Object to EC1 with the following: There are not enough spaces for carparking as it is- the small carpark often over flows on the street for residents. Even with the proposal for extending a carpark- it would need to be very big to include existing households- assuming 10 properties have 1-2 vehicals. The lane itself is not suitable for extra traffic, with heavy farm machinery in constant use. It is often very busy and the extra traffic would be unsafe and impractical to the quiet part of Etchingham. Houses proposed are VERY close to existing and far too many. The construction noise will impact those who work from home and cause loss of earnings. Houses squeezed in to north end will impact privacy of houses, and the light of dwellings would change the environment hugely. This is a flood plain, the field floods as does the carpark and the field.

EC1.
Oxenbridge Lane is not a suitable road for extra traffic flow especially during construction and traffic from new homes.
Where will existing cars park when parking area taken away, can't be on the Lane as per above! Car Park at south end floods as it is.
Bottom of EC1 site floods at south end, aware its been considered but has an impact on area!

Noise during construction in such a confined area will have a huge impact on surrounding properties, some of which work from home so there will be loss of income for a period which will impact residents.

Privacy reduced massively with having so many houses squeezed in behind existing homes looking over the site!

It feels like the site hasn't been given enough consideration and that homes are just being squeezed in, not considering surounding roads, size of site, existing homes and impact on landscape!

EC1: As a resident of Oxenbridge Lane for over 40, I do not agree with the building behind these properties.
1. Building on greenbelt is environmental destruction, not to mention the red belly newts that frequent this area.
2. Although it states that the houses are at low flood risk, access would actually be high.
3. Historic traffic problems for pedestrian have never been resolve, over the last 50 year high traffic volumes speed through the village with no calming systems in place and now the plan is to add more.
4. The run off for all of these will be straight into the Dudwell, along with any pollution.
5. This will not only change the view from this row, it will remove it completely and therfore devalue the houses purchased in this row. Furthermore, this will detrimental to the mental health and wellbeing of its residents.

I object as this will cause further issues with flooding and impact on the biodiversity in the area.

I particularly object to proposed sites EC1 & EC2. Increased congestion from traffic on church lane, where there are no footways, this increases the risk to pedestrians using the highway, there is already inadequate parking provision for the single row of cottages, making this stretch of road a single carriageway
The carriageway already floods causing damage to the properties already situated on church lane and I am concerned the development will increase the run off from the surface of the propised development will increase the problem.
The increased traffic on oxenbridge lane will make an already congested area much worse. There is inadequate parking for the existing dwellings making driving dangerous at the top of oxenbridge lane.

I object to site proposed in Etchingham, site plan EC2. I is totally unsuitable. It is in a flood zone 3b. It always floods, to the point the road has to be closed, this happened only yesterday. The water runs off all the fields opposite the cottages there. In past years several of the houses have flooded. The road is already busy, with traffic and footfall, which becomes dangerous now, let alone when traffic is diverted from A21 when it is closed which can be regular. The impact on the residence will be immense, and they will lose there privacy, and view, they already have a trainline behind them. Property will be devalued. The impact on wildlife will be massive, there are Bats, Barn and Tawny owls, Swallows, woodpeckers and Deer, plus much more. We are also a dark skies area. All this environmental degradation, just for a few houses.

