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

NOR1 - Land to the south of Northiam Church of England Primary School

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.

RHA1 - Land at Stonework Cottages, Rye Harbour

The policy mention that there should be no harm to Rye Harbour SSSI. However, the site is in fact adjacent to Dungeness, Romney Marsh and Rye Bay SSSI, Special Protection Area (SPA) and Wetland of International Importance under the Ramsar Convention (Ramsar Site). While there are no scrub or grassland habitats on site there is still a possibility that the site may contain species that are notified features of these designated sites. Appropriate surveys need to be carried out.

WES1 - Land at Westfield Down, Westfield

It is positive that a large area has been set aside for recreational use. However, if this area was considered on a multi-functional basis biodiversity enhancements could be made that would not interfere with the recreational use. For example the margins to the field could be maintained with flower rich grasses. This would be in line with the aims of Policy DEN4: Biodiversity and Green Space.

WES2 - Land at Moorhurst Care Home, Westfield

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.

WES3 - Land off Goulds Drive, Westfield

It is noted that the boundaries are to be protected to enhance ecological networks,
However, 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.

Four comments:

1.Item 3.2.17 of the SA main document, relating to Deprivation, states: 'Almost 9% of Rother households are classed as being in fuel poverty, which is low compared to
England & Wales, but high compared to the wider county and region'. Could RDC
provide more information, with specific numbers relating to England & Wales, the county and the region. This would better help in understanding to what extent this may be a RDC area issue, why this is and what solutions are being proposed. We have looked for the answer in the background information but it is not clear.

2.SA Objective 11, page 65 of SA Appendices 1 & 2, shows the mean average annual gas and electricity consumption in the industrial and commercial sector. The figure for Rother in 2014 was 824,053 kWh, which is almost double the East Sussex figure of 418,633 kWh and the South East figure of 443,867 kWh. Is there an explanation as to why Rother's figure is so much higher and is it an issue that RDC should seek to address?

3.It is noted generally that many of the data sets date back to 2010 or before and are therefore in need of updating. The 'concentration of air pollutants' (SA Objective 10) for instance is based on 2005 data, now more than 11 years ago. With the increase in diesel cars air pollution in many cities has been getting worse, which is contrary to previous assumptions that air pollution will improve as cars got cleaner.

4. We have looked at the matrix to see how it rates the various policies against
biodiversity and the environment and we do not agree with a number of the ratings given and these would need further investigation.

a. The following site allocations could potentially have a negative impact on biodiversity due to the possible presence of protected species (scrub and rough grassland habitats) but there does not appear to be provision for them on site (they are mainly shown as neutral):
HAS2
BRO1 - showing as positive but probably negative
BRO2
CAT1
HUR1
IDE1
NOR1
RHA1
WES2
WES3
b. CAM1 and 2 are showing as positive but are more likely to be neutral unless there
are positive enhancements proposed which we could not see.

c. BEC2 - showing as negative but with the large amenity area it could have a positive impact if well designed and multi-functional.

d. RHA2 - showing as positive but no indication why. More likely to be neutral or even negative given that increased commercial use will mean more traffic and a deterioration in local air quality and the designated site habitats are sensitive to air pollution.

e. WES1 - as with BEC2 this could be positive if the recreation area is designed with
biodiversity and is multi-functional.

Four comments:

1.Item 3.2.17 of the SA main document, relating to Deprivation, states: 'Almost 9% of Rother households are classed as being in fuel poverty, which is low compared to
England & Wales, but high compared to the wider county and region'. Could RDC
provide more information, with specific numbers relating to England & Wales, the county and the region. This would better help in understanding to what extent this may be a RDC area issue, why this is and what solutions are being proposed. We have looked for the answer in the background information but it is not clear.

2.SA Objective 11, page 65 of SA Appendices 1 & 2, shows the mean average annual gas and electricity consumption in the industrial and commercial sector. The figure for Rother in 2014 was 824,053 kWh, which is almost double the East Sussex figure of 418,633 kWh and the South East figure of 443,867 kWh. Is there an explanation as to why Rother's figure is so much higher and is it an issue that RDC should seek to address?

