Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25945
Received: 23/07/2024
Respondent: Southern Water
Southern Water supports the intention of this policy, although we advocate sufficient flexibility in design to ensure the most effective SuDS options remain as viable to as many sites and types of developments as possible. Viability will be particularly important to ensuring SuDS delivery, particularly for affordable homes and single-dwelling development. In line with paragraphs 167(c) and 180(e) of the NPPF(2023) it would therefore increase the efficacy of this policy to make these requested changes:
(iii) for all development, including outline applications, sufficient space must be given within a site to ensure that SuDS can be accommodated within the layout of the site, whilst avoiding any adverse impacts to the natural drainage channels existing within the site;
(Viii) all developments should demonstrate compliance with LLFA guidance for SuDS design, which for large developments or more sensitive locations, may require a minimum of 2 stage filtration of surface water runoff.
Southern Water is the statutory wastewater undertaker for the Rother district. We support the intention of the Sustainable Drainage policy, although we advocate sufficient flexibility in design to ensure the most effective SuDS options remain as viable to as many sites and types of developments as possible. . Viability will be particularly important to ensuring SuDS delivery, particularly for affordable homes and single-dwelling development. Also, it would increase the efficacy of this policy to include the need to protect natural drainage channels, and to refer to the combined sewer network as explained further below.
Requested changes:
(iii) for all development, including outline applications, sufficient space must be given within a site to ensure that SuDS can be accommodated within the layout of the site, whilst avoiding any adverse impacts to the natural drainage channels existing within the site;
(Viii) all developments should demonstrate compliance with LLFA guidance for SuDS design, which for large developments or more sensitive locations, may require a minimum of 2 stage filtration of surface water runoff.
These changes will ensure the policy’s approach contributes to reducing the risk and causes of flooding and pollution in line with paragraphs 167(c) and 180(e) of the NPPF (2023).
Further explanation and justification:
Preventing surface water from entering the foul and combined systems during heavy rainfall is the most sustainable and cost-effective way to reduce storm overflows. Southern Water is investing heavily in work to reduce their use across its region, in part by removing existing connections of surface water to the combined and foul networks. However, even as we deliver this work, development continues to increase surface water run-off in those areas.
For this SuDS policy to be effective, we need to ensure the fullest range of SuDS options remain viable to developments, in appropriate locations, to:
• Secure the resilience of our communities into the future by enhancing surface water management in the most sustainable way whilst protecting the natural water cycle.
• Minimise future connections of surface water to foul/combined sewers.
• Ensure policy is enforceable and mitigate the risk of rogue behaviours – by requiring appropriate levels of treatment only where the conditions warrant it. Whilst we understand from paragraph 11.20 of the draft Plan that the LLFA requires rainwater to pass through at least two stages of treatment in order to improve water quality, there is also concern that two-stage filtration for all infiltration SuDS in any location could be costly where there is minimal contamination risk. Southern Water has has produced ‘SuDS in SPZ guidance’* to support developers and policy makers when considering SuDS design.
*https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf
Building Regulations H3 provides a drainage hierarchy whereby surface water should first discharge to a soakaway or other infiltration system where practicable, with discharge to the combined sewerage system a last resort. Development will not be allowed to drain surface water to the foul sewer, and Southern Water will resist new connections of surface water to the combined sewer 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 because, during heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater that enters the network. Under these conditions, storm overflows can then release excess flows 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, increasing reliance on network pressure release via 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’.
The SuDS measures encouraged by planning policy should therefore support surface water infiltration into the ground wherever possible. Southern Water has produced ‘SuDS in SPZ guidance’ here: https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf to support developers and policy makers when considering SuDS design, to help ensure the fullest range of SuDS options remain viable to each development, as appropriate to the location of the site and underlying hydrogeology.
