Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27367

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy LAN3: Dark Skies
This policy is supported. Dark Skies are identified in the High Weald Management Plan as a key character
component of the natural beauty of the High Weald, and this policy’s emphasis on the avoidance of the
negative effects of light pollution on wildlife and landscape character is welcomed, as is the policy’s
specific reference to the dark skies of the High Weald National Landscape.

Comment

Representation ID: 27368

Received: 22/07/2024

Respondent: High Weald AONB Unit

We also note that the matter of Ancient Woodland is covered not in LAN2, but instead in Proposed
Policy ENV5: Habitats and Species. Whilst we understand why this may have been considered the
appropriate location, we consider that this will lead to confusion for users of the Local Plan, and we
advise that parts vi) and vii of ENV5 be relocated to LAN2, along with explanatory text paras 11.54 –
11.57 inclusive, in order that all consideration relating to trees and woodland are in one place in the
Plan.

Comment

Representation ID: 27369

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy ENV7: Environmental Pollution
We note that this policy understandably contains refences to lighting; however, in some ways the
supporting text to this policy this duplicates much of Proposed Policy LAN3: Dark Skies and its
supporting text, and in some instances is inconsistent with that policy; e.g. supporting text para 11.84
– zone E1 applies to all the HWNL, not just areas outside development boundaries, and that
paragraph needs amending accordingly. We consider the supporting text here relating to lighting
needs rationalising to avoid duplication, for example by primarily directing readers back to the
supporting text for LAN3, and by deleting paras 11.81, 11.83, 11.84 and 11.85, potentially
incorporating elements of those paras into the supporting text for LAN3 where appropriate.

Comment

Representation ID: 27370

Received: 22/07/2024

Respondent: High Weald AONB Unit

Proposed Policy HER1: Heritage Management
We are generally supportive of this policy however, there are a couple of additions we would wish to see:
The High Weald AONB Management Plan includes a specific Objective with the ‘Settlement’ key
character component of natural beauty, Objective S3 - To conserve the distinct built heritage of the
High Weald. In this regard, we would like to see a reference to the role historic environment in the
The High Weald Joint Advisory Committee is a partnership between: East Sussex, West Sussex, Kent and Surrey County Councils; Horsham, Mid Sussex,
Tandridge, Sevenoaks, Wealden and Rother District Councils; Tunbridge Wells, Hastings, Ashford, Crawley and Tonbridge & Malling Borough Councils;
Defra; and organisations representing farming, forestry, community, business and recreation interests.
High Weald National Landscape included in the supporting text, suggested additional text at end of
supporting para 12.3:
“, and to the natural beauty of the High Weald National Landscape.”
Also, AONB Management Plan objective S3 (referred to above) includes specific mention of the
historic public realm in the High Weald. As suggested in comments above, we consider part xii of
LWL7 might be better re-located to within HER1, and expanded to suggested text:
“Regard should be had to the conservation of historic public realm features as nondesignated heritage assets, which cumulatively contribute to the rural landscape character
particularly within the High Weald National Landscape”
To support this, we would wish to see specific reference, in the explanatory text, to the historic public
realm as an important part of the historic environment, suggested text:
“The historic public realm across the High Weald is identified in the AONB Management
Plan as playing an important role in defining the rural landscape character of the HW
National Landscape. Historic features such as locally distinctive paving, railings, lamp-posts,
milestones and historic fingerpost signs, along with red telephone kiosks and letterboxes,
contribute positively to the character of the rural public realm.”

Comment

Representation ID: 27371

Received: 22/07/2024

Respondent: High Weald AONB Unit

Other General Comments
It is noted that in a few instances, policies might helpfully cross-reference other policies in the plan,
for example,
• bullet point (vi) of Proposed Policy HOU5: Rural Exception Sites might helpfully cross-refer to
Policy GTC9: High Weald National Landscape (AONB) for relevant sites,
• Proposed Policy ECO5: Tourism Activities, Facilities and Accommodation – should include
reference to other policies, including GTC9 for relevant sites, and to ECO8.
• Proposed Policies EN07 and EN08 should include reference to GTC9 for relevant sites.