County Council and and City Council Wastewater Management Study

Revision Schedule

Wastewater Management Study October 2009

Rev Date Details Prepared by Reviewed by Approved by

01 06/09 v1 Mary Pyne/Sarah Kelly Clare Postlethwaite Damon O’Brien Assistant Consultant Consultant Technical Director

02 07/09 v2 Clare Postlethwaite Carl Pelling Damon O’Brien Consultant Principal Consultant Technical Director

03 10/09 Final Clare Postlethwaite Carl Pelling Damon O’Brien Consultant Principal Consultant Technical Director

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www.scottwilson.com East Sussex County Council and City Council Wastewater Management Study

Table of Contents

1 Introduction ...... 1 Study Area...... 1 Objectives...... 1 Legislative Context ...... 2 Growth in East Sussex and Brighton & Hove...... 5 2 Stage 1 – Baseline Assessment and Issue Identification...... 9 Sludge Treatment Capacity ...... 9 WwTW Consent Capacity...... 11 Wastewater Treatment Works Process Capacity ...... 16 Environmental Capacity of Receiving Watercourses...... 19 3 Stage 2 Significance of Issues ...... 27 Sludge treatment capacity ...... 27 WwTW capacity...... 27 4 North and South WwTW ...... 36 Significance of Issues Assessment...... 36 5 Stage 3 - Option Assessment...... 38 WwTW Option Identification...... 38 WwTW Option Assessment ...... 40 Sewage sludge...... 45 6 Preferred Spatial Strategy ...... 49 7 References...... 50 8 Appendix A – Statutory Standards...... 51 Bathing Water Standards...... 51 9 Appendix B – SWS information ...... 54 SWS Sludge Treatment Position Statement...... 54 PR09 and NEP Schemes...... 56 10 Appendix C – Wastewater Calculations...... 58 11 Appendix D – Environmental Capacity Data...... 67 12 Appendix E – Figures ...... 72 Figure 1 – Study Area...... 72 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

Figure 2 – WwTW DWF locations ...... 73 Figure 3 – Current WwTW Volumetric Capacity_HR...... 74 Figure 4 - Current WwTW Volumetric Capacity...... 75 Figure 5 – Future WwTW Volumetric Capacity ...... 76 Figure 6 – Future WwTW Dwelling Capacity...... 77 Figure 7 – Bathing Waters ...... 78 Figure 8 – Sites of Conservation Interest ...... 79 Figure 9 – Hailsham Potential Preferred Spatial Options ...... 80 13 Appendix F - Sustainability Appraisal of Options ...... 81

1 Introduction

1.1 East Sussex County Council (ESCC) and Brighton & Hove City Council (BHCC) are undertaking a joint Waste and Minerals Core Strategy Development Plan Document (WMCS) which will undergo public examination by independent inspection to judge ‘soundness’ of the evidence. As part of this process, a Wastewater Management Study is required to support the evidence base, providing information relating to the management of wastewater and sewage sludge in the ESCC and BHCC areas.

Study Area

1.2 The study area covers the county of East Sussex and the city of Brighton and Hove. East Sussex contains the Boroughs of and and the Districts of , Rother, Wealden. Figure 1 shows the study area and the council boundaries within.

1.3 The Regional Spatial Strategy has set out the required number of new houses to be built in East Sussex and Brighton and Hove up to 2026. Each of the councils within the study area is at a different stage in the development of their Local Development Framework but housing figures have been adopted at the District level. Subsequently, current and future capacity in terms of wastewater treatment and disposal has been assessed using estimated growth figures provided by Southern Water Services (SWS).

1.4 SWS is the sewerage undertaker for the East Sussex region, and has been an active consultee in this project, while also providing information regarding sewage and sludge treatment.

Objectives

1.5 It is intended that this report and the outcomes of this study be a ‘Living Document’, to be updated and amended as and when new data, such as housing figures, or new policies and guidance are published and become available. It should be noted that this report provides a picture of the current situation with regards to wastewater treatment capacity and it is likely that the conclusions could become obsolete if not regularly updated.

1.6 In accordance with the tender brief, the objectives of this project are to:

• assess the baseline capacity of wastewater and sludge management capacity within the East Sussex and Brighton and Hove areas; • determine any issues with the available capacity relating to future housing and employment growth within the area; • determine whether these issues are significant enough to require a separate issues assessment encompassing the development of ‘options’ for addressing the issue; • for significant issues, identify reasonable options for sludge and wastewater treatment capacity expansion; • test the identified available options to identify the most suitable option(s); and

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• produce a preferred Spatial Strategy for future sludge and wastewater management.

1.7 The preferred Spatial Strategy will not identify individual sites; rather this will be covered by the upcoming Waste and Minerals Development Plan Document (DPD), which will provide further details of potential site allocation for waste sites. Work is due to commence on the Waste DPD in 2010, with the content guided by the Core Strategy.