3.It is noted generally that many of the data sets date back to 2010 or before and are therefore in need of updating. The 'concentration of air pollutants' (SA Objective 10) for instance is based on 2005 data, now more than 11 years ago. With the increase in diesel cars air pollution in many cities has been getting worse, which is contrary to previous assumptions that air pollution will improve as cars got cleaner.

4. We have looked at the matrix to see how it rates the various policies against
biodiversity and the environment and we do not agree with a number of the ratings given and these would need further investigation.

a. The following site allocations could potentially have a negative impact on biodiversity due to the possible presence of protected species (scrub and rough grassland habitats) but there does not appear to be provision for them on site (they are mainly shown as neutral):
HAS2
BRO1 - showing as positive but probably negative
BRO2
CAT1
HUR1
IDE1
NOR1
RHA1
WES2
WES3
b. CAM1 and 2 are showing as positive but are more likely to be neutral unless there
are positive enhancements proposed which we could not see.

c. BEC2 - showing as negative but with the large amenity area it could have a positive impact if well designed and multi-functional.

d. RHA2 - showing as positive but no indication why. More likely to be neutral or even negative given that increased commercial use will mean more traffic and a deterioration in local air quality and the designated site habitats are sensitive to air pollution.

e. WES1 - as with BEC2 this could be positive if the recreation area is designed with
biodiversity and is multi-functional.

Four comments:

1.Item 3.2.17 of the SA main document, relating to Deprivation, states: 'Almost 9% of Rother households are classed as being in fuel poverty, which is low compared to
England & Wales, but high compared to the wider county and region'. Could RDC
provide more information, with specific numbers relating to England & Wales, the county and the region. This would better help in understanding to what extent this may be a RDC area issue, why this is and what solutions are being proposed. We have looked for the answer in the background information but it is not clear.

2.SA Objective 11, page 65 of SA Appendices 1 & 2, shows the mean average annual gas and electricity consumption in the industrial and commercial sector. The figure for Rother in 2014 was 824,053 kWh, which is almost double the East Sussex figure of 418,633 kWh and the South East figure of 443,867 kWh. Is there an explanation as to why Rother's figure is so much higher and is it an issue that RDC should seek to address?

3.It is noted generally that many of the data sets date back to 2010 or before and are therefore in need of updating. The 'concentration of air pollutants' (SA Objective 10) for instance is based on 2005 data, now more than 11 years ago. With the increase in diesel cars air pollution in many cities has been getting worse, which is contrary to previous assumptions that air pollution will improve as cars got cleaner.

4. We have looked at the matrix to see how it rates the various policies against
biodiversity and the environment and we do not agree with a number of the ratings given and these would need further investigation.

a. The following site allocations could potentially have a negative impact on biodiversity due to the possible presence of protected species (scrub and rough grassland habitats) but there does not appear to be provision for them on site (they are mainly shown as neutral):
HAS2
BRO1 - showing as positive but probably negative
BRO2
CAT1
HUR1
IDE1
NOR1
RHA1
WES2
WES3
b. CAM1 and 2 are showing as positive but are more likely to be neutral unless there
are positive enhancements proposed which we could not see.

c. BEC2 - showing as negative but with the large amenity area it could have a positive impact if well designed and multi-functional.

d. RHA2 - showing as positive but no indication why. More likely to be neutral or even negative given that increased commercial use will mean more traffic and a deterioration in local air quality and the designated site habitats are sensitive to air pollution.

e. WES1 - as with BEC2 this could be positive if the recreation area is designed with
biodiversity and is multi-functional.

Rother is one of the most wooded areas within England and therefore has a large
resource of biomass that could be exploited for wood-burners and small scale biomass boilers and Combined Heat and Power (CHP) plants. We would support any policies that encourage the use of this sustainable resource. Bringing back large areas of woodland into active management has the potential to be very positive to biodiversity as evidenced by the work of the Wildlife Trusts, Natural England, The Forestry Commission and the Butterfly Conservation Trust, all of which are actively working with landowners to this effect.

