Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.