Legislative Context Water Framework Directive

1.8 The Water Framework Directive (WFD) (2000/60/EC) was passed into UK law in 2003. The competent authority responsible for its implementation is the Environment Agency in and Wales. The overall requirement of the directive is that all water bodies in the UK must achieve good ecological, chemical status and morphological status by 2015 unless there are grounds for derogation.

1.9 The WFD will for the first time combine water quantity and water quality issues together. The directive combines previous water legislation and in certain areas strengthens existing legislation. An integrated approach to the management of all freshwater, groundwater, estuaries and coastal waters at the river basin level will be adopted. Involvement of stakeholders is seen as key to the success in achieving the tight timescales and objectives set by the directive. The WFD states that all countries in the European Union should:

• prevent deterioration in the classification status of aquatic ecosystems, protect them and improve the ecological condition of waters; • aim to achieve at least good status for all waters. Where this is not possible, good status should be achieved by 2021 or 2027; • promote sustainable use of water as a natural resource; • conserve habitats and species that depend directly on water; • progressively reduce or phase out releases of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment; • progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants; and; • contribute to mitigating the effects of floods and droughts.

1.10 Ecological status is measured on a scale from high, good, moderate, poor and bad; and good chemical status as pass or fail. For groundwater, good status has a quantitative and a chemical component, which together provide a single final classification: good or poor status. Good ecological status is defined as a slight variation from undisturbed natural conditions, but artificial and heavily modified waters are not able to achieve natural conditions. Instead the target for these waters is good ecological potential. This is also measured on the scale high, good, moderate, poor and bad. The chemical status of these water bodies is measured in the same way as natural water bodies.

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1.11 Ecological Status is based on biological quality which includes invertebrates, fish and macrophytes; physicochemical quality (temperature, dissolved oxygen, salinity, pH and nutrients) and hydromorphological quality, which assesses ability of the watercourse to support the habitats appropriate to its typology.

1.12 Chemical Status is assessed on the presence and concentration of Priority Substances for which standards have been established. A full list is located in the UKTAG advice for classification (Reference 1).

1.13 The elements that these criteria are based on are specific for the different water body type – Rivers, Lakes, Transitional Waters and Coastal Waters. The classification is assigned by comparing the feature in question with the reference values. The system works on a worse case scenario; a principle of ‘one out, all out’ i.e. a waterbody is assigned an overall class based on the lowest reporting parameter 1. The aim is to move water bodies as close to a natural state as possible.

1.14 Draft River Basin Management Plans (DRBMPs) (Environment Agency, 2008), set out detailed proposals for the next 6 years via a Programme of Measures (POM) to bring about the changes necessary in order to bring the water bodies which are currently failing the required standards up to good status. The measures in the draft plans have been developed with the assistance of the River Basin Liaison Panels, and include actions required by a wide range of organisations under three scenarios; business as usual, baseline and those actions desirable if there were more information. The range of organisations responsible for co-delivering elements of the POMs include the water industry, businesses, planning authorities, environmental organisations, agriculture, forestry, consumers, fishing bodies, ports, drainage boards and regional government, which will all have key roles to play in implementing the plan. The draft plans should be finalised in December 2009.

Freshwater Fish Directive

1.15 The Freshwater Fish Directive (2006/44/EC) seeks to protect those fresh water bodies identified by Member States as waters suitable for sustaining fish populations. For those waters it sets physical and chemical water objectives for salmonid waters and cyprinid waters. The directive will be replaced in 2013 by the WFD. Annex I of the directive lists the parameters for a freshwater fishery to be maintained (Reference 2).

Urban Wastewater Treatment Directive

1.16 The objective of the Urban Waste Water Treatment Directive (UWWTD) is to protect the environment from the adverse effects of sewage discharges. It sets treatment levels on the basis of sizes of sewage discharges and the sensitivity of the waters receiving the discharges.

1.17 Under the Directive, the UK is required to review environmental waters at four-yearly intervals to determine if they are sensitive to the effects of sewage discharges (Reference 3). As part of the UWWTD, areas sensitive to sewage discharges have been mapped. The Levels, Waldron Ghyll and the Rivers Cuckmere and Camber bathing water are all noted as sensitive.

1 In the Draft WRMP, where Fish or Phosphorus are considered to be poor, a compromise is made between the status of phosphorus and fish and the rest of the determinants. This will be confirmed within the final RBMPs.

