Demolition of inappropriate old houses in town centre needs to happen

This seems to be reasonable policy

Please see attached for full representation:

- Full representation on Draft Rother District Local Plan 2025-2042 Consultation (including underlined text and hyperlinks that do not appear in text copied out below)
- Supporting document: Southern Water input to Rother District Council’s 2026 IDP review
- Supporting document: IDP feedback provided for the Regulation 18 consultation deadline 23rd July 2024

Q5 We attach our separate IDP response to Rother as part of our feedback to this Regulation 18 consultation on the Local Plan, requesting update of the IDP in accord with the information and explanations provided. This also includes our feedback from the previous 2024 Regulation 18 consultation, in addition to a full explanation of how Southern Water plans investment for adopted local plans. Included within this explanation are our key AMP8 (2025-2030) investment plans for the Rother district. Some plans extend into AMP9, but for the reasons we explain in our IDP response, most AMP9 schemes are not known at this time.

There is considerable investment planned for the district in this 2025-2030 AMP8 period, supported by a range of technical disciplines. This represents the latest investment information and therefore supersedes the DWMP content referred to (as this DWMP work was concluded in 2023).

Q8 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q9 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q10 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q17 Q17 - all BX sites.

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording to all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to critical assets running beneath sites.”

Southern Water’s initial checks indicate that a number of the new/changed sites (BX6, BX7, BX22, 23, 24, 27, 28, BX31, 34, 36, 37, 38, 39 and BX41) may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and all those we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BX9 and may require easements or diversion. For this site, and any we’ve previously requested layout wording please include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q19 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

26 CR1 to CR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

However, we note that for site CR2 in particular, there is no wording in the site allocation policy to address the site’s proximity to an operational wastewater treatment works. In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site CR2 is within 500m of Battle wastewater treatment works and we therefore request the additional wording –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

28 GU1 & GU2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for site GU2 at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Southern Water infrastructure crosses GU2 and may require easements or diversion.”

30 GU4 & 5

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site GU5 and may require easements or diversion. For GU5, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

31 GU6

Southern Water has identified no constraints for this site at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

32 IK1&2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site IK1 and may require easements or diversion. For IK1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

34 WS1 WS2, WS3 WS4 WS5

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that sites WS2 and WS3 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site WS3 and may require easements or diversion. For WS3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

36 BT1 to BT11 (BT3, BT4, BT5, BT6)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to this site is within 500m of Battle wastewater treatment works and we therefore request the additional wording – The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

Southern Water’s initial checks indicate that sites BT1, BT2, BT7, BT9, BT10 and BT11 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BT11 and may require easements or diversion. For BT11, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

38 CT1 CT2 CT3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure may cross sites CT2 and CT3 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

39 NE1 & 2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

40 SD10 SD11 (SD1 to SD9)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site SD11 (and as previously advised the for the existing site allocation SD7) is within 500m of Sedlescombe wastewater treatment works and we therefore request the following additional wording in these policies–
The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

42 BC1 (BC2) BC3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site BC3 and may require easements or diversion. For BC3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

43 (BR1) BR2 BR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

44 CM1 to CM3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

45 (ID1) ID2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site ID2 and may require easements or diversion. For ID2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

46 NR1 and NR2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for this site (NR2) at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

Additional policy wording is needed for each site to address it’s proximity to operational wastewater treatment works. The proposed boundary of each site is within 500m of an operational wastewater treatment works (Mill Corner Northiam WTW, and Quickbourne Lane Northiam WTW) and we therefore request the additional wording for each site policy –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses site NR2 and may require easements or diversion. For NR2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

47 PE1, 2 & 3 (PE4 & PE5)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

49 (RY1 to RY1, RY7&8) RY5, RY6 & RY9

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that sites RY5 and RY9 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses sites RY5, RY6 and RY9 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

50 RH1

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

53 BW1 to 4

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that site BW1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Please note that Southern Water wastewater sewers cross all BW sites (BW1 to 4) and may require easements or diversion (so please note that whilst we agree that consultation with Southern Water will be required, it may not be necessary for the developer to deliver a package treatment plant as currently stated in part Xi of the policy. Were the developer to want to deliver such plant they will first need to consult with the Environment Agency). For these sites, and any we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

54 BWC1 and 2

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

55 EC1 to 3

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site EC1 and may require easements or diversion. For EC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

56 (HG1&2) HG3 & 4

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that site HG4 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses site HG3 and may require easements or diversion. For HG3, and any sites we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

57 RB1, RB3, RB4 (RB2, RB5) to RB6a & RB6b

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to sites R3 and R4 (and also as will have been previously advised the boundary to existing site allocation RB2) are all within 500m of Robertsbridge wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses sites RB3, and RB5 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

