Rother Local Plan 2025-2042 – Development Strategy and Site Allocations

Draft Rother Local Plan 2025-2042 Consultation
Thank you for sharing the Draft Rother Local Plan 2025-2042 with the Pevensey and
Cuckmere Water Level Management Board, after reading the document we have made
some observations and have the following comments:
The draft Environmental Policy ENV2 recognises the role Internal Drainage Boards play in
ensuring water is appropriately managed within their districts as well as the need to reduce
flood risk and promote the benefits of blue /green infrastructure. The PCWLMB recognises
this as an important strategic objective for Rother District Council.
However, it is noted that policy text for Part 4 Site Allocations is not consistent when referring
to the application of ENV 2 at each site. Sustainable Drainage should apply to all new
development, not a select few within the local plan for example BX20 correctly states that
ENV 2 applies to the site while there is no mention of the policy in BX19. And like wise CR1
correctly states that ENV 2 applies to the site but no mention of the policy in CR2.
ENV 2 recognises that drainage systems should allow for ongoing maintenance. However,
the proposed development should also reserve adequate space for access and maintenance
of Sustainable Drainage Systems and other water bodies within the sites. This is to ensure
that the water bodies and drainage system can be maintained and operated safely and
sustainably for the lifetime of the development. This should apply to all development sites,
including those in the PCWLMB’s catchment area.
Development sites in West Bexhill Growth Area discharge their water to watercourses in the
Pevensey Levels whose drainage is supplemented by pumping during extreme rainfall
events. These pumps were installed in the 1970s and have reached the end of their design
life with limited funding available for their replacement. There is, therefore, a likelihood that
these watercourses will have high water levels over long periods in winter where drainage
systems might struggle to discharge water into the watercourses. During such periods,
drainage systems should have been designed to take that into account to ensure it does not
result in flooding on or offsite. In addition, the PCWLMB has a byelaw that requires anyone increasing the flow or volume of
water discharged into its drainage district to agree the discharge rates with the Board prior to
making the discharge. Applicants should seek pre-applications with the Board and LLFA at
the earliest opportunity for all sites within the water level management board’s catchment
area. This applies West Bexhill Growth Area, North Bexhill Growth Area, parts of Central
Urban Area, Catsfield and Crowhurst
There is little opportunity for infiltration in the catchment area of the water level management
board due to impermeable geologies and high / perched groundwater. Therefore, space
should be considered when designing surface water drainage as a lager area could be
required for attenuation prior to discharge to a waterbody.
The PCWLMB will also take into consideration water quality passing into the Boards
drainage district especially in the Pevensey Levels. This is because there are a number of
species within the watercourses that are dependent on clean water.