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Groundwater Directive

1.18 The Groundwater Directive aims to protect groundwater from pollution by controlling discharges and disposals of certain dangerous substances to groundwater. In the UK, the directive is implemented through the Groundwater Regulations 1998. The Directive aims to protect groundwater under these Regulations by preventing or limiting the inputs of listed substances into groundwater. Substances controlled under these Regulations fall into two lists:

• List 1 substances are the most toxic and must be prevented from entering groundwater. Substances in this list may be disposed of to the ground, under a permit, but must not reach groundwater. They include pesticides, sheep dip, solvents, hydrocarbons, mercury, cadmium and cyanide. • List 2 substances are less dangerous, and can be discharged to groundwater under a permit, but must not cause pollution. Substances in this list include some heavy metals and ammonia (which is present in sewage effluent), phosphorus and its compounds

1.19 The existing Groundwater Directive is to be repealed by the Water Framework Directive in 2013. New or amended regulations are expected before then to enact both the Water Framework Directive and its Daughter Directive on the protection of groundwater. This new Groundwater Directive (2006/118/EC) is commonly referred to as the Groundwater Daughter Directive.

1.20 The Water Framework Directive and the new Groundwater Directive make changes to how groundwater can be protected. These changes will provide a new regulatory setting for the protection of groundwater. However, the new or amended Regulations will be no less protective than the existing Regulations. The existing principle of preventing or limiting the inputs of list 1 or list 2 substances respectively into groundwater under the original Groundwater Regulations 1998 will remain, but will be expanded to encompass all pollutants (any substance liable to cause pollution). For example, nitrate will be included as a pollutant.

Shellfish Waters

1.21 The aim of the EC shellfish Waters Directive is to protect or improve shellfish waters in order to support shellfish life and growth, therefore contributing to the high quality of shellfish products directly edible by man. It sets physical, chemical and microbiological water quality requirements that designated shellfish waters must either comply with (‘mandatory’ standards) or endeavour to meet (‘guideline’ standards) (Reference 4).

1.22 There are no designated shellfish waters in the coastal waterbodies adjacent to the study area; therefore this directive does not apply.

Bathing Water Directive

1.23 The main objective of the current and revised Bathing Water Directives (76/160/EEC and 2006/7/EC) is to protect public health and the environment from faecal pollution at bathing waters. Member States are required to identify popular bathing areas and to monitor water quality at these bathing waters throughout the bathing season.

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1.24 Directive 76/160/EEC sets a number of microbiological and physico-chemical standards that bathing waters must either comply with (‘mandatory’ standards) or endeavour to meet (‘guideline’ standards). These standards will continue to be monitored until 2012, at which point Defra and the Environment Agency will change monitoring to meet the higher standards set out in Directive 2006/7/EC (Reference 5). The standards are given below in Appendix A.

Marine and Coastal Access Bill

1.25 The aims of the Marine and Coastal Access Bill, published in December 2008, are:

• a new network of marine conservation zones; • the establishment of a new Marine Management Organisation which will be a centre of marine expertise; • a new marine planning system which will enable a more strategic approach to be taken to the use of our seas; • a simpler more streamlined marine licensing system; and • better management of fisheries.

Flood and Water Management Bill

1.26 The draft bill will create a simpler and effective means of managing the risk of flood and coastal erosion. It will also help improve the sustainability of our water resources and protect against potential droughts. The draft Flood and Water Management Bill will:

• deliver improved security, service and sustainability for people and their communities • it will be clear who is responsible for managing flood risk • protect essential water supplies • modernise the law for managing flood risk and reservoir safety • encourage more sustainable forms of drainage • enable water companies to control more non-essential uses of water during droughts • make it easier to resolve misconnections to sewers

1.27 The overall effect will be a healthier environment, better service and greater protection for people, their communities and business.

Growth in East Sussex and Brighton & Hove

1.28 Following discussions with the local planning authorities within the ESCC area and after review of the RSS, the current understanding is that a total of 41,400 houses are required by 2026 in the ESCC and BHCC areas. Table 1.1 below sets out the numbers of growth within each district.

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Table 1.1 Growth numbers in the study area, Policy H1 of the South East Plan

Local/Unitary Authority Annual Average Total New Dwellings Development (Dwellings) 2006-2026 B&HCC 570 11,400 Eastbourne 240 4,800 Rother 280 5,600 Hastings 210 4,200 Lewes 220 4,400 Wealden 550 11,000 Total 2,070 41,400

1.29 There is currently no information on the location of the development within the districts. There have been significant delays in the preparation of Local Development Frameworks (LDFs) in the East Sussex and Brighton and Hove area, in part due to delays in progression of the South East Plan through to adoption. As a result, none of the local authorities in ESCC or BHCC areas have adopted Development Plan Documents (DPDs) that fully or partly define the location of development to 2015 and beyond. Most of the current Local Plans have end dates of 2011.

