Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28096

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Assessment of Effectiveness: The effectiveness of the proposed SuDS policies should be evaluated based on their capacity to mitigate the specific flood risks in Pett Level. This includes their ability to handle both current water flow levels and anticipated increases due to climate change and urban development. So this means that RDC needs a data-based baseline for what current surface runoff rates and their impact on the flood risk in Pett Level. We believe this needs to go beyond a reliance on "greenfield rates."

Question: What standards are being used to assess the effectiveness of SuDS?
Comments: The current policy mentions the use of SuDS but does not specify the standards or performance metrics used to evaluate their effectiveness. We suggest adopting standards from recognized bodies such as the CIRIA SuDS Manual (C753) to ensure that the implemented systems are robust and effective in managing surface water runoff and reducing flood risk.

Comment

Representation ID: 28097

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Innovative Techniques: Consider the adoption of newer, innovative drainage solutions that go beyond traditional SuDS, such as green roofs, permeable pavements, and enhanced natural landscaping that increases absorbency in flood-prone areas.

Comment

Representation ID: 28098

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Monitoring and feedback: To ensure that the proposed policies are not only implemented but remain effective, establish a transparent monitoring system with clear metrics for success and clear public displays of enforcement. Regular feedback loops involving community stakeholders can help identify areas for improvement and foster a proactive approach to policy adaptation. RDC needs to be in regular contact with all relevant community-led flooding initiatives to ensure that these planning rules are adaptive to what is happening on the ground and are updated for data-led innovations which identify increased risks, a changing environment, and newer solutions.

Comment

Representation ID: 28099

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Comments: While Policy EN6 outlines measures for individual development flood risk assessments, it is crucial to consider the cumulative impact of multiple developments on flood risk in Pett Level. We recommend integrating a comprehensive flood risk model that takes into account the combined effect of all developments in the area to provide a more accurate risk assessment and mitigation strategy.

Comment

Representation ID: 28100

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Question: How does the plan address long-term climate change impacts on flood risk?
Comments: The plan should include specific strategies for adapting to long-term climate change impacts, such as increased rainfall and sea level rise, which are likely to exacerbate flood risks in Pett Level. This could involve incorporating predictive climate models and developing adaptive infrastructure that can respond to changing conditions over time.
The plan also needs to sync with Southern Water’s stated aim of returning the combined sewer network back to a foul water system only. This means diverting grey and surface water, etc. back into local water courses. This potential increase in ground water and local water course water levels needs to be understood and analysed. There is little point in the council setting planning rules based on current greenfield rates if those are about to be fundamentally changed by the actions of Southern Water.

Comment

Representation ID: 28101

Received: 23/07/2024

Respondent: Marsham Brook Residents’ Association

Question: What are the potential impacts of the proposed development at Wakehams Farm on local flood risk?
Comments: We strongly oppose the proposed development at Wakehams Farm due to its potential to significantly increase flood risk in Pett Level. Previous assessments have indicated that the site is unsuitable for development due to its impact on local hydrology. We urge the council to uphold the previous rejection of this development and ensure that future proposals are thoroughly evaluated for their flood risk implications.