I object to the proposed allocation of Site EC2 (Land at Church Lane, Etchingham) on the grounds that it is fundamentally constrained by flood risk, suffers from recurrent real-world flooding, and cannot meet national or local planning policy tests for safe and sustainable development.
We live on Church Lane and experience these flooding conditions directly. The lane floods in periods of prolonged or intense rainfall, affecting access, surrounding land and nearby properties. We are increasingly anxious that the proposed development would significantly increase the risk to our own home, safety and ability to access or leave the area during flood events. The allocation of new housing on land that already contributes to flooding would place additional pressure on an environment and drainage system that is demonstrably failing. This is not an abstract concern but a lived reality for residents who already contend with recurring flooding and its impacts.
I object to the proposed allocation of Site EC2 (Land at Church Lane, Etchingham) on the grounds that it is fundamentally constrained by flood risk, suffers from recurrent real-world flooding, and cannot meet national or local planning policy tests for safe and sustainable development.
1. Church Lane is a proven flood location, not a hypothetical risk
East Sussex County Council’s Flood Risk Study – Church Lane, Etchingham was commissioned specifically because of repeated flooding incidents affecting Church Lane and adjacent properties. The study confirms that there have been numerous flood events which have impacted on the residents of Church Lane. Flooding typically occurs after prolonged rainfall and causes flooding of the highway and curtilage flooding of properties. The flooding is caused by a combination of surface water runoff and groundwater emergence, not a single easily mitigated source. The lane sits in a low-spot, constrained by a railway embankment which limits the conveyance of flows.
This demonstrates that Church Lane flooding is chronic, multi-mechanism and structural, not occasional or easily engineered away.
2. The site fails the “safe access and egress” test
National planning policy requires development to be safe for its lifetime, including safe access and escape routes during flood events.
The Flood Risk Study documents that flooding regularly affects the highway itself and the lowest parts of Church Lane, which are the main access route to the proposed site. Photos and site inspections recorded standing water, boggy ground, blocked conveyance routes and overwhelmed drainage systems.
Even where the dwellings are placed on the least at risk northern portion, residents would still depend on Church Lane for access and evacuation. A development cannot be considered safe if the only access route is known to flood.
3. The Local Plan itself acknowledges the site is fundamentally unsuitable
The draft allocation already concedes that the southern portion lies in Flood Zone 3b (functional floodplain) and is unsuitable for development, and that development must be restricted to a small remaining area and supported by a site-specific Flood Risk Assessment.
This is not a resilient or robust allocation. It is a highly constrained, marginal site being carried forward despite clear evidence of flood risk.
The Flood Risk Study explicitly states that current measures will not resolve the associated flood risk experienced across Church Lane, and that only further feasibility studies and major interventions might partially reduce risk. Even the professional evidence does not conclude that Church Lane flooding can be satisfactorily resolved.
4. Development risks worsening existing flooding
The study identifies that flooding is driven by runoff from elevated fields to the south-west, groundwater emergence linked to clay and sand geology, and restricted outflows due to infrastructure constraints.
Introducing housing, hard surfacing and engineered drainage into this system risks increasing surface water runoff, reducing natural land absorption, and further overloading already constrained drainage routes. The study notes that groundwater already reduces the capacity of the existing sewer during rainfall events. Additional development would place further pressure on a system already demonstrated to fail.
5. The planning balance does not justify the risk
The site is proposed for approximately five dwellings only. This is a very small contribution to district housing numbers.
Against this must be weighed the presence of functional floodplain, repeated historic flooding of the access route, acknowledged unresolved mechanisms of flooding, ongoing drainage and infrastructure failures, and real risks to existing and future residents.
Given the availability of alternative sites elsewhere in the district which are not constrained by functional floodplain and recurrent access flooding, it is not justified to allocate a site with such clear and documented hazards.
Conclusion
Site EC2 is not a precautionary or sustainable allocation. It is a site already known to flood, served by a lane with a recorded history of flooding, in a location where professional evidence confirms the mechanisms of flooding are complex, recurring and unresolved.
The site therefore fails the Sequential Test, raises serious doubts under the Exception Test, and cannot reasonably be described as safe for its lifetime.
I strongly request that Site EC2 is removed from the Local Plan.

Please see attached photos and video attachment.

I am objecting to Policy EC2. During my 19 years living on Church Lane, the Lane immediately opposite the proposed site has flooded severely, every Autumn and Winter on numerous occasions. The latest being last week, 28/01/26 when Highways actually closed the road due to cars being stuck in the flood. We could not get our cars off our drive for over 8 hours. This site will most definitely fail the Sequential Test as it is a major flood risk and there are other safer sites locally. It will fail The Exception Test as it will not be safe for its lifetime putting its users in a very vulnerable position as they will not be able to access or exit their properties during flooding.
Development will make flooding worse as it will contribute to increased surface water run off, reducing the ability of the already sodden land to absorb any more. The existing sewer already overflows during flooding so further development would place extreme pressure on an already failing system. Site EC2 should be removed from the Local Plan as it will undoubtedly put the row of cottages at continuous threat of severe flooding and this is just not fair or acceptable.

EC1 site behind houses in Oxenbridge Row and including small car park to North and near river which runs between Etchingham and Burwash

This area is subject to regular floods at intervals. The density of six houses on the site will reduce the flood plain further.

It is not suitable as a site for building. The area for parking is nearest to the river which floods making it a liability for vehicles parked there.