1.30 Growth estimates provided by SWS (as part of their planning and capacity assessment for the preparation of their Final Business Plan) have been used in this assessment due to the scarcity of development figures available for each of the local/unitary authorities at the time of the assessment. These overall growth figures are lower than the RSS growth targets as the public sewerage does not extend to the rural areas. Typically, some 5-8% of the population is not connected to public sewers and they depend on septic and cess tanks for drainage. In East Sussex, approximately 8% of the population is not connected to mains sewage systems, reflecting the rural nature of the county.

Shoreham Harbour Regeneration

1.31 Shoreham Harbour has Growth Point status and is identified as an area for strategic development in the South East Plan. An outline housing target of up to 10,000 new dwellings (500 annual average) has been identified.

1.32 The Shoreham Harbour Redevelopment area covers the south western corner of the Brighton and Hove City Council area and partly lies within the area covered by the neighbouring Adur District Council. The majority of the Shoreham Harbour Regeneration area drains to Shoreham Wastewater Treatment Works, but the area east of the Boundary and Stations Roads is in the Brighton and Hove catchment and drains eastwards to Portobello WwTW in Brighton.

1.33 The South East England Development Authority (SEEDA), in conjunction with Adur District Council, Brighton and Hove City Council and West Sussex County Council, commissioned an Outline Water Cycle Study (WCS) to provide an evidence base for a number of planning processes relating to the Shoreham Harbour Regeneration, namely the Minerals and Waste Core Strategy, the Adur DC Core Strategy and the LDF (Reference 6).

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1.34 The Outline WCS report concluded that Shoreham WwTW has limited spare hydraulic and treatment capacity and there is limited space for expansion on the current site. If the full potential development of 10,000 new homes proceeds, then the treatment works would have to expand outside of its current boundaries. SWS advised as part of the study that such expansion would be possible, provided that additional land can be made available adjacent to the existing site. Flows from the eastern part of the development areas at treated at Brighton Portobello WwTW. SWS have proposals to replace Portobello with a new treatment works at . It is expected that the new treatment works will be ready in time to treat the additional flows form the eastern part of the proposed development.

1.35 The findings and figures within the Outline WCS in relation to Shoreham WwTW have been used in this study in the absence of any information from SWS.

Water Company Planning

1.36 As part of the Final Business Plan submitted to Ofwat, SWS have undertaken an assessment of the current capacity and provision of future capacity throughout the ESCC and BHCC areas. In terms of growth and new development, only the works at Hailsham are identified as in need of investment in the period 2010-15, all the other proposed schemes have legislative drivers, such as the UWWTD. It should be noted that the proposed measures are subject to Defra/Ofwat review and approval and agreement by Ofwat to fund them in the 2009 Price Review (PR09) to be announced later in the year.

1.37 WwTW have been identified for investment by both SWS in the Final Business Plan and the Environment Agency in the National Environment Programme (NEP) from 2010 to 2015, and these are shown in Appendix B. It is important that the proposed volumetric and process improvements at these works are taken into account when assessing both current and future capacity, though the benefits these schemes will produce are difficult to quantify at this stage.

1.38 Appendix B provides an extract from their SWS Final Business Plan which was submitted to Ofwat in April 2009. This has assessed the additional demand arising from the proposed population increase for each wastewater catchment up to 2020 using the population projections from Experian Business Strategies, as described in the Final Business Plan and the concomitant risk of exceeding the consented Dry Weather flow (DWF) and process capacity.

1.39 For the consented DWF assessment, where DWF was forecast to exceed consent, indicative standards for the new discharge were obtained from the Environment Agency (it is anticipated that these are as provided in the NEP and have been indicated in Appendix B).

1.40 In terms of installed process capacity, all works above 2,000 population equivalent (PE) were assessed against forecast demand and the outcome from this assessment was used to determine the need for investment in the period to 2015. For the majority of catchments it was concluded that deferral of investment to 2020 was appropriate or recognised that the Environment Agency NEP would provide additional capacity at many key sites (Reference 7).

1.41 Only two WwTWs were identified as requiring investment within the period 2012 – 2015 as a result of new development up to 2020 and were subsequently included within SWS Final Plan submitted to Ofwat. Hailsham North was identified as requiring additional process capacity whilst both Hailsham North and South were identified as requiring a new discharge location investigation during the AMP5 period; both constraints placed by the Environment Agency to

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protect Pevensey Levels SSSI. For the purposes of this study Hailsham North and South can be considered to be a single works, as due to the proximity of the two sites it would be possible to transfer flows between the two works. A new works serving the Hailsham/ area may be needed before the end of the 2026 plan period. Sections 3.2 to 3.9 provide further information on the Hailsham North and South WwTWs.

