Excellent plan but very limited in forward view. Why no mention of future tech advances in wind turbines, molten salt reactors at Dungeness, extended out fall to help sewage overflows.

Southern Water is the statutory wastewater undertaker for the Rother district. As stated in our response to question 184, we support the intention of Policy ENV1 but ask that wording is added to the policy to help safeguard sewage capacity and protect rivers and seas from potential pollution. In particular, priority should be given to natural flood management and sustainable drainage approaches.

Requested changes:
(ii) Ensuring that new development does not adversely impact any Ordinary Watercourse, Main River, natural drainage channel or flood and sea defence… No surface water will be allowed to connect to the foul or combined sewer networks
(vii) Ensuring, through the protection of natural drainage routes and the provision of effective sustainable drainage solutions, that development does not increase flood risk elsewhere. All development proposals (including smaller developments and extensions/renovations) should include adequate sustainable drainage provisions and seek to reduce flood risk and contribute to flood alleviation

Further explanation and justification:
Southern Water supports the overall intention of this policy to manage flood risk. However, for major development in areas where SuDS are viable, we believe their use should be mandated. To increase the effectiveness of this policy we ask that sustainable drainage measures be incorporated, particularly as the current SuDS policy ENV2 is proposed as a non-strategic policy. Preventing connections of surface water to foul or combined sewer networks will be key to safeguarding the capacity and effective operation of the public sewage network into the future, this is in line with our surface water management policy here:
https://www.southernwater.co.uk/media/l23dbon0/surface-water-management-policy-120724.pdf
This is required to mitigate the risk of sewer flooding and increase available capacity for foul drainage.

During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. As stated in Water UK’s 21st Century Drainage Programme;

“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.

In terms of future flood risk, better rainwater management through SuDS is the preferred approach to avoid placing added pressure on drainage networks during heavy rainfall. As set out in Defra’s Storm Overflows Discharge Reduction Plan “Water companies must remove rainwater from the combined sewer system as part of effectually draining their areas. This should include limiting any new connections of surface water to the combined sewer network, and any new connections should be offset by disconnecting a greater volume of surface water elsewhere within the network". This is also in line with paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) that requires:
167(c) using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)

The Barnhorn sewage pipe is too narrow to cope with sewage from the current Rosewood Park dwellings. It is totally unacceptable now for houses and gardens south of Barnhorn Road (119 to 123) to be flooded with sewage after heavy rain. This is a very serious issue which demonstrates a major flaw in earlier planning decisions and subsequent building work. There is therefore ample evidence that Rosewood Park development of 356 houses and a 72-bed Care Home should not have been allowed without the construction of a robust sewage system to deal with the additional sewage.

Additional dwellings either side of Barnhorn Road will increase the pressure on the totally inadequate
sewer pipe, cause further blockages and more extensive and frequent hazardous flooding. This is a major health issue.

The current sewage system is clearly obsolescent. It must be replaced before any further development along Barnhorn Road is even considered.

Please see attached the full response from Etchingham Parish Council regarding the draft Local Plan.

Draft Rother Local Plan 2020-2040 – Public Consultation

Hastings Borough Council welcomes the opportunity to formally comment on the Rother District Council Regulation 18 draft Local Plan. Hastings Council is broadly supportive of the Rother Local Plan and its vision, aims and objectives. Specific comments are made here on those areas of the Draft Plan where there are strategic cross-boundary issues. We wish to continue to work with the Rother District Council on these and other matters in the Plan, as work on the Plan progresses as part of meeting Duty to Cooperate requirements.

- Joint Statement:

The Council is supportive of the joint statement and is committed to continuing to work closely together on strategic matters affecting both of our councils’ Plans.

- Housing requirement and Development Strategy:

The joint Housing and Economic Development Needs Assessment (HEDNA) identifies a need for 14,740 net new homes over Rother’s Plan period. The draft Plan outlines the potential to meet this need through the delivery of between 5,158 and 7,287 new homes. This equates to meeting approximately 50% of the district’s identified housing need, and places a potential pressure on Hastings Council, as a neighbouring authority within the same housing market area, to assist Rother in meeting their full housing need. Rother Council, has, after the start of their Regulation 18 consultation, now formally requested this council’s assistance in meeting their unmet housing need. As established through joint working with Rother planning officers, we will regrettably be unable to assist in meeting any of Rother’s potential unmet need owing to the challenges we face in meeting our own housing targets.

We note that at this draft Regulation 18 stage of the plan making process, (with an additional final public consultation to follow) this draft Plan does not provide any specific allocations but presents sites that have been assessed as part of the Housing Economic Land Availability Assessment (HELAA) process. The draft Plan’s preferred development strategy policy includes development around the Hastings Fringe (as referenced in option SD05 set out in the Development Strategy Background Paper) and identifies small-scale sensitive development around the fringe.

From the HELAA document it can be identified that there are only three sites identified in the Hastings Fringe that would be considered as potentially suitable sites that have not been rejected as part of the HELAA process. Hastings will be keen to discuss these potential sites on the Hastings Fringe and surrounding area as the Rother Plan progresses and further details of specific site allocations come forward. However, in principle, the Council is broadly supportive of the residential development within the Hastings Fringe, subject to the details of specific sites and their constraints.

Furthermore, the council is supportive of the assessment within the HELAA of land at the Breadsell (HAF0007), which indicates that the site is not currently suitable for allocation.

- Strategic Gap:

The Council is broadly supportive of the strategic gaps between Bexhill, Crowhurst and Battle in relation to Hastings, given the importance of the Combe Valley Countryside Park, environmental constraints and the lack of suitability in sustainability terms of these locations to accommodate significant levels of development. The supporting land supply evidence documents should clearly set out how these broad locations have been assessed and discounted for significant development.

- Employment Land:

The draft Plan indicates that it will be possible to meet overall employment needs in terms of having a sufficient supply of land suitable for employment-related development. However, there is an identified undersupply of land suitable for meeting storage and distribution needs. Given the undersupply of land suitable for storage & distribution within Hastings Borough, this could result in a significant under-delivery across the district and borough functional market area combined. The Council would therefore welcome more discussion on meeting employment needs across the two authorities’ areas.

- Flood Risk:

We recognise that flood risks may cross our respective district and borough boundaries. Some watercourses have interactions with, or originate from, watercourses beyond the Hastings borough. In some cases, surface water can enter these watercourses over quite a wide area (the Combe Haven is an example of this). The Council would welcome at this stage in the development of Rother’s Plan, the opportunity to explore whether the Rother Strategic Flood Risk Assessment (SFRA) is able to consider how surface water discharge may impact on flood risk in Hastings, either through runoff or interaction with watercourses.

- Whole Plan Viability:

As already stated, the Council is generally supportive of the policies that have been proposed in the Draft Local plan and their alignment with Draft Plan objectives. However, the Council notes that there is no whole plan viability assessment underpinning the policy proposals at this time. The Council is therefore keen to understand the viability of Regulation 18 policy proposals set out, as the plan progresses.

We also look forward to the continuing dialogue between the two councils as part of the duty to cooperate process.

The original reponse has been saved as an attachment, titled: 'Regulation 18 Representation - Hastings Borough Council'

Please see attached document for the full submission from Westfield Parish Council.