SWT supports this policy and particularly the requirement to deliver BNG within the park. The park is a valuable recreational resource to local communities and holds some very important places for wildlife that need to be protected and enhanced. In particular, the Countryside Park contains the Combe Haven SSSI which includes Sussex Wildlife Trust’s reserve Filsham Reedbed, the park also connects down through Glyne Gap LWS to the Bulverhythe Shingle Beach and Cliffs LWS.

Southern Water understands the desire to protect habitats and sites of local importance. However, we are concerned that the current wording of this policy may create a barrier to statutory utility providers, such as Southern Water, from delivering essential infrastructure required to serve existing and planned development. We therefore request the following wording change to HWB7, explaining our reasoning further below.

Requested changes:
(i) Are small in scale and supported by the CVCP Community Interest Company and its strategy for the Park, other than in exceptional circumstances, for example where a proposal relates to necessary utilities infrastructure and where no reasonable alternative location is available.”

Further explanation and justification:
The National Planning Policy Framework (NPPF) (2023) sets out the intention to protect the countryside, for which it establishes:

• The intention in paragraph 152 of ruling out inappropriate development ‘except in very special circumstances’.
• In paragraph 153 that special circumstances exist if the potential harm of a development proposal is clearly outweighed by other considerations.
• In paragraph 155 that 'certain other forms of development are also not inappropriate' including 'engineering operations'.

Southern Water considers that should the need arise, special circumstances exist in relation to the provision of essential wastewater infrastructure required to serve new and existing customers. This is because there can be limited options available with regard to location, as the infrastructure would need to connect into existing networks. The National Planning Practice Guidance (ref: 34-002-20140306) recognises this scenario and states that ‘it will be important to recognise that water and wastewater infrastructure sometimes has particular locational needs (and often consists of engineering works rather than new buildings) which mean otherwise protected areas may exceptionally have to be considered'.

Planning policies should therefore support proposals that come forward to deliver necessary water supply and wastewater infrastructure.

Please see attached comments from Burwash Parish Council.

Please refer to attachment

We welcome the Overall Priority 1 - Green to the Core and the Proposed Policy HWB7: Combe Valley Countryside Park. However it is unfortunate that the Park is not referenced by name in the Proposed Policy DEV6: Strategic Green Gaps, where it is referred to as Bexhill and Hastings/St Leonards Strategic Green Gap. The park is clearly important as part of the policy relating to health and well being, but it also needs to be emphasised that it is land which is protected from development as part of the strategic green gap between Bexhill and St Leonards

Please see attached submitted document for full comments.