Planning policies should be put in place that not only encourage the householder e.g.
chimneys/flues on all new properties for wood burners; but also to make it easier for
landowners to set up wood fuel businesses e.g. buildings, storage facilities etc.

The current system of asking for all new developments over a certain size to explore the use of biomass / CHP does not seem to be working as developers tend to show that they are not viable. Often it is the public sector that has to lead the way and therefore it is suggested that all new public buildings of a minimum size should have a system installed. This would kick start a local market for fuel. Consideration should also be given to retro-fitting existing public assets. Swimming pools would be a prime target as they have a year round need for heat.

The policy wording for larger developments to 'consider' biomass is not strong enough. There is a need for a proper viability analysis to be undertaken and for RDC to employ their own consultants to review rather than accepting the results.

In conclusion, there is a need to strengthen use of biomass as suitable for smaller
developments and public buildings so that this form of energy is given more serious
consideration.

It should also be borne in mind that adequate insulation saves more energy than can be generated by householders. It is essential therefore that the highest standards are sought.



6.20 Comments on solar paragraph as no question for response

There needs to be a DRM2- to encourage where appropriate wind and solar, and to
make solar mandatory on all commercial and industrial buildings; and any application to alter/extend industrial building needs to carry an obligation to fit rooftop solar.

Encourage:
* Solar thermal panels for "family" properties.
* Community solar schemes.

The National Grid needs updating so that the above average generation rates achieved within Rother can be utilised fully. In the meantime, where there are grid problems, smart meters should allow neighbours to share.

Could RDC council monies be used to improve the grid?

The document from Maidstone BC which in turn was borrowed from Cornwall CC and
Ashford BC gives detailed guidance and it would be helpful for RDC to provide similar
guidance:

Reference; Maidstone Borough Council: Planning Policy Advice Note:
Domestic and Medium scale solar PV arrays (up to 50kw) and solar thermals
Jan 2014

Items 6.21 & 6.22 of the DaSA are deeply flawed. The 'unduly onerous' (para 6.22) is dubious to whom? Any developer will always say such is 'unduly onerous'. CS SRM(i) does not contain a target for energy reduction proposals. Without, such it is not effective. Target should be to cut predicted C02 emissions by the equivalent of 20% over and above what current building regulations require.

The validation checklist referred to in paragraph 2.21 of the Renewable Energy
background paper is inadequate and in urgent need of updating. Other local authorities, such as Maidstone Borough Council, include the following condition for ALL new build houses (threshold 1 dwelling): 'Prior to any development above damp proof course level, details of proposed renewable energy sources shall be submitted to and approved in writing by the local planning authority. The approved details shall be implemented prior to the first occupation of any dwelling.' This clearly demonstrates that RDC can, if it so chooses, impose much tighter and binding rules, for ALL new build development. The difficulty in applying the current policy is due to a lack of will by RDC. As it is, rather than relaxing Core Strategy Policy SRM1, it should be tightened.

Reference: RDC Development and Site Allocation Local Plan, Renewable and Low
Carbon Energy - Background Paper. November 2016
Examples of criteria RDC should be setting:

* Are as many as possible of the sloping roofs oriented as much as possible to the
South and West in order to be fitted with solar panels?

* Are locations for solar panels included in the design of the roofs - even if not
fitted?
* Where solar panels can be fitted have you considered providing space in the
dwelling for batteries?
* Are heat pumps being considered?
* If so have you included in the design suitable locations for them?
* Have you considered installing under floor heating?
* Are electric charging points being included for electric vehicles?
* All new commercial and industrial roofs over (100) sq. m. must install solar panels
on south or south west facing roofs.
* All new developments should consider specific on-site positioning to maximise the
possibility of installing solar roof panels and for increasing passive solar gain.

6.23 Praise to RDC for this clause as this applies to every development/dwelling.

Rother is one of the most wooded areas within England and therefore has a large
resource of biomass that could be exploited for wood-burners and small scale biomass boilers and Combined Heat and Power (CHP) plants. We would support any policies that encourage the use of this sustainable resource. Bringing back large areas of woodland into active management has the potential to be very positive to biodiversity as evidenced by the work of the Wildlife Trusts, Natural England, The Forestry Commission and the Butterfly Conservation Trust, all of which are actively working with landowners to this effect.

