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

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Comment

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

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

Representation ID: 23369

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

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: 23370

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

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: 23371

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

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: 23372

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside. We highlight part of paragraph 7.16: 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining for clarity.
We are concerned about equestrian developments being proposed on designated sites. Therefore we welcome more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per NPPF section 165.

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: 23374

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

Creative approaches and orientation should be considered when designing external spaces.

While bullet point (i) gives clarity to the external spaces, there is a lack of commitment to the amount of space need for flat and complex developments.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF (para 109).

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF (para.118).

Comment

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

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

Representation ID: 23375

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

Comment

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

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed cies? If not, what changes would you wish to see?

Representation ID: 23376

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

Comment

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

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

Representation ID: 23377

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

Comment

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

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Representation ID: 23378

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

Supporting text (10.19-10.21) does not indicate reasons for the exclusion of the area of existing Bexhill and Hastings/St Leonards gap to be removed.
The council should consider the value of the gaps in harnessing natural capital. We suggest this is reflected in policy wording:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'
This wording will reflect the importance of strategic gaps for ecosystems service delivery and compliance with NPPF.

Comment

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

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

Representation ID: 23379

Received: 20/02/2017

Respondent: Sussex Wildlife Trust

Representation Summary:

The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed.

Part ii - the word 'significant' should be removed.

Part iii - should look to reflect the sentiments of the NPPF section 109.

Part iv: We are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings.

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