For more information on Southern Water’s work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26403
Received: 17/07/2024
Respondent: Burwash Parish Council
As above
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26966
Received: 22/07/2024
Respondent: Brede Parish Council
Rother District Council has 3620 hectares of SSSI across the counties,
drainage plans for these locations need additional measures exercised,
it states 3 levels of treatment “What are these”. The water utility
company has sewage treatment sites across multiple locations which
are governed by the regulator known as the EA (Environment Agency),
what are the measures being put in place to monitor the impact from
new developments.
• Water Utility infrastructure, confirm on level of dialogue and
understanding will be expected to the current in design of all its
wastewater treatment sites.
• Pollution caused by third party industries, development sites, farming
and industry- all add additional pressures dependant on type of
development requested.
• Southern England has been identified as a water scarcity risk area of
the country, what measures are being considered on the development
and population growth.
• Developers being accountable for the drainage and impact on the
environment. How will this be managed and considered.
Full submission attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27181
Received: 22/07/2024
Respondent: Westfield Parish Council
See point 255 in the attached submission.
Please see attached document for the full submission from Westfield Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27237
Received: 23/07/2024
Respondent: Guestling Parish Council
The existing WWTWs in Guestling Parish have inadequate capacity. The WWTWs that outflow into the Rye Bay RAMSAR discharged raw sewage into the above ground drainage system that flows into the Pannel and Marsham sewers more frequently and for a greater number of hours than all the WWTWs between Rock a Nore and Bexhill discharged into the sea. Southern Water would have us believe that their expansion of the Guestling Green WWTW allows for a futher 84 connections to be made. It was following this expansion and modernisation that this WWTW remained the plant with the worst record. It has been stated categorically by the Marsham Future Landscapes Trust that annual rainfall in this area has fallen. This is evidentially untrue for the last 12 years.
Failure of Southern Water's infrastructure is not relevant to planning decisions.
The gap between RDC policy and reality is a major problem in the credibility of planning for the future. Good intentions will not change anything. Connections to the WWT system should only be allowed if the infrastructure is adequate. No housing scheme or house extension should be permitted unless it can be shown demonstrably by Southern Water that they are actually fulfilling their role in safeguarding our environment.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28097
Received: 23/07/2024
Respondent: Marsham Brook Residents’ Association
Innovative Techniques: Consider the adoption of newer, innovative drainage solutions that go beyond traditional SuDS, such as green roofs, permeable pavements, and enhanced natural landscaping that increases absorbency in flood-prone areas.
See attachments for supporting documentation to the representations that have been made
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28135
Received: 22/07/2024
Respondent: East Sussex County Council
ENV2: Sustainable Surface Water Drainage (ii), p371; Part (ii) of the policy should be altered to ensure developers discuss and agree appropriate discharge rates for a site with the LLFA. This will allow site and development specific conditions such as discharge points, geology, topography etc to be taken into consideration when determining maximum discharge rates/ volumes. The following wording is, therefore, recommended;
‘*For minor applications* peak run-off rates from development must be the lower of the two following options: either the greenfield rate in terms of volume and flow; or the existing rate/volume of discharge. *For major applications appropriate run-off rates and volumes should be determined in conjunction with the LLFA*.’
Please see attached submitted document for full comments.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28136
Received: 22/07/2024
Respondent: East Sussex County Council
ENV2: Sustainable Surface Water Drainage (vii), p372; Part (vii) of the policy should be modified to ensure existing flood flow paths are also taken into consideration. The following addition is, therefore, recommended;
‘new development should utilise opportunities to reduce the causes and impacts of all sources of flooding, ensuring flood risks are not increased elsewhere, *that existing flood flow pathways are maintained*, that flood risks associated with the construction phase of the development are managed, and that surface water run-off is managed as close to its source as possible’.
Please see attached submitted document for full comments.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28137
Received: 22/07/2024
Respondent: East Sussex County Council
ENV2: Sustainable Surface Water Drainage, para 11.21, p375; Please add ‘where appropriate’ to the last sentence.
Please see attached submitted document for full comments.