OBJECTIONS TO PROPOSED ALLOCATION OF SITE EC2 (CHURCH LANE, ETCHINGHAM)
We would like to register our strong objections in relation to the Proposed Site Allocation EC2.
The site is located on a sloping field adjacent to a narrow road with no street lighting or pavement. As there are so few houses along this section of the road, it has the character of a country lane.
The distance to the nearest centres of Hawkhurst and Heathfield means that sustainable modes of transport such as walking or cycling are not an option. It is therefore likely that future occupants of any proposed housing would rely on private vehicles to access day-to-day services and facilities. This likely reliance on cars, with no guarantee of the use of low- or zero-emission vehicles, would conflict with any objective of supporting the transition to a low-carbon future. As such, the proposal would not achieve good levels of sustainability.
We also question whether refuse collection vehicles, fire engines, ambulances, removal lorries, and indeed construction traffic itself would be able to navigate the narrow lane effectively – let alone any visitors’ vehicles (guests, delivery vans, etc.) This would exacerbate the situation and result in any ‘overflow’ vehicles parking out on the lane, when there is simply not enough space to do so.
In bad weather, Church Lane suffers from an excess of water from rain run-off. A stream of water grows alongside the south-western side of the lane leading down towards the village pond, such that it forms a puddle so large that it cannot be driven through. A recent example occurred on 27/01/26, and Church Lane was closed to traffic in both directions. This affected residents’ ability to access their homes. The construction of additional properties (with associated patios, driveways and parking areas) would worsen the situation with additional run-off. A new development could not be considered safe if its only access route is prone to flooding.
Even if the development were to be restricted to the northernmost portion of the site, we believe that it would be completely inappropriate; it would have an urbanising effect, introduce a greater degree of light pollution and would generally diminish the prevailing rural character of the site and its surrounding area.
We are also concerned that if this proposal is successful, it will be the first phase in a series of subsequent applications for more construction on the same piece of land. Approval of any proposal could also set a precedent for any past applications to be resubmitted, and new ones to be lodged, using this proposal as a precedent to spread housing into the space adjacent.
We concur with, and support, the objections you have received from other local residents, each of whom highlight a range of genuine concerns.
We believe that the adverse impacts of taking this development forward would significantly and demonstrably outweigh the benefits, and we therefore strongly request that the Proposed Site Allocation detailed in Policy EC2 is withdrawn from the Local Plan.

I strongly object to the proposed allocation of land at Church Lane, Etchingham (Policy EC2). I live in one of the cottages already built on Church Lane, directly opposite the proposed development site, and I am deeply concerned about the serious safety, flood risk, and health impacts this proposal would have on existing and future residents.

Church Lane is a narrow rural lane with no pavements, no street lighting, and poor visibility in places. As someone who uses this lane daily, I can state clearly that it is not safe for pedestrians or cyclists. Residents are forced to walk on the road, often stepping into hedges or gateways to avoid passing vehicles.

Traffic speeds are already an issue, particularly at peak times and when vehicles use the lane as a through route. Introducing additional housing will inevitably increase vehicle movements, deliveries, bin collection, and visitor traffic, all of which will significantly worsen an already unsafe situation and create potholes.

The policy suggests that traffic surveys and potential improvements could address this. In reality, there is no realistic way to make Church Lane safe without fundamentally altering its layout. The lane cannot accommodate pavements or widening without damaging the historic hedgerow and rural setting. Any so called “improvements” would either be ineffective or harmful, and they would still leave pedestrians and cyclists exposed to risk.

From lived experience, I do not believe safe access for all users can be achieved. Allocating housing where safe access is uncertain and dependent on future surveys is unsound. A substantial part of the site lies within Flood Zone 3b, the policy itself acknowledges that the site must pass the Sequential Test and potentially the Exception Test before it can be formally allocated. This alone demonstrates that the site is highly constrained and unsuitable.

Allocating the site before these tests have been passed is premature. National planning policy is clear that development in functional floodplain should be avoided, not partially developed with the remainder left as mitigation. Flooding affects access routes, surrounding land, and existing homes. As a resident living opposite the site, I am particularly concerned about how floodwater movement, surface water run off, and emergency access would be managed during flood events, especially as climate change increases the likelihood and severity of flooding over time. The risks are real, long term, and unresolved.

The proposal also undermines health and wellbeing. While the site is described as being within walking distance of village services, Church Lane is not a safe or accessible walking route. This is especially true for older residents, disabled people, children, and anyone with reduced mobility. As a result, any new residents would be forced to rely on cars for even short journeys, increasing traffic and reducing opportunities for active travel. This directly contradicts planning objectives around promoting healthy lifestyles, reducing car dependency, and addressing inequality.

The site currently forms part of an open, undeveloped field that supports local wildlife and ecological connectivity, particularly along the roadside hedgerow and across the low lying land associated with the floodplain. I regularly observe birds, bats, sheep, owls, dears etc. using this field as feeding and sheltering. The roadside hedgerow is a historic field boundary and provides important habitat and connectivity. Even limited removal to create access would fragment this habitat and reduce its ecological value. Increased lighting, noise, domestic activity, and vehicle movements would further disturb wildlife, particularly nocturnal species.

