Local Plan Supporting Evidence Base Documents

Representation on HELAA site RYE0003

Site ID RYE 0003 within the HELAA states that the site is almost entirely within Flood Zone 3. As part of the preparation of planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P, extensive flood modeling has been undertaken.

The modeling has confirmed that the site is in tidal / fluvial Flood Zone 3A, according to the Environment Agency’s fluvial modelled flood data and confirmed by JBA’s (Flood Risk Consultant's) model. It benefits from tidal flood defences (in reasonably good condition currently), which protect it in all tidal scenarios – including the 1 in 200yrs storm + climate change. The lowest parts are liable to flood in the event of a breach/overtopping of the tidal defences.
The flood risk assessment submitted for the current live planning applications demonstrate that the Flood Zone is not a impediment for developing on the site.

We welcome the Council's acceptance that the site could accommodate more development, above the existing thresholds of Policy H6 of the Rye Neighbourhood Plan. However, as increase in 15 additional dwellings does not go far enough. As demonstrated by the current live planning applications (RR/2024/949/P & RR/2024/960/P & RR/2024/976/P), RYE 0003 is able to accommodate at least 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. We also request that greater flexibility is given within the policy to "employment space" to include Class E and to increase the flexibility on residential typology.


Appendix A - LSE Screening of Potential Development Sites:

The "brief" summary of the development proposals is below the yield of what is currently being proposed under live planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P which propose 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. These yields should be screened for accordingly.


The screening outcome states that the development will have a likely significant effect as the site is located within 200m of Dungeness, Romney Marsh & Rye Bay SPA/Ramsar. The screening outcome states that surface water discharge pathways can reach for several hundred metres. Therefore, it is not possible to say that the development would not have likely significant effects on the SPA/Ramsar site. Nonetheless, the outcome of the HRA does accept that this judgement is made prior to the consideration of any mitigation measures devised for the site.

With this in mind under the current planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P it has been confirmed that the proposed surface water drainage system has an appropriate level of pollution/runoff treatment in accordance with the CIRIA SUDS manual 753. The proposed surface water solution for the proposed development is a huge betterment on the existing, as the surface water from the site is currently untreated and flows into the combined sewer and some areas just run off untreated to the ditch which forms the south-western boundary of the site.

It also must be recognised that the protected site (Dungeness, Romney Marsh & Rye Bay SPA/Ramsar) are a significant distance away and on the other side of A259 further mitigating any potential effect.

This betterment to the surface water drainage for the site demonstrates that there will not be a likely significant effect on the protected sites.

We request that the above mitigation measures are factored into the Council's HRA document.

Representation on HELAA site RYE0003

Site ID RYE 0003 within the HELAA states that the site is almost entirely within Flood Zone 3. As part of the preparation of planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P, extensive flood modeling has been undertaken.

The modeling has confirmed that the site is in tidal / fluvial Flood Zone 3A, according to the Environment Agency’s fluvial modelled flood data and confirmed by JBA’s (Flood Risk Consultant's) model. It benefits from tidal flood defences (in reasonably good condition currently), which protect it in all tidal scenarios – including the 1 in 200yrs storm + climate change. The lowest parts are liable to flood in the event of a breach/overtopping of the tidal defences.
The flood risk assessment submitted for the current live planning applications demonstrate that the Flood Zone is not a impediment for developing on the site.

We welcome the Council's acceptance that the site could accommodate more development, above the existing thresholds of Policy H6 of the Rye Neighbourhood Plan. However, as increase in 15 additional dwellings does not go far enough. As demonstrated by the current live planning applications (RR/2024/949/P & RR/2024/960/P & RR/2024/976/P), RYE 0003 is able to accommodate at least 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. We also request that greater flexibility is given within the policy to "employment space" to include Class E and to increase the flexibility on residential typology.


Appendix A - LSE Screening of Potential Development Sites:

The "brief" summary of the development proposals is below the yield of what is currently being proposed under live planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P which propose 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. These yields should be screened for accordingly.


The screening outcome states that the development will have a likely significant effect as the site is located within 200m of Dungeness, Romney Marsh & Rye Bay SPA/Ramsar. The screening outcome states that surface water discharge pathways can reach for several hundred metres. Therefore, it is not possible to say that the development would not have likely significant effects on the SPA/Ramsar site. Nonetheless, the outcome of the HRA does accept that this judgement is made prior to the consideration of any mitigation measures devised for the site.

With this in mind under the current planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P it has been confirmed that the proposed surface water drainage system has an appropriate level of pollution/runoff treatment in accordance with the CIRIA SUDS manual 753. The proposed surface water solution for the proposed development is a huge betterment on the existing, as the surface water from the site is currently untreated and flows into the combined sewer and some areas just run off untreated to the ditch which forms the south-western boundary of the site.

It also must be recognised that the protected site (Dungeness, Romney Marsh & Rye Bay SPA/Ramsar) are a significant distance away and on the other side of A259 further mitigating any potential effect.

This betterment to the surface water drainage for the site demonstrates that there will not be a likely significant effect on the protected sites.

We request that the above mitigation measures are factored into the Council's HRA document.