Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Policy DEN4:
A positive approach to biodiversity is welcomed. However, we feel that the policy needs to be revised:
* In (ii) the aim should be to prevent a net loss of biodiversity, not 'avoid significant
harm'.
* The wording of sub-section (iii) strengthened from "...all developments will be
expected to retain and enhance biodiversity..." to "...all developments must retain
and enhance biodiversity...".
* To ensure that a comprehensive network of habitats is maintained. To help this
aim, sub-section (iv) should seek that Green Infrastructure (GI) strategies for
individual developments link into the GI strategy for the district.
* To contribute to the protection, management and enhancement of biodiversity.
* To make a positive contribution to biodiversity, through the restoration and
enhancement of existing habitats, as well as the creation of new ones.
* To maintain existing green spaces and provide alternative equivalent where
appropriate.
* Proposals which have an adverse impact on bio or geodiversity or green spaces,
which cannot be adequately avoided, mitigated or compensated for, will be
refused.

It would also be appropriate to cross reference the policy to the Green Infrastructure
background paper and the need for all developments to undertake biodiversity
surveys if they meet the criteria set out. Currently a lot of smaller developments do
not submit surveys in the first instance and rely on the planning officers to pick this
up. The Council's Validation Checklists should be reviewed to ensure that this is
picked up at validation rather than later when the 'clock is ticking'.

Access to the Countryside and green spaces need to be protected.

Sustainable Urban Drainage Systems (SUDS)
Policy DEN5:

Needs adding to with the following:
* Should take account of the one in 10 year six-hour storm event, plus 30%
allowance for climate change to ensure no flooding of properties or public highway, or inundation of foul sewerage system.
* Any excess of flows to be contained within the site boundary.
* SUDS should be designed to ensure there is no flooding in a one in 30 year storm
event.
* Where ground infiltration is feasible and developers want to use it, developers to
provide minimum six months groundwater monitoring within the winter period.
(These ideas from the South Downs Draft Local Plan).

Policy DEN7

The policy refers to "...adverse impacts on health, local amenities or environment
character...". This is slanted towards human issues but the thresholds for many species and habitats are often lower than those for human health. The wording should be amended to ensure that it is clear that species and habitats are also included e.g. add biodiversity to the list.

The Policy does not deal with development on contaminated land - it should, for
example, encourage development and re-use of contaminated land, provided
accompanied by a complete survey and plan for remedial measures.

It should be noted that the document 'Planning Noise Advice Document: Sussex' is
effectively out of date, as it does not take account of either BS 8233 2014 'Sound
Insulation and Noise Reduction for Buildings - Code of Practice', which supersedes the 1999 guidance, or BS 4142:2014 'Methods for rating and assessing industrial and commercial sound', which supersedes the 1997 guidance. The impact - if any - of these updated documents on the proposed policy still requires assessing by RDC.

Viewing this site on the government's Magic mapping system would indicate that while the land may be in a poor condition parts are listed as ancient woodland and priority habitats. It is therefore essential that it is clearly set how the economic reasons outweighs the loss of ancient woodland in accordance with the provisions of the NPPF. Given the size of the developments it is unlikely that they are essential for the aims and objectives of the Local Plan and there are alternatives that would not result in the loss of ancient woodland.

Viewing this site on the government's Magic mapping system would indicate that while the land may be in a poor condition parts are listed as ancient woodland and priority habitats. It is therefore essential that it is clearly set how the economic reasons outweighs the loss of ancient woodland in accordance with the provisions of the NPPF. Given the size of the developments it is unlikely that they are essential for the aims and objectives of the Local Plan and there are alternatives that would not result in the loss of ancient woodland.

This seems like a good idea. Has consideration been given to the status of much of the area being ancient woodland in drawing up the plan?

BRO2 - Land south of the Rainbow Trout, Broad Oak

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

CAT1 - Land to the rear of the White Hart, Catsfield

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

HUR1 - Land off Foundry Close, Hurst Green

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

The stream and hedgerow between the two fields could be used as the basis of a green corridor within the site and suitably buffered could provide some valuable habit.

IDE1 - Land south of Elmsmead, Iden

While the policy mentions the pond to the east being retained, the aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to accommodate the biodiversity on site. It is suggested that the policy be amended to highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

The pond could also be incorporated into a SUDS strategy for the site to increase the
area of wetland habitat.