Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27835

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

Proposed Policy LAN1: Rural Environments and Landscape Character P332
“The siting, layout and design of development should maintain and reinforce the natural and built landscape character of the area in which it will be located, based on a clear understanding of the distinctive local landscape characteristics. Priority must be given to the conservation and enhancement of the district’s national designated and locally distinctive landscapes and landscape features, including but not limited to: The High Weald National Landscape (which is also subject to Policy GTC9). The Romney Marshes, comprising of the distinctive low-lying levels to the east of the district with particular regard to the landscape setting of Rye and Winchelsea.”
Q173: Rye strongly agrees.

Comment

Representation ID: 27836

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

Proposed Policy LAN2: Trees, Woodlands and Hedgerows P336
Q175 – 176
Rye agrees.

Comment

Representation ID: 27837

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

Proposed Policy LAN3: Dark Skies P339
Q177
Rye agrees; avoid development on high ground sites adjacent to bio protected land and AONL.

Comment

Representation ID: 27838

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

In general, Rye supports the overall direction of the policies (ENV 1 -7). The test will be in the implementation because of the “opt outs”.
Rye:
Of special importance to Rye is ENV1 (Coastal, Water and Flood Risk Management) and ENV 2 (Sustainable Surface Water Drainage).
Q179 - 180
P343 - ENV1. Rye has a five sites of regular surface water risk (identified in the JBA study of 2015 and the ESCC Surface Water Management Plan) and there is a sewage capacity problem with spillages occurring regularly during extreme rainfall. Storm overflows lead to untreated sewage run off to the Strand and the rivers in Rye. The policy should be that sufficient additional mains drainage and sewage capacity equal to sewage and run off generated by the development must be secured before a development is allowed.

Comment

Representation ID: 27839

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

P348 - ENV2 Q181 – 182
Rye strongly supports. Suggest obligatory sustainable drainage (SuDS) - that as a minimum requires no additional run off rates for any development. There should be the inclusion of permeable surfaces as standard in any development proposals.

Comment

Representation ID: 27840

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

Proposed Policy ENV3: Land Stability
P354 Q183 – 185
“New development, including residential extensions and alterations, will only be permitted on unstable or potentially unstable land, including former landfill sites and coastal margins, where the nature of the instability has been properly assessed through a full land instability risk assessment report; and any remedial measures required to ensure that the development does not add to the instability of the site or surrounding land, are environmentally acceptable, and are normally implemented prior to the commencement of building works. The use of infiltration to manage surface water will not be allowed, unless a qualified geotechnical engineer has assessed the risk.”

(See reports of event on 26 Feb 24, extracted below. Applies particularly to any development on north side of Military Road)
Landslip onto Military Road : On Tuesday afternoon there was a significant landslip of topsoil and vegetation onto Military Road, 200 yds to the east of the Globe Inn. After the recent heavy rainfall, ground water in the Rye Hill escarpment has loosened the surface, causing several tons of debris to slip and block the road. At 0730hrs on Wednesday the road remained blocked.
There is a history of landslip in this area. Many years ago, Point Hill at Point Hill above the site of this event, had a tennis court, which slipped down towards Military Road. Several smaller landslip events have occurred since, both in the east and west of Rye.
Landslip is a risk which is recorded in the Rye Neighbourhood Plan in parts of Rye where the underlying sandstones, topsoil and vegetation is exposed to water and erosion.

To the north of the Military Road is a broad location from where spring outfalls occur, where the aquifers leak out at the base of the escarpment. Aggravated by more frequent extreme rainfall, this aggravates the risk of landslip.
https://www.ryenews.org.uk/community/riddle-of-our-hidden-reservoirs.

An earlier article on land instability is linked below and I will not repeat the detail here. The issue has been discussed at Rye Planning and Townscape meetings, but this latest event highlights the need to for the LPA to ensure that developers are fully aware by imposing strict conditions on any groundwork.

https://www.ryenews.org.uk/news/how-unstable-is-rye

Mike Pepler’s youtube video covers the extent of the slip.
https://youtu.be/2JtAMHL6Kio

It is noticeable that this latest slip occurred above an area where the base of the escarpment has been excavated and some vegetation removed. It is not too soon to link the two events and what is clear is that trees, shrubs and plants should not be removed from areas where there is risk of slip as the roots help to bind the surface soil.
Climate change indicates that we can expect more extreme and prolonged rainfall as there are changes to the Jetstream. Landslip risks are likely to increase in the future.

It is recommended that the land stability report for this project, which accepts that there is a risk of landslip, should be reviewed and reassessed.

Comment

Representation ID: 27841

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

P361 - Proposed Policy ENV5: Habitats and Species
Q189 – 191
Rye strongly endorses this policy as there are several protected areas surround Rye.

Comment

Representation ID: 27842

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

P369- ENV6: Sustainable Access and Recreation Management Strategy
Q192 – 193
Rye agrees

Comment

Representation ID: 27843

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

ENV7: Environmental Pollution.
Q194 - 196
Rye supports in general, but development proposals should address in particular:
- Noise of ground pumps – installation standards
- Egress of catering business kitchen exhausts: filtered and away from adjacent dwellings.
- Location of security lights and CCTV covering public areas
- Recycling, not least plastic to reduce the amount of plastic and microplastic in our rivers and Rye Bay;
- Road pollution of the type suffered along the A259.
- Illegal dumping on “green sites” such as Harbour Road
- The requirement for a bulk waste site for Rye.

Comment

Representation ID: 27844

Received: 23/07/2024

Respondent: Rye Neighbourhood Plan Steering Group

Proposed Policy HER1: Heritage Management P380
Q197 – 198
Rye: one of the key aims of the Rye NP is to preserve the character of the settlement. However there must be some flexibility to allow like for like replacement of windows and doors but incorporating thermal insulation.