Draft Rother Local Plan 2025-2042 Consultation
Thank you for sharing the Draft Rother Local Plan 2025-2042 with the Pevensey and
Cuckmere Water Level Management Board, after reading the document we have made
some observations and have the following comments:
The draft Environmental Policy ENV2 recognises the role Internal Drainage Boards play in
ensuring water is appropriately managed within their districts as well as the need to reduce
flood risk and promote the benefits of blue /green infrastructure. The PCWLMB recognises
this as an important strategic objective for Rother District Council.
However, it is noted that policy text for Part 4 Site Allocations is not consistent when referring
to the application of ENV 2 at each site. Sustainable Drainage should apply to all new
development, not a select few within the local plan for example BX20 correctly states that
ENV 2 applies to the site while there is no mention of the policy in BX19. And like wise CR1
correctly states that ENV 2 applies to the site but no mention of the policy in CR2.
ENV 2 recognises that drainage systems should allow for ongoing maintenance. However,
the proposed development should also reserve adequate space for access and maintenance
of Sustainable Drainage Systems and other water bodies within the sites. This is to ensure
that the water bodies and drainage system can be maintained and operated safely and
sustainably for the lifetime of the development. This should apply to all development sites,
including those in the PCWLMB’s catchment area.
Development sites in West Bexhill Growth Area discharge their water to watercourses in the
Pevensey Levels whose drainage is supplemented by pumping during extreme rainfall
events. These pumps were installed in the 1970s and have reached the end of their design
life with limited funding available for their replacement. There is, therefore, a likelihood that
these watercourses will have high water levels over long periods in winter where drainage
systems might struggle to discharge water into the watercourses. During such periods,
drainage systems should have been designed to take that into account to ensure it does not
result in flooding on or offsite. In addition, the PCWLMB has a byelaw that requires anyone increasing the flow or volume of
water discharged into its drainage district to agree the discharge rates with the Board prior to
making the discharge. Applicants should seek pre-applications with the Board and LLFA at
the earliest opportunity for all sites within the water level management board’s catchment
area. This applies West Bexhill Growth Area, North Bexhill Growth Area, parts of Central
Urban Area, Catsfield and Crowhurst
There is little opportunity for infiltration in the catchment area of the water level management
board due to impermeable geologies and high / perched groundwater. Therefore, space
should be considered when designing surface water drainage as a lager area could be
required for attenuation prior to discharge to a waterbody.
The PCWLMB will also take into consideration water quality passing into the Boards
drainage district especially in the Pevensey Levels. This is because there are a number of
species within the watercourses that are dependent on clean water.

Draft Rother Local Plan 2025-2042 Consultation
Thank you for sharing the Draft Rother Local Plan 2025-2042 with the Pevensey and
Cuckmere Water Level Management Board, after reading the document we have made
some observations and have the following comments:
The draft Environmental Policy ENV2 recognises the role Internal Drainage Boards play in
ensuring water is appropriately managed within their districts as well as the need to reduce
flood risk and promote the benefits of blue /green infrastructure. The PCWLMB recognises
this as an important strategic objective for Rother District Council.
However, it is noted that policy text for Part 4 Site Allocations is not consistent when referring
to the application of ENV 2 at each site. Sustainable Drainage should apply to all new
development, not a select few within the local plan for example BX20 correctly states that
ENV 2 applies to the site while there is no mention of the policy in BX19. And like wise CR1
correctly states that ENV 2 applies to the site but no mention of the policy in CR2.
ENV 2 recognises that drainage systems should allow for ongoing maintenance. However,
the proposed development should also reserve adequate space for access and maintenance
of Sustainable Drainage Systems and other water bodies within the sites. This is to ensure
that the water bodies and drainage system can be maintained and operated safely and
sustainably for the lifetime of the development. This should apply to all development sites,
including those in the PCWLMB’s catchment area.
Development sites in West Bexhill Growth Area discharge their water to watercourses in the
Pevensey Levels whose drainage is supplemented by pumping during extreme rainfall
events. These pumps were installed in the 1970s and have reached the end of their design
life with limited funding available for their replacement. There is, therefore, a likelihood that
these watercourses will have high water levels over long periods in winter where drainage
systems might struggle to discharge water into the watercourses. During such periods,
drainage systems should have been designed to take that into account to ensure it does not
result in flooding on or offsite. In addition, the PCWLMB has a byelaw that requires anyone increasing the flow or volume of
water discharged into its drainage district to agree the discharge rates with the Board prior to
making the discharge. Applicants should seek pre-applications with the Board and LLFA at
the earliest opportunity for all sites within the water level management board’s catchment
area. This applies West Bexhill Growth Area, North Bexhill Growth Area, parts of Central
Urban Area, Catsfield and Crowhurst
There is little opportunity for infiltration in the catchment area of the water level management
board due to impermeable geologies and high / perched groundwater. Therefore, space
should be considered when designing surface water drainage as a lager area could be
required for attenuation prior to discharge to a waterbody.
The PCWLMB will also take into consideration water quality passing into the Boards
drainage district especially in the Pevensey Levels. This is because there are a number of
species within the watercourses that are dependent on clean water.