As the wastewater undertaker for Rother, Southern Water owns and operates wastewater treatment works established within the district. We request additional planning policy wording to cover possible odour impacts of existing businesses and facilities as accounted for in the NPPF. We explain our reasoning further below.
Requested changes:
Regarding specific forms of pollution:
(i) in relation to both noise and odour, consideration will also be given to the character of the location and established land uses. Also, in the case of new noise or odour sensitive development, the agent of change principle applies to the new development and appropriate design and mitigation must be provided in the new development to ensure the ongoing viability of existing surrounding uses is not compromised. Development which is sensitive to noise or odour must ensure an acceptable standard of environmental quality is maintained for future residents.
Developments in close proximity to existing uses which produce odour will provide an odour assessment in consultation with Southern Water to determine if any mitigating measures are required. If any measures are identified, the applicant must demonstrate how these have been included within the scheme.

Further explanation and justification:
Southern Water agrees with the policy from the perspective of noise. Our concern is that by restricting its scope to noise, policy ENV7 precludes any other existing environmental conditions that may have an impact on any ‘sensitive’ future development built adjacent or near to a WTW, such as housing, which could have an unacceptable impact on the amenity of the site’s future occupants arising from the WTW’s essential operational activities. Such impacts may include odour as well as noise and vibration.

Paragraph 193 of the NPPF (2023) seeks to ensure that ‘existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established,’ while paragraph 191 states that development should be appropriate for its location, and that living conditions of future occupants needs to be taken into account.

Full submission attached

Given the recognition of the valuable role played by trees in mitigating air pollution, we recommend strengthening the policy with reference to nature-based solutions.

eg in the introductory paragraphs, the wording could be expanded to read " Developments should put good design first to minimise the need for mitigation measures, including maximising the use of nature-based solutions."

The vehicles using Barnhorn Road emit invisible particulates PM10 and PM25 from noxious exhaust gases as well as particulates from brakes and tyres. This is evident in the black deposit which frequently settles on cars overnight; where there are visible particulates, there will also be the dangerous invisible-to-the-naked eye particulates. The danger to health will increase with increased traffic congestion.

Please see attached comments from Burwash Parish Council.

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

Please see full the Environment Agency's representations, please see attached submission document.