Box 33 - Preferred Strategy for Flood Risk

Support

Representation ID: 19117

Received: 16/01/2009

Respondent: mr roy dyer

Please implement measures as soon as possible.

Support

Representation ID: 19235

Received: 29/01/2009

Respondent: Sedlescombe Parish Council

Every effort should be made not to allow development in the flood plain.

Object

Representation ID: 19375

Received: 17/02/2009

Respondent: Natural England

The draft Strategy does not allow for reduced development pressure on areas of high flood risk or the coastline, noting that this 'would fail to achieve regeneration objectives' (para. 12.42). Recognition of the impact of development in flood plains on natural ecosystems, the sensitive coastal ecosystem around Rye Harbour should be made.
The draft Strategy should incorporate a recognition of this impact in the Environment chapter, Flood Risk section.
We would welcome a commitment to produce an ecological assessment and monitoring report of Rother's coastal habitats, including assessing opportunities for managed retreat and mitigating against development in the long-term.

Comment

Representation ID: 19399

Received: 29/01/2009

Respondent: Rother Environmental Group

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.

Object

Representation ID: 19488

Received: 24/02/2009

Respondent: Environment Agency

It is accepted that where there is an identified need for regeneration, some development within the floodplain may be inevitable. If this can be justified with PPS25 the sites themselves should be sequentially tested; to ensure that higher vulnerability uses are located on parts of the site that are at lower risk of flooding.
Recommendation: Page 119-120. Criteria (d) and (h) from Box 33 should be removed as it repeats the provisions of PPS25 and a further criterion should be added: "Ensure that where the principle of development has been established on a site within an area of flood risk in accordance with PPS25, the layout and distribution of development is informed by any variation in flood risk across the site according to land use vulnerability".

Support

Representation ID: 19496

Received: 24/02/2009

Respondent: Southern Water

Southern Water supports the comprehensive preferred policy direction for flood risk. In periods of flooding, surface water can inundate the public sewerage system thereby exceeding its capacity. The extra pressure can cause flows from the main sewer to surcharge up tributary sewers. As a result, properties may become flooded by foul sewage, even relatively remote from the flooded site.

We support the objectives of Sustainable Drainage Systems (SUDS) provided arrangements exist for the long term maintenance of them, so that their effectiveness is maintained in perpetuity. This is because such systems rely on facilities which are not adoptable by sewerage undertakers. Good management can avoid flooding and subsequent inundation of the foul sewerage system.

Comment

Representation ID: 19513

Received: 30/01/2009

Respondent: Guestling Parish Council

Box 33 Flood Risk. Maintaining flood defences is important (item a) but with forecast rises in sea levels it seems likely that the Shoreline management plans/Coastal strategies (item e) will need regular review to avoid uneconomic expenditure on slowing inevitable retreat.

Comment

Representation ID: 19554

Received: 25/02/2009

Respondent: Trustees of the Glyndebourne 1991 L & P Trust

Agent: Mr. Dale Mayhew

PPS25 seeks to ensure that flood risk is taken into account in the planning system, to avoid inappropriate development, and where development is exceptionally necessary in such areas, the policy is then to make it safe without increasing flood risk elsewhere and possibly reducing flood risk overall.
It is therefore important that the preferred strategy for flood risk within the Document acknowledges that within an overall context of minimising flood risk, some development in areas at risk of flooding may be acceptable, having regard to wider sustainability benefits, and through application of the sequential test and exception test.
The strategy should also indicate that regard will be had to areas for development which benefit
from the provision of flood defences, which can provide a high level of protection.

Object

Representation ID: 19619

Received: 30/01/2009

Respondent: Rother and Hastings CPRE

Page 119 Box 33 RDC needs to address the flooding implications of all development proposals, not just those in the flood plain, since all contribute to increased run off. So press for sustainable drainage systems everywhere. Ensure so far as you are able that agricultural practices do not exacerbate the flooding problem

Comment

Representation ID: 19628

Received: 30/01/2009

Respondent: Campaign for a Democratic Rye

There are clearly major risks to Rye from flooding and these will increase, as climate change accelerates during this century. The Strategic Flood Risk Assessment has already identified areas of Rye at risk. Clearly development on these sites is highly undesirable.
Equally, other developments could increase the risks of flooding to existing sites (Box 33f. support)

This important topic needs full public scrutiny and information. (Box 15f Comment).

Object

Representation ID: 19722

Received: 02/03/2009

Respondent: Messrs. Chishick, Commotto and Terry

Flood Risk
We are surprised that Parish Emergency Plans are not mentioned and Parish Councils are not included as partners.

Comment

Representation ID: 19754

Received: 30/01/2009

Respondent: RSPB

Flood Risk
We would like to discourage any further development within flood zones as it is against national policy identified in PPS25. Any flood alleviation or mitigation works may affect the hydrological regime in sensitive downstream receptors like the Dungeness to Pett Level SPA, or Pevensey Levels Ramsar sites.

Comment

Representation ID: 19855

Received: 04/02/2009

Respondent: Crowhurst Society

f) Vital if low lying communities are to survive. As global warming raises water levels more stringent planning tools are needed to protect communities.

Support

Representation ID: 19956

Received: 28/01/2009

Respondent: Ewhurst Parish Council

Support is given to the preferred strategy for flood risk in not allowing development to increase the risk of flooding to properties elsewhere (e.g. through surface water run-off, or by impeding the flow or storage of flood water) at box 33.

Support

Representation ID: 20304

Received: 29/01/2009

Respondent: SEEDA

SEEDA supports the approach to managing flood risk, in accordance with PPS25.

Comment

Representation ID: 20417

Received: 29/01/2009

Respondent: Sussex Wildlife Trust

Re-naturalisation of rivers, streams and flood plains can be an effective and economical way of reducing flood risk and maintaining water supplies.