1.42 SWS has stated that it considers there to be capacity to serve development currently defined in the planning system. This does not include development planned via the South East Plan and subsequent LDFs, which define which catchment the development falls within and will feed through to the investment programme. SWS will not be able to confirm capacity at individual WwTW until the location of planned development is known; this is essential to inform their investment decisions.

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2 Stage 1 – Baseline Assessment and Issue Identification

2.1 Stage 1 of this report gives a technical assessment of the current capacity of existing sludge and wastewater infrastructure, to assess capacity to accommodate the proposed housing and employment growth targets in East Sussex and Brighton & Hove, to the required Environment Agency standards. This assessment included:

• sludge treatment capacity; • wastewater treatment works process capacity; • wastewater volumetric headroom capacity; and • environmental capacity of receiving watercourses.

2.2 Stage 1 was undertaken as a desk review of available data and reports in consultation with the main Stakeholders. A full bibliography is included at the end of the report.

Sludge Treatment Capacity Baseline

2.3 SWS provided a position statement for the provision of sludge treatment in the ESCC and BHCC area, included in Appendix B.

2.4 Sludge from sewage treatment works is transported, by tanker, either directly to a sludge treatment centre or to an intermediate site such as Hailsham where sludge is thickened to be a maximum of 25% solids. The sludge is treated at the treatment centre by anaerobic digestion and in some cases further treated by thermal drying as is the case at the Hastings sludge treatment centre.

2.5 The anaerobic digestion process generates biogas (contains methane), which can be used to as a fuel to generate power. The end product of anaerobic digestion is suitable for application to land..

2.6 SW has a co-ordinated a dynamic management strategy approach to current and future development for the treatment and recycling of sludge. Their sludge strategy is developed in line with legislation, product market requirements and the need for business efficiency and the management of risk to the business.

2.7 Currently SW aim to recycle all biosolids to agricultural land, via various treatment processes and their future sludge strategy takes into account:

• increase in quantities of sludge from environmental enhancement programme and future population growth; • current and proposed future applicable legislation;

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• risk & opportunities associated with different sludge recycling routes; • climate changes and carbon footprint (environmental impacts); and • costs & benefits to customers.

2.8 SWS is looking to adopt a balance of application to agricultural land and thermal destruction as recycling options. SWS havs recognised and benefited from biogas utilisation for electricity generation and will continue to broaden their sludge treatment strategy approach.

2.9 SW has recently obtained planning permission for the construction of a new treatment works to serve Brighton and Hove conurbation. The new works will incorporate the Best Practicable Environmental Option (BPEO) to produce treated product that complies with the current legislation requirement. ..

Discussion

Brighton and Hove

2.10 In order to comply with the European Urban Waste Water Directive (91/271/EEC) and the consequent Urban Waste Water Treatment Regulations of 1994, SWS are required to provide improved waste water treatment facilities for the whole of Brighton area, namely secondary treatment of wastewater arising within the Brighton and Hove catchment.

2.11 SWS submitted a planning application for a new WwTW at Portobello in 1997. The application was refused by the County Council and subsequently dismissed on appeal by the Secretary of State, who accepted that while there was a need for enhanced wastewater treatment facilities under the requirements if the Urban Wastewater Treatment Directive, the proposal was unacceptable due to:

• significant harm to the Area of Outstanding Natural Beauty; • large scale damage to the SSSI, in conflict with Structure Plan policy EN17; • serious harm to the character and appearance of the undeveloped coast; and • the realistic alternative sites available to Portobello, which may be less harmful in terms of the above adverse affects.

2.12 A further application was made in January 2008 for a combined wastewater treatment works and sludge-recycling centre, located to the northeast of Peacehaven. This application has been approved and the new works will include:

• a compact wastewater treatment works comprising lamella primary settlement and biologically activated flooded filter (BAFF) secondary treatment, designed to treat a flow to full treatment (FFT) of 2.7 m 3/s and a PE of around 300,000; • sludge recycling centre which will produce a dry pellet product for use as a soil conditioner; • a major new combined sewer overflow and outfall at Blackrock, Brighton; • two new pumping stations at Roedean and Portobello;

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• new transfer infrastructure, including pipelines, tunnels and access shafts; and • a new Long Sea Outfall at Friar’s Bay, East Sussex.

2.13 Following the Council’s decision to grant planning permission for the Peacehaven site, an application for a Judicial Review of the Council’s decision was made to the High Court. The application was initially refused but an oral hearing for application for a Judicial Review was called and heard in the High Court in April 2009. The application for the Judicial Review was refused and the Council’s decision to grant planning permission was upheld.

2.14 However, it should be noted that although the planning issues surrounding the Peacehaven application have been resolved, there is still formal opposition to the scheme and while this is resolved there is still a risk factor involved in the scheme.

