Proposed Submission Development and Site Allocations (DaSA) Local Plan

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy DRM1: Water Efficiency

Representation ID: 24328

Received: 07/12/2018

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Rother District Council - Proposed Submission Rother District Development and Site Allocations (DaSA) Local Plan
Thank you for consulting us on the above Local Plan document.
We have reviewed the DaSA and overall we are pleased that our comments on the previous iteration of this document have been considered and taken on board. As such we consider the document "Sound" subject to some minor amendments for clarification purposes.

Part A: Development Policies
2. Resource management, Water Efficiency
Policy DRM1: Water Efficiency (Page 20)
We are disappointed not to see requirements for water efficiency measures for commercial developments. We would expect to commercial developments required to meet BREEAM "excellent" or "very good" as a minimum. Other councils including Rother's neighbour Folkestone and Hythe have policies requiring such suggested standards. We would query why the LPA has seen fit not to mention BREEAM standards.

We hope you find our comments useful. If you have any queries, please do not hesitate to contact me.

Full text:

Rother District Council - Proposed Submission Rother District Development and Site Allocations (DaSA) Local Plan
Thank you for consulting us on the above Local Plan document.
We have reviewed the DaSA and overall we are pleased that our comments on the previous iteration of this document have been considered and taken on board. As such we consider the document "Sound" subject to some minor amendments for clarification purposes.

Part A: Development Policies
2. Resource management, Water Efficiency
Policy DRM1: Water Efficiency (Page 20)
We are disappointed not to see requirements for water efficiency measures for commercial developments. We would expect to commercial developments required to meet BREEAM "excellent" or "very good" as a minimum. Other councils including Rother's neighbour Folkestone and Hythe have policies requiring such suggested standards. We would query why the LPA has seen fit not to mention BREEAM standards.

We hope you find our comments useful. If you have any queries, please do not hesitate to contact me.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy DEN4: Biodiveristy and Green Space

Representation ID: 24329

Received: 07/12/2018

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

6. Environment, Biodiversity and green space
Policy DEN4: Biodiversity and Green Space (Page 85)

We are satisfied that our previous comments have largely been acknowledged and amended within the current version of the plan. However, in amending Policy DEN 4 reference to protected species has been lost. Including protected species in the list of biodiversity features in DEN 4 (ii) would secure the requirements made in paragraph 6.43. We would recommend reference to protected species is reintroduced to this policy?

Full text:

6. Environment, Biodiversity and green space
Policy DEN4: Biodiversity and Green Space (Page 85)

We are satisfied that our previous comments have largely been acknowledged and amended within the current version of the plan. However, in amending Policy DEN 4 reference to protected species has been lost. Including protected species in the list of biodiversity features in DEN 4 (ii) would secure the requirements made in paragraph 6.43. We would recommend reference to protected species is reintroduced to this policy?

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy DEN7: Environmental Pollution

Representation ID: 24330

Received: 07/12/2018

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

6. Environment, Environmental pollution

Section 6.78 (Page 95) and Section 6.96 Contaminated Land (Page 98) and Policy DEN7: Environment Pollution (Page 99)

Please be advised that reference to contaminated land should be changed to say "Land Contamination". Contaminated Land has a specific definition under the Environment Act 1990 Part IIA Regulations. Environment Agency Orchard House Endeavour Park, London Road, Addington, West Malling, Kent, ME19 5SH Customer services line: 03708 506 506 Email: enquiries@environment-agency.gov.uk www.gov.uk/environment-agency

Full text:

6. Environment, Environmental pollution

Section 6.78 (Page 95) and Section 6.96 Contaminated Land (Page 98) and Policy DEN7: Environment Pollution (Page 99)

Please be advised that reference to contaminated land should be changed to say "Land Contamination". Contaminated Land has a specific definition under the Environment Act 1990 Part IIA Regulations. Environment Agency Orchard House Endeavour Park, London Road, Addington, West Malling, Kent, ME19 5SH Customer services line: 03708 506 506 Email: enquiries@environment-agency.gov.uk www.gov.uk/environment-agency

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy RHA2: Harbour Road Employment Area

Representation ID: 24331

Received: 07/12/2018

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

11. Villages with site allocations, Rye Harbour
Policy RHA2: Harbour Road Employment Area (Page 248)
This policy needs to reference the requirement for surface water drainage and foul provision agreements. The drainage at Rye harbour road is an issue with regards adequate sewer provision and surface water drainage due to contamination, so this should be included as a requirement as it is on other allocation sites for different reasons, i.e. high water tables etc.

We strongly support the inclusion of the text "the provision of an overarching foul drainage strategy, in conjunction with Southern Water" in all the other identified allocations.

Full text:

11. Villages with site allocations, Rye Harbour
Policy RHA2: Harbour Road Employment Area (Page 248)
This policy needs to reference the requirement for surface water drainage and foul provision agreements. The drainage at Rye harbour road is an issue with regards adequate sewer provision and surface water drainage due to contamination, so this should be included as a requirement as it is on other allocation sites for different reasons, i.e. high water tables etc.

We strongly support the inclusion of the text "the provision of an overarching foul drainage strategy, in conjunction with Southern Water" in all the other identified allocations.

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