Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28126

Received: 22/07/2024

Respondent: East Sussex County Council

ECO2: Protecting Existing Employment Sites and Premises, p321-322; The concept of a Cultural Opportunity Zone could be explored and would be welcomed. The concept has been developed by the South East Creative Economy Network (SECEN) and informed by the SECEN Framework for Creative Open Workspace.

Comment

Representation ID: 28127

Received: 22/07/2024

Respondent: East Sussex County Council

ECO2: Protecting Existing Employment Sites and Premises, para 9.24, p325; The paragraph states that there is ‘the potential to claw back demand that is currently lost through trips to Central London’. Is there evidence and data to support the assertion that demand is being lost to London?

Comment

Representation ID: 28128

Received: 22/07/2024

Respondent: East Sussex County Council

ECO5: Tourism Activities, Facilities and Accommodation, para 9.43, p332; It should be highlighted that tourism also relies on our cultural destinations offer which is one of the primary reasons visitors cite for visiting East Sussex.

Comment

Representation ID: 28129

Received: 22/07/2024

Respondent: East Sussex County Council

ENV1: Coastal, Water and Flood Risk Management vi), p367; Section vi) discusses the LPA’s preference around non-mains foul drainage solutions. Whilst the principle of this section is acceptable, we would advise the removal of the hierarchy list. This will ensure the policy remains up to date should the Environment Agency’s hierarchy alter during the lifetime of the Local Plan.

Comment

Representation ID: 28130

Received: 22/07/2024

Respondent: East Sussex County Council

ENV1: Coastal, Water and Flood Risk Management, Para 11.8, p369; Paragraph 11.8 should include an additional caveat to ensure a point of connection is discussed with the relevant Water Authority, therefore amend to read; ‘The Council must be satisfied that the applicant has identified the closest potential point of connection, *in communication with the Water Authority*, to the existing public foul sewerage network.’

Comment

Representation ID: 28131

Received: 22/07/2024

Respondent: East Sussex County Council

ENV1: Coastal, Water and Flood Risk Management, p366-370; It is advised that any reference to ‘Southern Water’ should be replaced with the term ‘Water Authority’ to ensure the policy remains relevant should there be any changes to how water companies operate within the lifetime of the Local Plan.

Comment

Representation ID: 28132

Received: 22/07/2024

Respondent: East Sussex County Council

ENV1: Coastal, Water and Flood Risk Management, Para 11.11, p369; Paragraph 11.11 should remove reference to the non-mains hierarchy to ensure the policy remains up to date should the Environment Agency’s (EA) hierarchy alter during the lifetime of the Local Plan. In addition, compliance with the EA’s General Binding Rules cannot be a planning policy requirement.

The following wording is, therefore, recommended; ‘Applicants should provide evidence that the Environment Agency’s General Binding Rules has been considered, and where compliance is not possible that application for the relevant permits has been submitted.’

Comment

Representation ID: 28133

Received: 22/07/2024

Respondent: East Sussex County Council

ENV1: Coastal, Water and Flood Risk Management, p366-370; Please be aware that the Pevensey & Cuckmere Water Level Management Board requires a nine-metre buffer between its water management/flood infrastructure and any development or other obstruction. Please see Confirmed Byelaws for Pevensey & Cuckmere Water Level Management Board (wlma.org.uk) for more information.

Comment

Representation ID: 28134

Received: 22/07/2024

Respondent: East Sussex County Council

ENV2: Sustainable Surface Water Drainage, p371; The first paragraph of the policy wording should be altered to ensure it reflects Lead Local Flood Authority (LLFA)
terminology with regards to drainage strategies:
“For planning permission to be granted, applicants must demonstrate that sustainable drainage is an integral part of the proposed development and its design *through the submission of a Drainage Strategy*.”

Comment

Representation ID: 28135

Received: 22/07/2024

Respondent: East Sussex County Council

ENV2: Sustainable Surface Water Drainage (ii), p371; Part (ii) of the policy should be altered to ensure developers discuss and agree appropriate discharge rates for a site with the LLFA. This will allow site and development specific conditions such as discharge points, geology, topography etc to be taken into consideration when determining maximum discharge rates/ volumes. The following wording is, therefore, recommended;

‘*For minor applications* peak run-off rates from development must be the lower of the two following options: either the greenfield rate in terms of volume and flow; or the existing rate/volume of discharge. *For major applications appropriate run-off rates and volumes should be determined in conjunction with the LLFA*.’