WwTW Consent Capacity Baseline

2.15 The WwTW consent capacity for each of the works within the ESCC and BHCC area has been assessed for both the current and planned development to 2026. The locations and relative sizes of the WwTW are shown in Figure 2. Volumetric capacity (hereafter referred to as headroom capacity) is the difference between the consented maximum dry weather flow (DWF) and the current DWF that is treated from the existing population. For the purposes of this assessment, the measured flows provided by SWS have been used to determine the current DWF at the works. Some smaller works do not measure flows; where this was the case the DWF has been calculated based on the Population Equivalent (PE) served by the works. It should be noted that with the exception of Portobello WwTW in Brighton, the majority of the works without measured flows serve a population of less than 100.

2.16 It is important to highlight that the volumetric assessment and the conclusions drawn in this study are based on DWF, defined as “the average daily flow of sewage during seven consecutive days without rain following seven days during which the rainfall did not exceed 0.25mm on any one day, averaged over a summer and winter period”. It does not take into account storm water discharges, which may cause flooding and/or other sewage related issues during times of heavy rainfall.

2.17 The headroom capacities at the WwTWs have been assessed based on the following criteria:

Capacity - The current measured DWF is much less than the consented DWF and therefore there is capacity to accept further flow to the WwTW;

Limited Capacity - The current measured DWF is close to the consented DWF resulting in a capacity of less than or equal to 5%. It is likely that any further flow to the WwTW will exceed the consented DWF and require a new discharge consent and/or upgrade to the WwTW. Mitigation measures may be planned to increase DWF consent but these are subject to approval;

No Capacity - The current measured DWF exceeds the current consented DWF and therefore no further flow can be accepted at the WwTW unless a new discharge consent is

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issued by the Environment Agency. If significant growth is planned here, new locations may need to be investigated; and

Not Assessed – The DWF capacity at the works could not be assessed as either the consented DWF information was not available (Portobello WwTW) or the works currently has a descriptive (no numeric limits on volume or sanitary determinands) consent.

2.18 Appendix C and Figure 4 show the current volumetric capacity of the WwTW in terms of the consented DWF. Table 2.1 highlights those works that currently have limited or no capacity and/or any proposed mitigation schemes under AMP5 or NEP that plan to address existing or known future capacity constraints by 2015.

Table 2.1 Current Consent Capacity Assessment WwTW WwTW DWF Proposed PR09 or NEP Measure Volumetric Capacity Capacity (m 3/d) Alfriston -36% -71 Environment Agency prepared to increase consented DWF , St Johns -23% 144 Environment Agency prepared to increase consented DWF Fletching - Proposed consent of 55 m 3/d by 31 Mar 2015 Halland -25% -33 DWF Consent Review – proposed DWF increase of 50 m 3/d to 183m 3/d by 31 Mar 2015 Lunsfords Cross -18% -8 DWF Consent Review - Proposed DWF increase of 13 m 3/d to 59 m 3/d by 31 Mar 2015 Mayfield, Crouch Farm 3% 5 Newhaven East/Newhaven 0% 59 Environment Agency prepared to increase New consented DWF , Mill Corner 5% 1 Offham -62% -5 Proposed increase in DWF of 7m 3/d to 15 m3/d Ripe -14% -6 DWF Consent Review - Proposed DWF increase of 11 m 3/d to 53 m 3/d by 31 Mar 2015 Streat - Proposed DWF consent of 50 m 3/d by 22 Dec 2012 Westfield 1% 3 DWF Consent Review – Proposed DWF increase of 54 m 3/d to 362 m 3/d by 31 Mar 2015 Wivelsfield 18% 58 DWF consent review - Proposed DWF increase of 86 m 3/d to 405 m 3/d by 31 Mar 2015

2.19 Six WwTW have been identified as currently exceeding their consented DWF, based on measured flows provided by SWS. A further four WwTW are close to their capacity limit with less than 5% capacity. An additional three WwTW have been identified as either increasing or setting flow consents by 2015. Fletching and Streat are relatively small works and currently have descriptive consents, but by the end of 2015 and 2012 respectively the works will have DWF consents limiting the flow that can be discharged.

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2.20 The increased capacity at the thirteen works will not guarantee that future growth (post 2015) can be accommodated without further upgrades to the WwTW.

2.21 Using the assumption that each household uses 500 litres of water per day (as used by SWS in their planning), the number of future homes and population equivalent that could be accommodated by the WwTW has been estimated. The 500l/hh/d is based on the following assumptions:

• an occupancy rate of 2.2; • 40% infiltration; • no allowance for water efficiencies elsewhere in the catchment; and • includes figures for trade flow.

2.22 It should be noted that SWS’s population projections do not include for water efficiency measures; in the future homes will be planned to use less water, as demonstrated by adoption of Code 3 planned water consumption (105 L/h/d) for new developments and Code 5 (80 L/h/d), by 2015. While this will result in the production of greater strength sewage, with an equal demand on treatment processes, it is worthwhile noting that planning for continued higher consumption may suggest a greater environmental risk and consequent higher investment levels than if lower consumption did materialise.

