Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28252

Received: 23/07/2024

Respondent: Environment Agency

We support this policy and are pleased to see flood risk included in it. We suggest that part iv is amended to read “Not be in an area at risk of flooding, unless a site-specific flood risk assessment has demonstrated that the development will be safe now and taking account of climate change, in the future, and will not increase flood risk elsewhere.”

Comment

Representation ID: 28253

Received: 23/07/2024

Respondent: Environment Agency

We welcome this policy for the inclusion of wetlands (Romney Marshes and Pevensey Levels) as priority landscape features for enhancement and conservation. Wetlands are key indicators for groundwater quality, given the connectivity between groundwater and wetlands. As such we welcome any proposals to better protect and enhance these features.

Comment

Representation ID: 28254

Received: 23/07/2024

Respondent: Environment Agency

Biodiversity:
Section ii) – page 366 While we are pleased to see that you will seek opportunities to increase the buffer distances we would like this to be more ambitious with requirement for buffer zones (and extended buffer zones) between new developments and watercourses. The creation and management of ecological buffer zones provide space:
• for riparian wildlife to inhabit and move along watercourses
• to help protect the biodiversity of the watercourse from new development
• to allow natural river processes to occur and rivers to function naturally.
• provide space for river enhancement or restoration where this is necessary (particularly in the case of larger buffer zones).

We would also like to see reference to the creation and management of new wetland areas to help manage flood risk and reduce diffuse pollution.

Comment

Representation ID: 28255

Received: 23/07/2024

Respondent: Environment Agency

Continued: (Biodiversity:
Section ii)

There is no mention of culverts or de-culverting anywhere in the current Local Plan. We strongly recommend inclusion of a policy that encourages development to carry out de-culverting wherever possible to increase light provision for aquatic plants and animals, to improve terrestrial connectivity and to provide green corridor connection with introduction of a riparian zone.

Would also like to see removal of redundant in channel and bank structures from main rivers where possible to improve habitat connectivity upstream.

Please see full text in attached submission

Comment

Representation ID: 28256

Received: 23/07/2024

Respondent: Environment Agency

Flood Risk:
Section ii) – page 366 We support the commitment to ensure all classifications of watercourses are not adversely affected by development and to seek opportunities to increase buffer distances as defined in the Environmental Permitting (Eng & Wales) Regulations 2016 (as amended).

Comment

Representation ID: 28257

Received: 23/07/2024

Respondent: Environment Agency

Section iii)

Whilst we support this policy in principle, we would encourage this to be strengthened to make sure a sequential approach to the layout is applied to all proposals in flood risk areas ensuring the most vulnerable form of development is placed in the areas of lowest risk.

Comment

Representation ID: 28258

Received: 23/07/2024

Respondent: Environment Agency

Section v)

We would like to see Working with Natural Processes (WwNP) or Natural Flood Management (NFM) included in relation to v) “Contributions will be sought for improvements to infrastructure to mitigate against flood risk where it is deemed necessary; and”. For example, by encouraging the use of NFM measures to help mitigate existing flood risk to communities. These measures are already being explored within the Combe Haven valley for small communities such as Crowhurst and can be important interventions.

Comment

Representation ID: 28259

Received: 23/07/2024

Respondent: Environment Agency

Flood risk Management

Flood Zone 3b (FZ3b) is the functional floodplain. This zone comprises land where water from rivers or the sea must flow or be stored in times of a flood.

The definition of FZ3b within the national Planning Practice Guidance (PPG) (Table 1: Flood Zones) states that it will normally comprise of:
• land having a 3.3% or greater annual probability of flooding, with any existing flood risk management infrastructure operating effectively; or
• land that is designed to flood (such as a flood attenuation scheme), even if it would only flood in more extreme events (such as 0.1% annual probability of flooding).

The SFRA should identify the Functional Floodplain and we recommend that you consider including this definition in your flood risk management policy to allow for accurate sequential test implementation when determining land use.

Please see attached submission document for full representation text.

Comment

Representation ID: 28260

Received: 23/07/2024

Respondent: Environment Agency

Please see attached submission for text on water quality and resource.

Comment

Representation ID: 28261

Received: 23/07/2024

Respondent: Environment Agency

Please see attached submission document for representation on Groundwater and contaminated land:
Foul Drainage in relation to Policy ENV1.