58 SC1 & 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site SC1 and may require easements or diversion. For SC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

59 FW1 to FW3

Southern Water’s initial checks indicate that site FW2 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure crosses site FW2 and may require easements or diversion. For FW2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

60 TC1 (or 2)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water’s initial checks indicate that site TC1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure also crosses site TC1 and may require easements or diversion. For TC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

62 SG1 or 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundaries to each site are within 500m of Stonegate wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Southern Water infrastructure crosses these sites and may require easements or diversion. For these sites please therefore also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q64 GYP1 to GYP6

Southern Water’s initial checks indicate that some of the GYP sites are proposed within 500m of operational wastewater treatment works. For example, the boundary to site GYP6 is within 500m of Robertsbridge WTW.

We therefore request Rother consult us on planning applications for all sites so that we can share the results of more detailed checks with the authority. Southern Water also request the addition of the following wording for all sites –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

And for each site proposed within 500m of operational wastewater treatment works (eg GYP6) please include the following additional wording;
“The layout of ‘sensitive residences’ for any site allocation within 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Q69 Any other issues or comments?

All site allocations should be proposed in locations where utilities can provide for the forecasted needs of the development without prejudicing existing or future utility provision necessary to support growth. Southern Water therefore requests the following additional policy wording in the Regulation 19 draft of the Local Plan:
The utility network should be protected and development proposals that would compromise existing utilities infrastructure, or encroach on future connections for utilities, will be refused. Opportunities should be sought to safeguard the provision of utilities wherever possible.

Removing Sainsbury’s? A well used supermarket in the town. Easy access. Plus removing more parking in wainwright Road? This town is being ruined with little parking (free or cheap) as it is. The council seem to want to ruin the town. Also more houses and no infrastructure to back it up! No dentists, no doctors, no schools. Poo in the sea. Roads are falling apart! The list could go on.

Much more investment needed in Central Urban Bexhill's basic infrastructure.To include Doctors surgeries, schools, community centres, water supply & drainage.
With so much outer town housing development having already taken place & a great deal more planned, current road capacity is not sufficient coupled with a lack of in town parking.
Traffic calming & traffic speed enforcement is essential considering the volume of vehicles the centre of the town needs to accommodate. The safety of residents & environmental considerations should be paramount.

Planning consultation: Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations and Interim Sustainability Appraisal and Infrastructure Delivery Plan.

Thank you for your consultations on the above dated 26th January and 11th February 2026, which were received by Natural England on the same days.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

We note that we previously provided comments on your Draft Rother Local consultation (our reference 359662) where we focused on the use of Natural England's 'Green Infrastructure Framework - Principles and Standards for England' (GIF) and briefly touched on other matters previously discussed with your authority. These comments remain valid (I have attached a copy for convenience) and the comments below, in relation to your latest consultations, will have a similar focus. The absence of comments on other matters within the Plan should not be taken as Natural England having no comments to make but that we have prioritised our advice. In particular, we have not commented on SA or HRA concerns (other than in relation to the Dungeness Complex, below), or any protected landscape concerns nor reviewed the allocations.

Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

Key sustainability issues

Plan- Making for Biodiversity in the Climate Emergency

Given the severity of the decline in biodiversity and the climate change emergency, local plans have a key role to play in planning for resilience, forecasting, and making space for nature to adapt to a changing climate. Plans should seize the opportunity to help to reverse this decline through ambitious and integrated plan-making which demonstrably avoids and minimises impacts and seeks all opportunities to help reverse the biodiversity decline.

Green Infrastructure

Plans must adopt a strategic approach through multifunctional green infrastructure provision and nature recovery networks. To this end, we welcome the incorporation of green and blue infrastructure provision within several of your site policies. In particular, we welcome the embedding of Natural England's GIF within Policy BX1 – Bexhill Urban Area. However, we recommend the strengthening of the wording, by clarifying the meaning of ‘Where appropriate…’ in the context of this policy and by requiring the use of the Urban Greening Factor (and incorporation of ‘…measures to support…and biodiversity enhancements’). To this end, we suggest the use of ‘must’ rather than ‘should’, in paragraph four of the policy text. We recognise the existing urban nature of this policy’s geographical area but this increases the likely need to provide green infrastructure within new developments (NPPF 20 d), 96 c) and 125 a).).

We also welcome the requirement within Site Policy BX8, that development ‘on this site must:…iv. Provide a Green Infrastructure framework that retains and enhances habitats, alongside sustainable drainage (SuDS) measures;…’

Additional Comments:
Local Nature Recovery Strategy (LNRS)

Spatial Strategic Objective (Figure 1) – We welcome the inclusion of an objective to ‘2. Maximise opportunities for nature conservation, recovery…’ However, although some of your previously proposed policies include the requirement to meet the objectives of the LNRS (non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain), there is currently no reference to the emerging LNRS. This section of the Spatial Strategic Objective would be a suitable place to support those policies and the NPPF (192 a)) by the addition a similar requirement, in relation to complying with the LNRS.