2.23 Appendix C and Figure 3 show the capacity within the individual WwTW in terms of dwellings that could be accommodated before an upgrade to the works, in terms of consented DWF and/or infrastructure, is required.

Future Growth and Capacity

2.24 The future potential volumetric (headroom) capacity has been assessed based on the population growth figures provided by SWS, calculated using a combination of the Experian methodology outlined in ‘Household and population estimation and projections: Methodological guide’, historic trend data and catchment knowledge. SWS population forecasting has been calculated using a November 2008 baseline date. Again, this has been estimated in terms of capacity of DWF utilised and dwelling capacity. Appendix C and Figure 6 illustrate the future flow and dwelling capacity based on the planned growth up to 2026.

2.25 It should also be noted that for the purposes of this study the SWS method of assessing WwTW catchments has been used. Therefore, when PE numbers refer to for example, , this refers to the properties that drain to Uckfield sewage works, rather than just the entire population of Uckfield. As can be seen from Figure 2, the Uckfield works serves a catchment which is larger than the geographical area of the Uckfield conurbation. There may therefore appear to be discrepancies between the population numbers used in this study and those used in Local Authorities’ housing allocation and LDF documents for different settlements, but these are purely due to reporting methods and do not indicate inaccuracies with the assessment methodology. The differences in population reporting methods will therefore not impact upon the conclusion of this study.

2.26 Table 2.2 highlights those works that are estimated to have limited or no capacity by the end of the plan period (2026). The capacity assessment (as provided in the column WwTW Volumetric

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Capacity) has not taken into account any of the proposed mitigation schemes under AMP5 or NEP as these are subject to Ofwat approval. However, where the proposed consent limits are known, the future capacity has been estimated and the results of this are provided in the comments column. Where the proposed measures, if implemented, would allow all the planned growth to be accommodated, the cell has been shaded orange. For Alfriston, Crowborough St Johns and Newhaven East WwTWs the proposed consents are unknown so it is not possible to identify whether the estimated growth for the areas served by the works could be accommodated without additional investment and upgrades.

Table 2.2 Future Volumetric Capacity Assessment WwTW WwTW DWF Comments Volumetric Capacit Capacity y (m 3/d) Alfriston There may be capacity at the WwTW to accommodate the growth – this will be dependent on the proposed increase to the -49% -97 consented DWF as agreed with the EA. At this stage it is not possible to state whether the works will have the required capacity to accommodate future growth up to 2026. Bexhill And Hastings -1% -367 Blackboys -1% -1 Bodiam, Levetts Lane -30% -6 Brighton, Portobello 1% 781 Cooksbridge -5% -5 Crowborough, St Johns May be capacity at the WwTW to accommodate the growth dependent on the proposed increase in consented DWF as agreed with the EA. At this -27% -163 stage it is not possible to state whether the works will have the required capacity to accommodate future growth up to 2026. Danehill -7% -18 Fairlight -1% -4 Fletching If the proposed consent of 55 m 3/d is agreed, the DWF by 2026 will exceed the consent by 14 m 3/d (25%) and will therefore need increasing. Green -1% -3 Hailsham North -17% -544 Hailsham South -21% -1,524 Halland If the proposed consent of 183 m 3/d is agreed, -37% -49 there will be capacity (1 m 3/d) at the WwTW to accommodate the growth. Iden 1% 3 Lunsfords Cross If the proposed consent of 59 m 3/d is agreed, the DWF by 2026 will exceed the consent by 1 m 3/d -31% -14 and will therefore probably be sufficient to accommodate the growth. Mayfield, Crouch Farm -9% -15 Newhaven East There may be capacity at the WwTW to -12% -1,513 accommodate the growth – this will be dependent on the proposed increase to the

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WwTW WwTW DWF Comments Volumetric Capacit Capacity y (m 3/d) consented DWF as agreed with the EA. At this stage it is not possible to state whether the works will have the required capacity to accommodate future growth up to 2026. Northiam, Mill Corner -61% -12 Northiam, Quickbourne 2% 7 Lane Offham If the proposed consent of 15 m 3/d is agreed, the DWF by 2026 will exceed the consent by 1 m 3/d -100% -8 and will therefore probably be sufficient to accommodate the growth. Plumpton -48% -26 Ringmer, Neaves Lane -10% -96 Ripe If the proposed consent of 53 m 3/d is agreed, -19% -8 there will be capacity (3 m 3/d) at the WwTW to accommodate the growth. Rye -6% -104 2% 5 Shoreham Assessed as part of Shoreham Harbour Regeneration and Adur District Council Outline WCS (Reference 6). This concluded that SWS -23% -3,000 have advised that expansion of the works would be possible provided that additional land can be made available adjacent to the existing site. Streat If the proposed consent of 50 m 3/d is agreed, 3 there will be 86% capacity (43 m /d). 3% 18 Wadhurst Washwell 5% 7 Lane Westfield If the proposed consent of 362 m 3/d is agreed, the DWF by 2026 will exceed the consent by 6 -19% -60 m3/d. This may be sufficient to accommodate the growth increase but may require a further increase to the DWF consent. Wivelsfield If the proposed consent of 405 m 3/d is agreed, 4% 11 3 there will be capacity (98 m /d).