Planning policies should be put in place that not only encourage the householder e.g.
chimneys/flues on all new properties for wood burners; but also to make it easier for
landowners to set up wood fuel businesses e.g. buildings, storage facilities etc.

The current system of asking for all new developments over a certain size to explore the use of biomass / CHP does not seem to be working as developers tend to show that they are not viable. Often it is the public sector that has to lead the way and therefore it is suggested that all new public buildings of a minimum size should have a system installed. This would kick start a local market for fuel. Consideration should also be given to retro-fitting existing public assets. Swimming pools would be a prime target as they have a year round need for heat.

The policy wording for larger developments to 'consider' biomass is not strong enough. There is a need for a proper viability analysis to be undertaken and for RDC to employ their own consultants to review rather than accepting the results.

In conclusion, there is a need to strengthen use of biomass as suitable for smaller
developments and public buildings so that this form of energy is given more serious
consideration.

It should also be borne in mind that adequate insulation saves more energy than can be generated by householders. It is essential therefore that the highest standards are sought.



6.20 Comments on solar paragraph as no question for response

There needs to be a DRM2- to encourage where appropriate wind and solar, and to
make solar mandatory on all commercial and industrial buildings; and any application to alter/extend industrial building needs to carry an obligation to fit rooftop solar.

Encourage:
* Solar thermal panels for "family" properties.
* Community solar schemes.

The National Grid needs updating so that the above average generation rates achieved within Rother can be utilised fully. In the meantime, where there are grid problems, smart meters should allow neighbours to share.

Could RDC council monies be used to improve the grid?

The document from Maidstone BC which in turn was borrowed from Cornwall CC and
Ashford BC gives detailed guidance and it would be helpful for RDC to provide similar
guidance:

Reference; Maidstone Borough Council: Planning Policy Advice Note:
Domestic and Medium scale solar PV arrays (up to 50kw) and solar thermals
Jan 2014

Items 6.21 & 6.22 of the DaSA are deeply flawed. The 'unduly onerous' (para 6.22) is dubious to whom? Any developer will always say such is 'unduly onerous'. CS SRM(i) does not contain a target for energy reduction proposals. Without, such it is not effective. Target should be to cut predicted C02 emissions by the equivalent of 20% over and above what current building regulations require.

The validation checklist referred to in paragraph 2.21 of the Renewable Energy
background paper is inadequate and in urgent need of updating. Other local authorities, such as Maidstone Borough Council, include the following condition for ALL new build houses (threshold 1 dwelling): 'Prior to any development above damp proof course level, details of proposed renewable energy sources shall be submitted to and approved in writing by the local planning authority. The approved details shall be implemented prior to the first occupation of any dwelling.' This clearly demonstrates that RDC can, if it so chooses, impose much tighter and binding rules, for ALL new build development. The difficulty in applying the current policy is due to a lack of will by RDC. As it is, rather than relaxing Core Strategy Policy SRM1, it should be tightened.

Reference: RDC Development and Site Allocation Local Plan, Renewable and Low
Carbon Energy - Background Paper. November 2016
Examples of criteria RDC should be setting:

* Are as many as possible of the sloping roofs oriented as much as possible to the
South and West in order to be fitted with solar panels?

* Are locations for solar panels included in the design of the roofs - even if not
fitted?
* Where solar panels can be fitted have you considered providing space in the
dwelling for batteries?
* Are heat pumps being considered?
* If so have you included in the design suitable locations for them?
* Have you considered installing under floor heating?
* Are electric charging points being included for electric vehicles?
* All new commercial and industrial roofs over (100) sq. m. must install solar panels
on south or south west facing roofs.
* All new developments should consider specific on-site positioning to maximise the
possibility of installing solar roof panels and for increasing passive solar gain.

6.23 Praise to RDC for this clause as this applies to every development/dwelling.