Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25946
Received: 23/07/2024
Respondent: Southern Water
Southern Water supports the intention to ensure and protect land stability. However, we are concerned that the current wording of policy ENV3 may create a barrier to developers from delivering essential sustainable drainage infrastructure required to serve planned development without increasing flood risk. We therefore request the following wording changes to ENV3 to ensure its effective application and implementation:
The use of infiltration to manage surface water will not be allowed in these areas (of unstable/potentially unstable land) unless a qualified geotechnical engineer has assessed the risk.”
Southern Water supports the intention to ensure and protect land stability. However, we are concerned that the current wording of policy ENV3 may create a barrier to developers from delivering essential sustainable drainage infrastructure required to serve planned development without increasing flood risk. We therefore request the following wording changes to ENV3 to ensure its effective application and implementation, explaining our reasoning further below.
Requested changes:
The use of infiltration to manage surface water will not be allowed in these areas (of unstable/potentially unstable land) unless a qualified geotechnical engineer has assessed the risk.”
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. Whilst we understand the intention of this policy, we raise concerns that with the current wording, this planning policy might be interpreted to apply to all infiltration SuDS in all locations. Also that viability will be particularly important to ensuring SuDS delivery, particularly for affordable homes and single-dwelling development.
Given the amount of work water companies are undertaking to reduce CSO spills and the level of investment necessary to remove surface water from the network, 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 geotechnical assessment only where the conditions warrant it.
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
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26404
Received: 17/07/2024
Respondent: Burwash Parish Council
Where there is infilling of land, clear deliverable infrastructure management plan on where the soil comes from. If the levels are changes through infill, that change is correctly implemented and overseen and agreed.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27182
Received: 22/07/2024
Respondent: Westfield Parish Council
See points 256-257 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: 27196
Received: 23/07/2024
Respondent: Derek Tomblin
A summary of the objections to development at Sandrock Park, Hastings:
Flooding: replacing ancient woodland on this high ground at the top of The Ridge with 140 houses will cause massive drainage, sewage and flooding problems for all properties downstream from this area. Businesses will also be affected further downstream in the town.
Traffic congestion: The Ridge is already over used at key times. Placing 140 houses in a critical and difficult part of the bend in The Ridge is just asking for more trouble. Additional access to existing estates leading to Elphinstone Road may also be proposed following on from the proposed development.
Loss of an accessible and wildlife diverse green space: the footpath and its surrounding woodland and meadow, provide much needed wildlife habitat, contributing to biodiversity, plus general access to green space, much used by the public, including young people on their way to and from the Ark School.
The big damaging issues from a housing development at Sandrock Park, Hastings are as follows:
Flooding: replacing ancient woodland on this high ground at the top of The Ridge with 140 houses will cause massive drainage, sewage and flooding problems for all properties downstream from this area. Businesses will also be affected further downstream in the town. The recent rainstorms have:
• damaged every manhole grill on The Ridge from the Conquerors March to the Cemetery. These were eroded underground causing considerable damage and expensive repairs for ESCC.
• damaged the dam in St Helen's Wood
• contributed to the recent flooding and sewage overflow in the town centre If excess rainfall continues to occur, as is predicted, then building on this land will contribute to further flooding.
Traffic congestion: The Ridge is already over used at key times. Placing 140 houses in a critical and difficult part of the bend in The Ridge is just asking for more trouble. Additional access to existing estates leading to Elphinstone Road may also be proposed following on from the proposed development.
Loss of an accessible and wildlife diverse green space: the footpath and its surrounding woodland and meadow, provide much needed wildlife habitat, contributing to biodiversity, plus general access to green space, much used by the public, including young people on their way to and from the Ark School.
Affordable housing is obviously needed but there are many other suitable sites for housing in the borough which do not require loss of a critical green space. This proposal will have disastrous consequences for many Hastings residents.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27840
Received: 23/07/2024
Respondent: Rye Neighbourhood Plan Steering Group
Proposed Policy ENV3: Land Stability
P354 Q183 – 185
“New development, including residential extensions and alterations, will only be permitted on unstable or potentially unstable land, including former landfill sites and coastal margins, where the nature of the instability has been properly assessed through a full land instability risk assessment report; and any remedial measures required to ensure that the development does not add to the instability of the site or surrounding land, are environmentally acceptable, and are normally implemented prior to the commencement of building works. The use of infiltration to manage surface water will not be allowed, unless a qualified geotechnical engineer has assessed the risk.”
(See reports of event on 26 Feb 24, extracted below. Applies particularly to any development on north side of Military Road)
Landslip onto Military Road : On Tuesday afternoon there was a significant landslip of topsoil and vegetation onto Military Road, 200 yds to the east of the Globe Inn. After the recent heavy rainfall, ground water in the Rye Hill escarpment has loosened the surface, causing several tons of debris to slip and block the road. At 0730hrs on Wednesday the road remained blocked.
There is a history of landslip in this area. Many years ago, Point Hill at Point Hill above the site of this event, had a tennis court, which slipped down towards Military Road. Several smaller landslip events have occurred since, both in the east and west of Rye.
Landslip is a risk which is recorded in the Rye Neighbourhood Plan in parts of Rye where the underlying sandstones, topsoil and vegetation is exposed to water and erosion.
To the north of the Military Road is a broad location from where spring outfalls occur, where the aquifers leak out at the base of the escarpment. Aggravated by more frequent extreme rainfall, this aggravates the risk of landslip.
https://www.ryenews.org.uk/community/riddle-of-our-hidden-reservoirs.
An earlier article on land instability is linked below and I will not repeat the detail here. The issue has been discussed at Rye Planning and Townscape meetings, but this latest event highlights the need to for the LPA to ensure that developers are fully aware by imposing strict conditions on any groundwork.
https://www.ryenews.org.uk/news/how-unstable-is-rye
Mike Pepler’s youtube video covers the extent of the slip.
https://youtu.be/2JtAMHL6Kio
It is noticeable that this latest slip occurred above an area where the base of the escarpment has been excavated and some vegetation removed. It is not too soon to link the two events and what is clear is that trees, shrubs and plants should not be removed from areas where there is risk of slip as the roots help to bind the surface soil.
Climate change indicates that we can expect more extreme and prolonged rainfall as there are changes to the Jetstream. Landslip risks are likely to increase in the future.
It is recommended that the land stability report for this project, which accepts that there is a risk of landslip, should be reviewed and reassessed.
Please see attachment