Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27345

Received: 22/07/2024

Respondent: High Weald AONB Unit

The text in the yellow box on page 112 presently sets out that “The Council will meet the
local need for all forms of housing, jobs, facilities and services by….” However, we understand (and
support) that the draft Local Plan does not necessarily seek to fully meet the OAN figure in full, due to
the extent of the High Weald AONB, which makes up 82% of the district, and we consider the
wording should be amended to explain this. (For background context, para 11 (b) (i) of the NPPF
allows for strategic policies in Local Plans to provide for less than the OAN where the application of
other NPPF policies that protect areas or assets of particular importance provides a strong reason for
restricting the overall scale, type or distribution of development in the plan area. Footnote 7 confirms
that NPPF polices related to AONBs are in the list of such policies.)
It is noted that the Reg 18 draft Local Plan presently proposes a range of housing figures over the plan
period, and it is understood that the figure will be refined following consideration of the HELAA sites
post the Reg 18 consultation, which will inform the Reg 19 draft plan, and which we trust will take into
account any comments we subsequently submit on the HELAA sites in the context of the AONB. In this
regard, it is considered reference should be made in tables 35 and 36 in the draft Local Plan to
highlight that these figures are subject to further scrutiny in terms of consideration of impacts of
proposed HELAA sites on the High Weald AONB

Comment

Representation ID: 27346

Received: 22/07/2024

Respondent: High Weald AONB Unit

Document Structure
The ‘Green to the Core’ and ‘Live Well Locally’ priorities are strong and admirable themes, but we
consider it is a somewhat confusing for the reader/user of the Plan in terms of how certain policies
have been selected to sit within these two sections 3 and 4, while certain other associated polices are
left to other sections later in the document.
One suggestion to address this could be to slightly re-order the policies, using ‘Green to the Core’ and
‘Live Well Locally’ as umbrella themes, under which sub-headings sat; for example ‘Green to the
Core’ could have subheadings ‘Resource Management’ (which would include GTC1-GTC6 inclusive),
Landscape Character (which would include GTC9 plus LAN1 -LAN3 inclusive), Biodiversity (which
would include GTC7, GTC8, and ENV5) and Environmental Management (which would include policies
ENV1-ENV4, ENV6 and ENV7) – as well as giving greater clarity, this would also give greater weight to
the Green to the Core priority, promoting that all of these policies contribute to this.
Meanwhile ‘Live Well Locally’ could have subheadings ‘Placemaking’ (policies LWL1-LWL8 inclusive)
Heritage (policies HER1 – HER3 inclusive), Health & Wellbeing (policies HWB1-7 inclusive) and
‘Infrastructure’ (policies INF1, INF2).
This would leave existing sections 5 (Development Strategy & Principles), 8 (Housing), and 9
(Economy) as stand-alone sections which cross both the two priority themes.

Comment

Representation ID: 27348

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

Comment

Representation ID: 27349

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

Comment

Representation ID: 27350

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

Comment

Representation ID: 27351

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

‘Vision for Rye & Eastern Settlements’
We consider this vision statement should include the reference to the High Weald NL that other
‘Visions’ do (i.e. for Battle & for Northen Rother) – much of this vision area is within the HWNL, or
within its setting

Comment

Representation ID: 27352

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

‘Vision for Northen Rother’
We are concerned about the somewhat vague statement ‘bypasses to Flimwell and Hurst Green could
open up opportunities for future development along the A21 corridor.’ Any such proposals, both for bypasses and future development, would have the potential to impact significantly on the natural beauty
of the High Weald AONB. Certainly this statement should be qualified in the vision by the addition of
text such as ‘subject to careful consideration of impacts on the natural beauty of the High Weald
National Landscape….’ Moreover, as any potential for future development is as yet not assessed, it
may also be more appropriate to delete the reference to that, and instead focus the statement on the
role that such bypasses could play in achieving sustainable transport goals.

Comment

Representation ID: 27353

Received: 22/07/2024

Respondent: High Weald AONB Unit

‘Visions’
The Visions for spatial areas of the district, set out on pages 123-164, could benefit from some
explanatory/linking text showing how the various policies of the plan seek to achieve these visions.
For example, how the ‘Vision for the Countryside’ links to polices ECO5, EC07, ECO8 and GTC9.

Comment

Representation ID: 27354

Received: 22/07/2024

Respondent: High Weald AONB Unit

Policy GTC9: High Weald National Landscape (AONB)
This policy, and its references to the AONB Management Plan, is supported. It would be helpful if this
policy could be accompanied by a map showing the extent of the High Weald National Landscape
within Rother district.
In the explanatory text, the wording of para 3.51 could helpfully be expanded to clarify that both
policies will apply; suggested amended wording (in bold):
“It should also be noted that developments for housing, commercial, renewable energy, health
and well-being and tourism uses are the subject of additional separate policies in the Local
Plan, with the emphasis on locations outside of the High Weald National Landscape and,
where appropriate, within them on a small scale, in accordance with policy GTC9.”

Comment

Representation ID: 27355

Received: 22/07/2024

Respondent: High Weald AONB Unit

Policy GTC8: Biodiversity Net Gain
We would wish to see specific reference made to the High Weald AONB, suggested additional text:
“Within the High Weald AONB, BNG proposals should be informed by a robust
understanding of the habitat typologies and systems of the High Weald, in order that they
are designed to provide a genuine positive contribution to local biodiversity and habitats.
Proposed enhanced or new habitats should function as a meaningful part of the wider
connected High Weald habitat mosaic, with reference to the components of natural beauty
set out in the AONB Management Plan, and should support the Nature Recovery principles
set out in the AONB Management Plan.