Rother Local Plan 2020-2040 (Regulation 18)

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Comment

Rother Local Plan 2020-2040 (Regulation 18)

1. What are your views on the Council's Vision?

Representation ID: 26011

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Support the element of the vision stating that "Bold solutions will have successfully addressed the climate and biodiversity emergencies and the housing crisis while protecting the High Weald National Landscape, our designated habitats, our heritage and our flood risk areas."
The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both.

Full text:

Support the element of the vision stating that "Bold solutions will have successfully addressed the climate and biodiversity emergencies and the housing crisis while protecting the High Weald National Landscape, our designated habitats, our heritage and our flood risk areas."
The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

Overall Priority 1 – Green to the Core

Representation ID: 26014

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Support this goal. The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both. The Committee on Climate Change has highlighted in its most recent progress report that we are failing significantly to meet the level of tree planting and woodland creation needed to meet net zero targets. In addition to absorbing carbon emissions, trees and hedgerows help mitigate the impacts of climate change, delivering natural cooling in urban heat islands through transpiration as well as providing shelter and shade, and contributing to sustainable urban drainage systems. They also make a valuable contribution to the quality of the public realm, helping reduce air, noise and light pollution and improve people’s mental health. A plan that is truly 'Green to the Core' should have policies for retaining and increasing tree cover at its heart.

Full text:

Support this goal. The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both. The Committee on Climate Change has highlighted in its most recent progress report that we are failing significantly to meet the level of tree planting and woodland creation needed to meet net zero targets. In addition to absorbing carbon emissions, trees and hedgerows help mitigate the impacts of climate change, delivering natural cooling in urban heat islands through transpiration as well as providing shelter and shade, and contributing to sustainable urban drainage systems. They also make a valuable contribution to the quality of the public realm, helping reduce air, noise and light pollution and improve people’s mental health. A plan that is truly 'Green to the Core' should have policies for retaining and increasing tree cover at its heart.

Attachments:

Comment

Rother Local Plan 2020-2040 (Regulation 18)

3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?

Representation ID: 26018

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

At para 2.13, the plan refers to "delivering carbon reduction and adaptation to climate change, and responding to
the locally declared ‘Climate Emergency" however there is no equivalent point for the biodiversity crisis, despite the earlier statement that "Being Green to the Core means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald Area National Landscape."

It would make sense therefore to add a key issue to reflect this, e.g. "delivering nature recovery, protecting and reconnecting priority habitats, and responding to the biodiversity crisis".

Full text:

At para 2.13, the plan refers to "delivering carbon reduction and adaptation to climate change, and responding to
the locally declared ‘Climate Emergency" however there is no equivalent point for the biodiversity crisis, despite the earlier statement that "Being Green to the Core means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald Area National Landscape."

It would make sense therefore to add a key issue to reflect this, e.g. "delivering nature recovery, protecting and reconnecting priority habitats, and responding to the biodiversity crisis".

Comment

Rother Local Plan 2020-2040 (Regulation 18)

Proposed Policy GTC7: Local Nature Recovery Areas

Representation ID: 26021

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Strongly support the incorporation of the emerging Local Nature Recovery Network mapping and priorities into the Rother Local Plan.

Full text:

Strongly support the incorporation of the emerging Local Nature Recovery Network mapping and priorities into the Rother Local Plan.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

20. What are your views on the Council's proposed policy for Local Nature Recovery Areas?

Representation ID: 26025

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Strongly support the policy to incorporate the emerging LNRS mapping and priorities into the local plan.

Full text:

Strongly support the policy to incorporate the emerging LNRS mapping and priorities into the local plan.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

22. What are your views on the Council's proposed policy for Biodiversity Net Gain?

Representation ID: 26027

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Support the policy that BNG should be set at a 20% minimum, delivered onsite as a preference and if offsite, then in line with the LNRS.

Full text:

Support the policy that BNG should be set at a 20% minimum, delivered onsite as a preference and if offsite, then in line with the LNRS.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

23. What are your views on the Council going above the national minimum requirement of 10%?

Representation ID: 26030

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

We support setting a greater than 10% target for net gain where appropriate. By setting a more ambitious target, the Local Plan increases the chances that an average net gain of at least 10% will be delivered across the Plan area, given the possibility that some sites may not be able to deliver net gain within the District or that initiatives intended to deliver such gain may fall short in practice.
Other LPAs, including Guildford, Maidstone and Worthing, have adopted planning policies with 20% BNG requirements, indicating that this is a sound and viable approach.

Full text:

We support setting a greater than 10% target for net gain where appropriate. By setting a more ambitious target, the Local Plan increases the chances that an average net gain of at least 10% will be delivered across the Plan area, given the possibility that some sites may not be able to deliver net gain within the District or that initiatives intended to deliver such gain may fall short in practice.
Other LPAs, including Guildford, Maidstone and Worthing, have adopted planning policies with 20% BNG requirements, indicating that this is a sound and viable approach.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

24. Are there any alternatives or additional points the Council should be considering?

Representation ID: 26031

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

We would also encourage considering development of a local metric for more urban/brownfield sites, such as the London Urban Greening Factor, because such sites may already have a very low level of biodiversity and therefore a percentage increase may not in practice deliver significant enhancements.

Full text:

We would also encourage considering development of a local metric for more urban/brownfield sites, such as the London Urban Greening Factor, because such sites may already have a very low level of biodiversity and therefore a percentage increase may not in practice deliver significant enhancements.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

Proposed Policy GTC9: High Weald National Landscape (AONB)

Representation ID: 26034

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

Strongly support this policy. The High Weald National Landscape has more ancient woodland than any other part of England. It is essential that this irreplaceable habitat is fully protected and that the High Weald management plan, which sets out a comprehensive approach, is reflected in local plans.

Full text:

Strongly support this policy. The High Weald National Landscape has more ancient woodland than any other part of England. It is essential that this irreplaceable habitat is fully protected and that the High Weald management plan, which sets out a comprehensive approach, is reflected in local plans.

Comment

Rother Local Plan 2020-2040 (Regulation 18)

3.53

Representation ID: 26036

Received: 23/07/2024

Respondent: Woodland Trust

Representation Summary:

The phrase "well wooded landscape" understates the significance of the High Weald. More ancient woodland survives in the High Weald than anywhere else in the country, and at 8%, compared with a national average of 3%, it has the highest coverage of ancient woodland in any protected landscape.

Full text:

The phrase "well wooded landscape" understates the significance of the High Weald. More ancient woodland survives in the High Weald than anywhere else in the country, and at 8%, compared with a national average of 3%, it has the highest coverage of ancient woodland in any protected landscape.

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