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.

This is a general comment, not an objection to RH1. I do, however, strongly object to RDC's ambiguous draft policy on protecting strategic gaps and will make my objection known elsewhere in my representations. Building of any any kind must NOT be permitted on the strategic gap between Rye and the industrial zone of Rye Harbour. Strategic gaps exist for good reasons; they are absolutely essential to preserving the character and appearance of ancient towns like Rye. In the case of this strategic gap, any building would adversely affect the historic views of Rye as seen from afar, and views from Rye itself. The housing would be built on flood plain beside the river and would require sacrificial ground floors, making the homes excessively high — which would harm vistas of historic Rye even more profoundly. It would be contrary to Rye Neighbourhood Plan and all planning precedent.

Folkestone & Hythe District Council supports the references to the Sustainable Access and Recreation Management Strategy (SARMS) in Policy RH1 as the site is located close to the internationally important nature designations at Dungeness, Romney Marsh and Rye Bay. FHDC will continue to work with Rother DC on the SARMS as it is updated. (Officer comments.)

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

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

Please see attached:
- Development Strategy and Site Allocations EA response (Part 1)
- Interim SA and IDP EA response (Part 2)
- Rother Draft Local Plan IDP Part B - EA amendments (Part2)

Part 1 - Development Strategy and Site Allocations

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

Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

We have provided advice and guidance
to strengthen policies and evidence to ensure the new Local plan aligns with
national, regional and local requirements.

Environment Agency Position

Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.

Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.

Further details are provided in:
• Section 1 – General recommendations
• Section 2 – Specific comments on proposed policies and sites

Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.

Our planning advice service

As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.

We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our
cost recoverable planning advice service.

Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally sensitive development.

We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

Part 2 - Interim SA and IDP

Consultation on the Draft Rother Local Plan 2025–2042 – Interim Sustainability
Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and Part B (the
Schedule)
Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Interim
Sustainability Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and
Part B (the Schedule). We have provided advice and guidance to strengthen policies
and evidence to ensure the new Local plan aligns with national, regional and local
requirements.
Environment Agency Position
Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.
Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.
Further details are provided in:
•
Section 1 – Infrastructure Delivery Plan (IDP) comments
•
Section 2 – Interim Sustainability Appraisals (SA) comments
We also attach the following document to our response:
•
Rother Draft Local Plan IDP Part B - EA amendments
Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.
Our planning advice service
As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.
We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our cost recoverable planning advice service.
Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally
sensitive development.
We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.