This proposal therefore conflicts with the objective of achieving measurable biodiversity net gain and risks incremental harm to wildlife through loss of habitat, disturbance, and reduced ecological connectivity. Once lost or degraded, these features cannot be meaningfully replaced within such a constrained site.

Given the very small scale of the site (five dwellings), the cumulative requirements for site specific flood risk assessment and mitigation, potential highway safety works, hedgerow retention and protection, relocation of overhead power cables, provision of policy compliant affordable housing, it is highly questionable whether this site is viable or deliverable. A site that is unlikely to be delivered cannot be considered effective or justified, and should not be allocated within the Local Plan.

For these reasons, I strongly object to EC2 and the allocation of land at Church Lane, Etchingham, and urge the Council to remove this site from the Local Plan.

This is a quiet bit of land that backs onto my house which I do not want, Along with every resident that lives here.
Besides this, The field is on a flood plain which has flooded 3 times in the last 2 weeks and is simply not suitable to be buying houses on.
I have also owned animals that use this field.

EC1 - This is a quiet bit of land that backs onto my house which I do not want, Along with every resident that lives here. Besides this, The field is on a flood plain which has flooded 3 times in the last 2 weeks and is simply not suitable to be buying houses on. I have also owned animals that use this field.

I and many others strongly object to the planning proposed in Etchingham of 10 houses down Oxenbridge Lane (EC1). The site is of utmost ecological importance to the wildlife of the Dudwell Valley, where almost 1,000 species of moth have been recorded, including many rare species seen almost nowhere else in southern England. The site would also be cut off from access when the area floods, which is very common, happening several times each winter. The only other access would be through private land, which is not approved by the owner. There are several other suitable locations for building, including the fields adjacent to the school. Dozens of residents of Etchingham feel the same way, and feel that our village would be irreparably damaged by such building on the Dudwell River.

I strenuously object to proposal EC2 as the proposed five new dwellings would cause increased flooding risks for those properties opposite that site. Fundamentally unless proper drainage is finally installed and maintained to carry the residual water away from Church Lane during heavy rainfall then the idea of creating more housing here is totally proposterous. Naturally water follows its own course and would pool around the slope on this proposed site and flow down into the road instead of seeping into the ground that these new buildings would occupy. So again unless adequate drainage was implemented it would be a total falisy and potentially disastrous for those already residing in this part of the village. Also there are sharp bends along this narrow and at times busy lane, so therefore any new access to it from the proposed site potentially would be hazardous as coming out directly onto it could cause accidents. My chief concerns are therefore concerning the flooding risk and risk to the users of this part of Church Lane.

EC1 site access via Oxenbridge Lane is totally unsuitable for lorries and building transport – the road is rarely in a good condition. The bottom part of the proposed site is also liable to flooding.

EC3
Church Lane is far too narrow to support more traffic and the proposed site is too close to the bridge across the rail line. It is impossible to see what is coming from either direction on the bridge and cars leaving from new properties would create a significant hazard. Although a nod to flooding is raised in the report, I would remind the council that Church Lane floods regularly on the approach to Sheepstreet Lane and further down Church Lane near the small industrial site. Residents could face being stranded. This area is not known as the Etchingham paddy fields for nothing, and with climate change accelerating it would be very short sighted to risk more development here.

Etchingham is a very small community without an any services that include; shops, doctor surgery, parking, dentists, banks, pubs, entertainment, etc. We were assured over 10 years ago that the 50 residences that were built, were enough. It is a site of outstanding natural beauty and peace and the plan is for a very large number of houses that with dwarf the residences currently existing. It is such a bad idea and will dilute our lovely village and make parking and driving very crowded and the limited services in a neighbouring villages overstretched. There are no brown field sites in the village so the proposal is for farmland, which we will need to aid the UK’s food programme, to assist in food production and lesson reliance on imports.

I understand that new building needs to happen and whilst many offer the objection ‘Not in my neighbourhood,’ I agree that Etchingham does need more housing. However, I object to the development on Church Lane due to ongoing issues with flooding; I would be very concerned about more development increasing flood risk for the existing Rother View properties. I also hope that the development near to Parsonage Croft is affordable to local people, where the large houses there currently are out pricing first time buyers. We need to keep young people/families in the village for its future success.

My concerns are the increase of traffic in Etchingham which is already busy enough, the pressure already felt by local doctors, the lack of any convenience stores leading to more traffic also. A large portion of local residents are retired & moved here for the quiet & slow pace of life, and finally there is the concern of the possible impact it may have on property prices. Surely there must be better options than sleepy Etchingham ?

re all sites EC1 to EC3: to protect the High Weald's intrinsically dark skies, sites should not feature any external lighting not necessary for safety purposes. All such lighting should be designed in accordance with Policy LAN3 and in reference to the High Weald National Landscape Unit’s Technical Advice Note on Dark Skies in the High Weald.

