and in landscape character. The AONB would be sensitive but the more heavily wooded and rolling topographical areas may have capacity. Much of the district is tranquil and relatively remote from disturbance and wind farm developments detract from remoteness. The light industrial urban edges of Hastings may have potential and existing light industrial areas along the Bexhill/Bulverhythe coast.
Landscape
RESOURCE MANAGEMENT Page 23
QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?
This would need to be subject to an assessment of the characteristics of a particular landscape area and a sensitivity/capacity assessment of that landscape to absorb this type of development. The open levels and river valleys and undeveloped coastal areas would be very sensitive visually and in landscape character. The Area of Outstanding Natural Beauty (AONB) would be sensitive but the more heavily wooded and rolling topographical areas may have capacity. Much of the district is tranquil and relatively remote from disturbance and wind farm developments detract from remoteness. The light industrial urban edges of Hastings may have some potential and existing light industrial areas along the Bexhill/Bulverhythe coast.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?
Representation ID: 23529
Received: 20/02/2017
Respondent: East Sussex County Council
Landscape
RESOURCE MANAGEMENT Page 23
There are opportunities, especially in existing light industrial areas. There would be significant benefits if this would promote the sustainable management of the extensive woodland in the district, much of which is ancient and lacks positive coppice management.
Landscape
RESOURCE MANAGEMENT Page 23
There are opportunities, especially in existing light industrial areas. There would be significant benefits if this would promote the sustainable management of the extensive woodland in the district, much of which is ancient and lacks positive coppice management.
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?
Representation ID: 23530
Received: 20/02/2017
Respondent: East Sussex County Council
COMMUNITIES Page 29
Yes
COMMUNITIES Page 29
Yes
Comment
Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options
QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?
Representation ID: 23531
Received: 20/02/2017
Respondent: East Sussex County Council
Landscape
HOUSING Page 35
Yes
Landscape
HOUSING Page 35
Yes