Designated Sites

Figure 11: Rother Development Strategy – Key Diagram – a pictorial representation of the development strategy

For completeness, this figure should include the Beachy Head East (Royal Sovereign Shoals) Marine Conservation Zone. Although the intended environmental interest coverage is not specified, it should be noted that Sites of Special Scientific Interest and Local Nature Reserves are also missing, so if these have been deliberately omitted, perhaps the addition of some text explaining the choice of environmental sites should be included by way of clarification.

Habitats Regulations Assessment Background Paper – Draft (Regulation 18) Version – January 2026

Further to our previous advice in relation to addressing recreational pressure on the Dungeness Complex, we would take this opportunity to repeat advice given on 19th January 2026, regarding the need to update the visitor surveys and to devise an appropriate mitigation strategy:
Natural England are concerned about delays in the production of a suitable mitigation plan; especially in view of the age of the original visitor surveys. The detailed mitigation within the SARMS would need an updated evidence base. However, if such surveys indicate that recreational use is predominantly from visitors from outside of the local authority area, it may be that mitigation would more appropriately be addressed through a ‘Coastal Code of Conduct’ type approach, rather than via developer contributions. The details of such an approach would need to be discussed with our protected sites colleagues.

Infrastructure Delivery Plan
We welcome the recognition of green infrastructure as a type of infrastructure (2.23) and for your authority’s commitment to “Integrate community centres into wider green infrastructure…” (4.22 c.). We also welcome your authority’s aim, as set out in the Council’s strategic objectives and in the Rother Climate Strategy 2030, to place strong emphasis on enhancing the quality, accessibility, and multifunctionality of the green infrastructure network. (7.12).


Please see attached PDF version of these comments as well as Natural England’s comments in response to the previous 2024 Regulation 18 consultation on the draft Local Plan.

Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation

We support the policy wording in principle. The draft policy is generally positive with the aim of encouraging denser forms of development within Bexhill which is well placed to accommodate new growth. We also welcome the flexibility regarding car parking and transport as it is in line with the approach encouraged by the NPPF, and on the basis that the town centre is well served by public transport, shops, services and employment opportunities.

With specific regard to density, the cap of 110 dph falls below the range identified in Figure 9 and the updated Density Study. Given the findings of the study, consideration should be given to increasing this figure to 125 dph. This will allow more dense forms of development in appropriate locations. The wording is sufficiently flexible to allow for fewer dense schemes to take account of local circumstances and characteristics. Consideration should also be given to amending the wording of the second to last paragraph (relating to conservation areas) to reference density e.g. “…responding carefully to the area’s heritage context, particularly in terms of scale, mass, street frontages and density.” This should ensure that density is a consideration when assessing schemes in the Conservation Area. Subject to this amendment, the Policy should encourage more dense schemes in appropriate locations whilst allowing a suitable level of protection for more sensitive areas.

There are no boxes on the consultation to object to BX5, residential development on the car park and not enough infrastructure for residents already in the area. BX7, the 75 dwellings to be built on top of the present Sainsburys store, no supporting infrastructure or parking. BX13, well used car park especially as there is a lack of onstreet parking in the town centre for visitors and residents.

The area south of railway line that includes the Egerton Park, the beach and the tennis courts etc is our tourist and leisure area and includes houses that the Earl De La Warr himself commissioned and had built that surround the park and it should not be designated 'Urban area' when it would be ruined by the very high density housing planned for the 'urban area'.
..........'Live well locally' you say but plan to build on gardens. People will desperately need the restful peace and beauty of the leisure/tourist area as refreshment from being crammed into the high density housing or as relief from the vilely cold wet and blustery winter cycle journeys you hope they will make to and from work.

The area south of railway line that includes the Egerton Park, the beach and the tennis courts etc area is our tourist and leisure area and includes houses that the Earl De La Warr himself commissioned and had built that surround the park and it should not be designated 'Urban area' when it would be ruined by the very high density housing planned for the 'urban area'.

'Live well locally' you say but plan to build on gardens. People will desperately need the restful peace and beauty of the leisure/tourist area as refreshment from being crammed into the ghetto-like high density housing or as relief from the vilely cold wet and blustery winter cycle journeys you hope they will make to and from work.

See attached letter responding to questions 7, 8, 10, 12, 17, 19, 20, 21, 22, 36, 48 and 69.

See attached letter responding to questions 7, 8, 10, 12, 17, 19, 20, 21, 22, 36, 48 and 69.