Rother Local Plan 2020-2040 (Regulation 18)

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Comment

Rother Local Plan 2020-2040 (Regulation 18)

90. What are your views on the Council's approach to strategic gaps and those that are identified?

Representation ID: 25709

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports this policy.

Full text:

SWT supports this policy.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

92. What are your views on the Council's proposed policy on supporting health and wellbeing?

Representation ID: 25710

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

We support this policy, particularly point iii.

Full text:

We support this policy, particularly point iii.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

101. What are your views on the Council's proposed policy on green and blue infrastructure?

Representation ID: 25711

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports the inclusion of this policy.

Full text:

SWT supports the inclusion of this policy.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

106. What are your views on the Council's proposed policy on the Combe Valley Countryside Park?

Representation ID: 25712

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports this policy and particularly the requirement to deliver BNG within the park. The park is a valuable recreational resource to local communities and holds some very important places for wildlife that need to be protected and enhanced. In particular, the Countryside Park contains the Combe Haven SSSI which includes Sussex Wildlife Trust’s reserve Filsham Reedbed, the park also connects down through Glyne Gap LWS to the Bulverhythe Shingle Beach and Cliffs LWS.

Full text:

SWT supports this policy and particularly the requirement to deliver BNG within the park. The park is a valuable recreational resource to local communities and holds some very important places for wildlife that need to be protected and enhanced. In particular, the Countryside Park contains the Combe Haven SSSI which includes Sussex Wildlife Trust’s reserve Filsham Reedbed, the park also connects down through Glyne Gap LWS to the Bulverhythe Shingle Beach and Cliffs LWS.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

180. What are your views on the Council's proposed policy on trees, woodlands and hedgerows?

Representation ID: 25713

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports the inclusion of this policy. However, we would like to see explicit requirements related to ancient woodland and veteran trees rather than just mention in the supporting text. The policy must make it clear that development leading to loss or harm to ancient woodland and/or veteran trees will be refused. It should also be made clear that adequate buffers are required and that these must be clear of any development or ancillary infrastructure.

Full text:

SWT supports the inclusion of this policy. However, we would like to see explicit requirements related to ancient woodland and veteran trees rather than just mention in the supporting text. The policy must make it clear that development leading to loss or harm to ancient woodland and/or veteran trees will be refused. It should also be made clear that adequate buffers are required and that these must be clear of any development or ancillary infrastructure.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

184. What are your views on the proposed policy on water, coastal and flood risk management?

Representation ID: 25714

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports the inclusion of this policy. We would like to see encouragement of the use of nature-based solutions when it comes to flood risk and coastal management. We also recommend that applicants within the Pevensey Levels catchment are encouraged to undertake early discussions with the Pevensey and Cuckmere Water Level Management Board.

Full text:

SWT supports the inclusion of this policy. We would like to see encouragement of the use of nature-based solutions when it comes to flood risk and coastal management. We also recommend that applicants within the Pevensey Levels catchment are encouraged to undertake early discussions with the Pevensey and Cuckmere Water Level Management Board.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

186. What are your views on the proposed policy on sustainable drainage?

Representation ID: 25715

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports this policy and particularly the extra requirements in the Pevensey Levels catchment and the requirement for SuDs to be multifunctional.

Full text:

SWT supports this policy and particularly the extra requirements in the Pevensey Levels catchment and the requirement for SuDs to be multifunctional.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

191. What are your views on the Council's proposed policy on the Fairlight Cove Coastal Change Management Area?

Representation ID: 25716

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports the inclusion of this policy. We hope that any consideration of coastal erosion data includes the most up to date climate change assessments.

Full text:

SWT supports the inclusion of this policy. We hope that any consideration of coastal erosion data includes the most up to date climate change assessments.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

194. What are your views on the Council's proposed policy on sites protected for their habitats and species?

Representation ID: 25717

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT supports the policy, but would like to see amendments to strengthen the protection of Local Wildlife Sites and to be explicit that developments leading to the loss or harm of ancient woodland, veteran trees or other irreplaceable habitats will be refused. We also recommend a larger default buffer of 25m.

Full text:

SWT supports the inclusion of this policy, however it should be more explicit that development leading to loss or harm to designated sites, including Local Wildlife Sites, will be refused. Paragraph 185 of the NPPF is clear that local plans should ‘identify, map and safeguard components of local wildlife rich habitats and wider ecological networks, including… locally designated sites.’ Further to this, Planning Practice Guidance (Ref ID: 8-013-20190721) makes clear that ‘National planning policy expects plans to identify and map these sites, and to include policies that not only secure their protection from harm or loss but also help to enhance them and their connection to wider ecological networks.’ As it stands, draft policy ENV5 is not strong enough.

The policy should also be explicit that developments leading to the loss or harm of ancient woodland, veteran trees or other irreplaceable habitats will be refused. We do support the inclusion of the requirement for a buffer to ancient woodland, but would like to see this extended as it has been in the draft policy NE4 of the emerging Wealden Local Plan:

‘In the absence of site surveys and detailed assessments that demonstrate a 25m buffer is not required, the Council will assume a minimum buffer of 25m from the edge of the woodland, which allows for the presence of veteran trees and the fall height of mature trees.’

Comment

Rother Local Plan 2020-2040 (Regulation 18)

196. Specifically, what are your views on the Council requiring an impact assessment for any development proposed within 25 metres of Ancient Woodland?

Representation ID: 25718

Received: 21/07/2024

Respondent: Sussex Wildlife Trust

Representation Summary:

We support this requirement.

Full text:

We support this requirement.

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