Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25940
Received: 23/07/2024
Respondent: Southern Water
We request correction of a statement made in the narrative of paragraph 11.3 on page 368 of the explanatory text for Policy ENV1. Southern Water is not the only organisation with drainage responsibilities across Rother. As flood and surface water drainage responsibilities are not described elsewhere within the draft Local Plan, we request the following change to prevent readers from misunderstanding Southern Water responsibilities at the exclusion of all others:
11.3…Southern Water has a Drainage and Wastewater Management Plan as well as a Water Resources Management Plan as Southern Water is the wastewater provider for the Rother district, also supplying water to parts of the district.
Land drainage responsibilities rest with multiple organisations - a more detailed explanation is provided in our full response, and also available here:
https://www.lgo.org.uk/make-a-complaint/fact-sheets/environment-and-waste/flooding-and-land-drainage-issues#:~:text=These%20are%20all%20other%20watercourses,and%20drainage%20works%20on%20them.
We request correction of a statement made in the narrative of paragraph 11.3 on page 368 of the explanatory text for Policy ENV1. Southern Water is not the only organisation with drainage responsibilities across Rother. As flood and surface water drainage responsibilities are not described elsewhere within the draft Local Plan, we request the following change to prevent readers from misunderstanding Southern Water responsibilities at the exclusion of all others:
Requested changes:
11.3…Southern Water has a Drainage and Wastewater Management Plan as well as a Water Resources Management Plan as Southern Water is the wastewater provider for the Rother district, also supplying water to parts of the district.
Further explanation and justification:
Land drainage responsibilities rest with multiple organisations, as well documented across numerous Strategic Flood Risk Assessments, various online sources and well discussed in the consultation sessions for the Drainage and Wastewater Management Plan (DWMP). Responsibilities for maintaining drainage channels and road drainage networks can include land owners, the Highways Agency as well as some councils – a more detailed explanation of the various responsibilities for flood and land drainage is available here:
https://www.lgo.org.uk/make-a-complaint/fact-sheets/environment-and-waste/flooding-and-land-drainage-issues#:~:text=These%20are%20all%20other%20watercourses,and%20drainage%20works%20on%20them.
The statement –
‘Southern Water are the drainage provider across all of Rother’
is therefore misleading to readers, particularly in the absence of similar descriptions for all other individuals/organisations with active drainage responsibilities across Rother.
In addition, according to earlier sections of the draft Local plan the Rother district is:
• 83-90% countryside (see Local Plan paragraphs 1.30, 1.34, 1.35).
• Predominantly exposed to flood risk from the sea, rivers and watercourses, although the district also suffers from surface water flooding (see Local Plan paragraph 1.36).
This broader context further establishes the multi-organisational responsibilities that will exist in relation to surface water management and flood across the Rother district (rather than Southern Water having responsibility for draining all such areas, or to drain flood arising from the sea, rivers or other watercourses).