ROTHER DISTRICT COUNCIL  CORE STRATEGY CONSULTATION
OUR RESPONSE SUBMITTED JANUARY 29TH 2009

The Core Strategy Consultation Document can be seen on Rother's Local Development Framework page

 

Subject

page

Para

COMMENT (C)  SUPPORT ( S)  Object (O)

O

Future Challenges

8

2.8

Changes have now taken place at the global level. The forecasts for economic development and house building will need to be revised in the light of the prevailing conditions. Adapting to the new economic realities is now a challenge.

There are a range of urgent environmental challenges facing the district. They deserve to be listed in the preamble of the Strategy.

Uncertainty of energy supply: this can be addressed by new development.

Food security: This can be addressed by encouraging local food production facilities and local distribution

Waste and recycling:  Although the burden of waste disposal falls on the County the District should acknowledge that it is right to encourage the development of local facilities for the recovery and recycling of waste, both domestic and commercial. The principal of handling waste locally – rather than shipping it out of the District should be accepted.

Water shortages: Rainfall per head is very low and reservoirs limited. Water conservation measures should be required in new developments.

O

Vision

12

Box 1

There is a mention of a “local commitment to a more sustainable future” in paragraph four.

This appears as a sub-clause of a paragraph that begins by addressing nature conservation.

The commitment to sustainability deserves a paragraph of its own.

 

It is an over-arching principal of the Strategy that Rother should become a more sustainable place: reducing its dependence on fossil fuels, and its ecological impact – both locally and globally.

 

The vision for Rye should include that it develops its role as one of the most important destinations for Sustainable Tourism.

O

Overall Spatial

29

Box 3

Encourage self sufficiency and healthy lifestyles by ensuring residents have convenient access to land for the growing of fruit and vegetables and the composting of food waste and if necessary provide allotments for those without gardens.

O

Overall Spatial

29

Box 3

Ensure that development contributes to the community’s resilience to the impacts of climate change and the addresses their need for security of supply of food, energy and water.

O

Development levels - 2026

30

5.06

These will need to be downgraded to reflect current conditions

O

Bexhill Link Road

31

5.79

Strongly disagree that appropriate growth in Rother is dependent on the construction of the BHLR. The Highways Agency should not be accorded the status of final arbiter of what development can take place. Employment and housing can be constructed in Rother and continue to be served by improved public transport and much less damaging road infrastructure.

 

Rural Areas/ Countryside strategy

80

Box 18

We endorse the support for local agriculture.

B(i) To the list of local agricultural enterprises could be added food processing facilities and small abattoirs. The contribution local food production makes to “food security” should be mentioned.

Support should be given to renewable energy facilities and measures to conserve water.

(c)Development in the Countryside should take full advantage of the rural location for renewable energy technologies (ground source heat pumps etc) and rainwater harvesting.

S

Economy/Tourism

106

Box 26

Support more emphasis on “green tourism”

 

 

 

 

 

C

Economy Implementation

107

11.20

Suggest the main mechanism could be a new “Green Tourism” / “Sustainable Tourism” Strategy to be prepared in consultation with, amongst others,  local farmers, environmental groups, and accommodation and catering providers.

O

Environment/Scope

109

12.1

See comment on Box 1

The emphasis on conservation of landscape, heritage and biodiversity misses the point about the key environmental concerns.
The urgent need to reduce CO2 and impact on natural resources justifies an active encouragement of development that helps achieve this. In particular schemes that reduce the need for car travel, provide local food and local renewable energy, reduce waste and assist the local recycling and recovery of waste and reduce water use are all priorities.

These issues are referred to in other parts of the document but deserve to head up the chapter on the environment as they are key to a concerted and meaningful environmental approach.

O

Environment/Scope

109

12.1

When reviewing the environmental options for Rother a list of the natural assets of our local environment should be included. This includes the fact that this sunny southern coastal region is especially suitable for solar power. There are also thousands of hectares of poorly managed woodlands, in particular chestnut coppice, that could provide fuel and, by being actively managed, benefit biodiversity. ( this is mentioned in para 9.69 on page 80 but deserves another mention here)

O

Environment/Aims Objectives

109

Box 27

See Box 1

The Aim is not sufficiently strong. The first part of the Aim refers to nature conservation. Although this is a good thing the more urgent need is to reduce our dependency on fossil fuels and our consumption of natural resources as well as adapt to the consequences of climate change. We want Rother to become a much more sustainable place!