The village cannot support the amount of new families who would move into these properties.
The infrastructure is at breaking point already! Roads are a dangerous mess, not to mention the lack of drain maintenance!
The school cannot facilitate the volume of children who would potentially need places!
The council don’t even want to facilitate a safe place to cross the main road near the school! Just a joke! Build lots of houses but get run over crossing the main road to get to school!
I do believe as much as etchingham is on a flood plain that where some of these proposed houses are going to be built, flooding is most common!

EC1. This is a flood plain which is not a suitable for more housing with other location being alot more suitable. I have lived next to this field for 32 years and it is an important part of the local environment. Being the main run off and natural drainage point to the river when it rains, plus wildlife.
Im also concerned with how this will alter the traffic, noise and reduced privacy. The entrance would be through a 4 car carpark that I currently use. This is an already terribly surfaced and underlooked area by the council. Further traffic will cause accidents on this small lane that has huge lorries and tractors using it daily.
I urge the council and government to find alternative areas for a project like this

As the owner of Church Farm, I was asked if we would be willing to sell the land comprising EC2 and EC3 for development. We generally support the Council’s strategy, but any development must be in line with the character of the village and is contingent upon the provision of the appropriate infrastructure. The EC3 site cannot accommodate 55 dwellings.

The village cannot cope with the extra traffic and footfall

I don't agree with the proposed sites EC2 and EC3 as they are green field sites and they are distroying our beautiful countryside. I consider EC3 to be ribbon development along the road and will extend the village beyond its boundary eventually merging with Burwash. There will be no defining boundary to the village. The exit onto the A265 will be dangerous from site EC3 as it is a busy road and people speed along the 'staight mile'. I am disturbed about the loss of habitats for wildlife and the slow urbanisation of our beautiful village and surrounding countryside.

Site EC1 would be very dangerous pulling out onto oxenbridge road as visibility is obscured by the bridge. And cars come very fast down the road. Would be an accident waiting to happen.
Also I'm aware the flooding has been addressed but I believe moving the houses to the northern part of the site will reduce house worth of the existing houses of park farm close and oxenbridge lane.
Not to mention destroy the scenery of aforementioned houses. And cause more noise pollution and cause damage to the local wildlife in that area.
I believe the other sites EC2 and EC3 to be better options.

Comments following the Public Forum

1. What is the basis for requiring Etchingham to provide 70 new dwellings?
2. Is the assumption that there is a lack of housing in the locality for local people or that there are work/business needs that are the generators or is it assumed that new residents would be using the local train station to access work? If the latter it should be noted that Etchingham station car parks are almost completely full now on every week day. Given that there is a very large number of new houses proposed for Burwash and Hurst Green this just exacerbates the problem.
3. Was the 2017 Neighbourhood Plan study on which I served as an architect on the Sub-Committee properly reviewed with its recommendations for housing layouts on the various sites?
4. If, and we say if, the figure of 70 is non negotiable what research was undertaken in advance to check on the following:
- Availability of brownfield as opposed to greenfield sites
- Topography
- Capacity of schools
- Capacity of Doctors surgeries and local dispensing pharmacies.
- Adequacy of existing drainage, water supplies, electricity; were local utilities consulted?
- Traffic and access points onto the main A265
- Etchingham only has a very small general store/post office and no other shops
5. Why has the Lambing Shed site not been considered as our study showed it to be a logical brownfield site for 10 starter homes always a much needed requirement? This should be included and should be either Local Authority or Local Housing Association not developer provided.
6. Why has the Crane site not been considered? Our suggested layout addressed the flood plain
7. We do not want the usual costly pastiche designs provided by developers; there is far too much locally. It should be a requirement that architects with considerable housing experience are used.

Sites EC1 & EC2 were raised within 2016 Neighbourhood Plan; it was recognised that flooding would be an issue at both and careful design would need to reduce the risks.
Site EC1: the landowners have offered this location where water run-off is likely. It seems they did not visualise anything like 55 dwellings. Whatever the agreed number of houses, it is important that the regulations concerning an A.O.N.B. are carefully observed. A turning-right lane on A265 is required for safety on a dead straight road.
General Observation: the Etchingham school is already fully subscribed, the Burwash doctors' surgery is at capacity. All the infrastructure throughout the village, including electricity supply and drainage will require substantial upgrading if 70 houses are built, implying a 25% increase in the village's present population.

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.