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

Thank you for consulting the RSPB on the Rother District Council. We have reviewed the 'Development and Site Allocations Local Plan - Options and Preferred Options' and the accompanying Habitats Regulations Assessment and would like to make the following comments.

The RSPB does not wish to comment on individual site allocations or housing developments at this stage of the consultation, however, we advocate the planning of development to minimise its impact on designated sites for biodiversity. As the Plan acknowledges, Rother district is located in an area of high nature conservation value, with a significant number of Nature 2000 sites (Special Protection Areas (SPAs) and Special Areas of Conservation (SACs)) located within and adjacent to the District boundary. We should urge that the council would apply a high standard of protection to these sites as set out in the Habitat Regulation Assessments (HRA) and that robust assessments are carried out in relation to the housing developments that lie in proximity to internationally designated sites; Dungeness SAC, Pevensey Levels. Dungeness to Pett Level SPA, proposed SPA extension and Dungeness, Romney Marsh and Rye Bay proposed Ramsar site.

Dungeness to Pett Level SPA may be vulnerable to the effects of recreational pressure associated with increasing populations in the surrounding area. In order for the Plan to be found sound and for it satisfy the tests of the Habitats Regulations, it is therefore essential that measures are in place to protect these sites from the effects of the new housing development and other relevant development proposed by the Plan.

In the RSPB's view, a key requirement in the development of Rother Local Plan Site Allocations is the assessment of the possible impact on the Dungeness to Pett Level SPA and the inclusion of any mitigation that may be needed. We are aware of your current commitment to the survey work to develop a Sustainable Access Strategy to address the mitigation of increased recreation of disturbance by working with Shepway District Council, Natural England and other environmental interests, including the RSPB.

Thank you for involving us in this process. We would welcome your continued consultation throughout the plans development, to enable us to feed into this work and help to ensure its effectiveness. We would however urge a commitment to a time scale for the adoption of this Sustainable Access Strategy and clear agreement of its objectives to allow for monitoring to ensure effective protection of these sites.

Thank you for consulting the RSPB on this application.