Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28240

Received: 23/07/2024

Respondent: Environment Agency

We are encouraged to note your intentions to prepare a comprehensive evidence base to inform the new Local Plan policies, and to make relevant evidence base documents available as part of consultation exercises, to set out justification for draft policies and help inform representations.

We look forward to working with you to update the evidence base to ensure that all decisions are informed and justified, in line with the ‘tests of soundness’ set out in the NPPF (Paragraph 35).

We are keen to share environmental evidence and data to inform Local Plan policies and planning decisions; data – including maps of Flood Zones, Source Protection Zones and so on – is available to download from the Defra Data Services Platform.

We should be consulted on any addendum to the Strategic Flood Risk Assessment and are involved where a Level 2 Assessment is necessary.

Please see full text in attached submission.

Comment

Representation ID: 28241

Received: 23/07/2024

Respondent: Environment Agency

We welcome your priority of being “Green to the Core” however, we would encourage your vision to be broadened to more clearly incorporate blue infrastructure, in line with your proposed policy “HWB5: Green and Blue Infrastructure” (page 211). We recommend the term “blue-green infrastructure” is used consistently to support the inclusion of urban infrastructure relating to water. These are both equally important sources of biodiversity and, if managed together, will have a cumulative benefit for the wider area and its residents. This is especially important for an Authority such as Rother, with low-lying coastal areas. We recommend policies that promote the re-naturalisation of riverbanks and streams for biodiversity, flood risk and public connection to nature.

We recommend amending “green infrastructure” to “blue-green infrastructure” or “blue and green infrastructure”.

Comment

Representation ID: 28244

Received: 23/07/2024

Respondent: Environment Agency

Welcome the proposal to support tighter standards for water efficiency. We would highlight Southern Water’s target to reach 100 litres per person per day by 2040. If this is to be achieved, then new housing will need even lower values to offset older, less efficient properties. It is positive to note that the plan already includes engagement with the relevant water companies (section 3.28).

We note that water efficiency requirements for commercial developments have not been included. We would expect commercial developments to meet BREEAM “excellent” for the same reasons. Rother is within a water stressed area.

As you have stated, in December 2023, DLUHC stated a review of the Building Regulations 2010 (Part G) would take place to allow local planning authorities to introduce tighter water efficiency standards in new homes. Some wording change to this draft policy may be necessary in the future.

Please see attached submission document

Comment

Representation ID: 28245

Received: 23/07/2024

Respondent: Environment Agency

Blue infrastructure should be included within the first paragraph of of the policy.

Comment

Representation ID: 28246

Received: 23/07/2024

Respondent: Environment Agency

Proposed Policy LWL5: Distinctive Places (v) – page 84

We are pleased to note the identified objective for “Bioregional Design” within proposed policy “LWL5: Distinctive Places” to “align development with the ecological and natural systems of the region” (Section 4.45, page 87). We would encourage that developments maximise opportunities to promote and enhance biodiversity, not just limited to open space, but also via living roofs, river restoration and enhancement and so on.

Comment

Representation ID: 28247

Received: 23/07/2024

Respondent: Environment Agency

We are pleased to see that you have made a commitment, in line with the NPPF, to undertake a sequential approach to development based on the SFRA and taking account of all sources of flooding. We understand the SFRA is currently being developed and we have provided modelled data in support of this. We would encourage further collaboration in production of the SFRA and would be happy review any draft reports or modelling ahead of the final submission.

Comment

Representation ID: 28248

Received: 23/07/2024

Respondent: Environment Agency

The Pevensey Bay to Eastbourne Coastal Management Scheme is not mentioned anywhere within the Bexhill chapter. This scheme will manage the 15km stretch of coastline over the next 100 years.

Reducing coastal flood and erosion risk to properties and infrastructure in the scheme area requires action. Alongside making the area more resilient to coastal flooding, we want to deliver interventions that will benefit the wider community and environment. We are working with a wide range of organisations and local communities.

This scheme covers the far south-west corner of Rother's coastline, from Norman’s Bay to Cooden. We recommend you explore the impact this may have on the Bexhill policy area outlined in the Local Plan, and any identified opportunities to deliver the priorities set out within the Local Plan, and work with neighbouring authorities also covered by the scheme to deliver wider benefits for this stretch of coastline.

See full text attached.

Comment

Representation ID: 28249

Received: 23/07/2024

Respondent: Environment Agency

Masterplanning must also include appropriate foul drainage connections, prior to occupation.

Comment

Representation ID: 28250

Received: 23/07/2024

Respondent: Environment Agency

We would prefer to see separate policy wording for green and blue infrastructure. Looking at the definition of green infrastructure these are predominately artificial or highly managed features associated with human activities, whereas the definition of blue infrastructure includes more natural habitats. Therefore, it would be more appropriate to have separate policy wording so that wording for each can maximise the benefits of each, whilst also protecting biodiversity and opportunities for habitat restoration.

Comment

Representation ID: 28251

Received: 23/07/2024

Respondent: Environment Agency

We have no specific comments about this section, but please see our comments for section 11, especially those relating to flood risk.