O

Environment/Aims

109

Box 27

There should be an aim to assist the efficient recovery and recycling of waste by encouraging the development of appropriate local infrastructure. Including local composting facilities and other facilities for the beneficial processing of food waste.

It should be recognised that the Rye Area is a part of East Sussex that is very poorly served in respect of Household Waste Recovery Site. It is an hour round trip by car to Mountfield. The need for a more local site should be recognised.

O

Environment/Aims

109

Box 27

There should be an aim to exploit the natural resources of Rother including the high levels of sunshine for solar power and the abundant un-managed woodland and chestnut coppice for biomass.

O

Environment/Aims

109

Box 27

The importance of encouraging the development of local food supplies should be added. The encouragement of facilities for the local processing of food, including small local abattoirs, both on farms as well as elsewhere. Providing or protecting spaces in towns and larger villages for weekly farmers markets. ( this is also covered in the Rural Area section Box 18 and Para 9.70 on page 80– but it is of wider significance to the whole district)

O

Design Quality

112

Box 29

The requirement for sustainable design and construction should be at the top of the list as a priority.

 

 

 

 

 

S

Sustainable resource management

Renewable Energy

117

Box 31

See comment on Box 1.

Energy deserves a Box of its own and we would commend the example of Tunbridge Wells who have produced a SPD on renewable energy 

 

The following is their policy
Having regard to the foregoing policy context, the Borough Council will therefore expect all development (either new build or conversion) with ten or more residential units/over 0.5ha site area, or for non-residential developments with a floor space of 1,000sqm or over 1.0ha site area, to incorporate renewable energy technology on-site to reduce predicted CO2 emissions by least 10%.

(NB. National targets of energy obtained from renewable sources are to increase to 15% by 2015 and 20% by 2020.)”

 

We strongly support the Option 2 (iii) to require a minimum of 10% of on-site renewable energy generation as above.

 

S/C

Sustainable Resource management

117

Box 31

We support Option 2 (ii) for Code 4 by 2010 but not that it should be restricted to identified development areas. This requirement should be met by all new development and major refurbishments.

 

S/C

Sustainable Resource/ Renewable infrastructure

117

Box 31

We support Option 2 (iv) but there is no need for the comment regarding sub regional joint working. It is appropriate for individual communities to seek ways of generating their own energy on their own.

O

Water Waste water
(Conservation)

118

Box 32

We recommend that a SPD on water is prepared to address the needs for water conservation (and flood mitigation).

New developments should be required to harvest rainwater.

This not only saves money but makes sense when there is less rainfall per head of population in the southeast than in Cairo.

S/C

Flood Risk

119

Box 33

We strongly support the introduction of a requirement to restrict water run-off from developments. This should be applied to all development including small projects such as driveways and garden patios.

An SPD setting out the requirements would be useful as with water conservation.

S/C

Transport/

Aims and objectives

123

Box 34

We strongly support the policy of increasing the potential to travel by train or public transport.

The high speed train services at Ashford to both London and Europe could contribute greatly to the regeneration of this corner of the Southeast and this should be recognised.

O

Transport/ Strategy

125

Box 35

See comments re BHLR above.

The railway options should be given a higher priority over road building.

If roads are to be built the priority should be on linking Hastings to the M25. It has been shown in Brighton that regeneration is intimately related to journey times to and from London.

The option (iv) Investment in rail infrastructure is too limited. There are clearly agreed objectives to dual the line between Hasting and Ashford.

Re option (v) It should be recognised that there are already severe capacity constraints on this line already due to the demand.

Re option (viii) also reserve land needed for the upgrading of track between Hasting and Ashford.

O

Transport/Strategy

Box 35

126

There should be a separate section on cycling. The introduction of a comprehensive cycle network with associated facilities should be an ambition of the strategy. Developer contributions should be sought. Land safeguarded etc.

An SPD on cycling is needed.

O

Implementation and monitoring

129

Box 36

It should be recognised in the strategy that many parishes and towns are engaged in preparing Local Action Plans. There should be a commitment to check during the annual monitoring process that the Core Strategy and other planning Documents remain sympathetic to the aims and ambitions contained within these plans. It should be stated that Local Action Plans can be used to justify amendments to the Strategy and other Planning Documents.

O

Implementation

130

Box 37

The comment above applies