2.27 The conclusions are sensitive to assumptions applied to the calculations, and in particular to the assumption of household consumption. With the publication of the Code for Sustainable homes there is a considerable drive to move towards more water efficient developments. A reduction in water usage would significantly reduce the wastewater generated from new properties, which could result in more properties being able to be treated at the WwTWs using existing headroom capacity. However, whilst water efficiency measures would reduce the volume of sewage, it would tend to increase the strength of the sewage. Consequently, as the volumetric capacity of a WwTW is increased, the biological capacity is reduced, and therefore the capacity at the works is not necessarily released for more housing by water efficiency measures.

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Wastewater Treatment Works Process Capacity Baseline

2.28 The WwTW process capacity has been assessed for each of the works within the ESCC and BHCC study area, based on the current process capacity at the works and the potential capacity and impacts of future development to 2026.

2.29 Process capacity refers to the volume that can be treated to the required quality standards set by the discharge consent. It is assumed that SWS would seek the funding required to upgrade the processes in the works (if necessary) to treat the additional DWF to the standard required under the existing consent. Whilst this assumption is acceptable for the purposes of this study, a further detailed study (a modelling exercise in conjunction with SWS) may be required to assess the actual process capacity and need for process improvements using finalised housing figures, occupancy rates and consumption (based on water efficiency targets) when available. The assessment may also be required to provide information on if/when the funding is required to upgrade the process capacity of the WwTWs as any new upgrades or infrastructure requires funding to be sought by SWS and as such, there is an associated lead-in time for the upgrade works which would limit the amount of development that could take place before the upgrades are in place.

2.30 For the purposes of this study, the process capacity has been assessed by identifying those WwTW that are currently operating under stringent discharge consents and are therefore likely to have less capacity, require special technical measures and incur more expense to treat sewage from new developments up to 2026. A stringent consent is often an effective indicator that an effluent receives little dilution and/or discharges to a high quality watercourse. Tightening of these already strict standards is likely to be an expensive treatment option. In some instances, future development could require the effluent to be treated beyond that current achievable with the Best Available Technology (BAT).

2.31 The current consents for the WwTW in the East Sussex and Brighton and Hove study area have been assessed (where available) to identify those works that are close to current Best Available Technology (BAT) discharge quality limits of 5 mg/l (95%Ile) BOD, 1 mg/l (95%ile) Ammonia and 1 mg/l (mean) phosphorous (P), and will therefore be more constrained in terms of future development and improving the effluent quality from the WwTW. The results provided in this assessment should be taken as indicative and providing guidance to highlight potential rather than definitive constraints in terms of WwTW process capacity to future development across the region.

2.32 The process capacity at the WwTW has been assessed based on the following criteria:

Capacity - The current consents are not considered to be stringent (> 10 mg/l (95%ile) BOD, > 5 mg/l (95%ile) Ammonia and > 2 mg/l (Mean) P) and therefore there is likely to be capacity to treat further flow to the WwTW;

Limited Capacity - The current consents are considered to be stringent (=< 10 mg/l (95%ile) BOD, =< 5 mg/l (95%ile) Ammonia, =<2 mg/l (Mean) P) and future growth at the WwTW may require expensive treatment options to reach the required consent.

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No Capacity - The current consents are at BAT (5 mg/l (95%ile) BOD, 1 mg/l (95%ile) Ammonia and 1 mg/l (Mean) P) and/or are close to BAT and have been identified by the Environment Agency as requiring further investigation.

Not Assessed - The current consent capacity could not be assessed as the WwTW consents were either not available or are descriptive consents.

2.33 Appendix C shows the capacity in terms of consents for all WwTW in the study area. Table 2.3 below highlights those works that currently have limited or no consent capacity and/or any proposed mitigation schemes under AMP5 or NEP that plan to address existing or known future capacity constraints by 2015. S and W refer to summer and winter discharge consent limits; stricter consent targets are required during the summer months to take account of decreased dilution from lower flows in watercourses and warmer temperatures which increase the environmental impacts of polluting loads.

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Table 2.3 Current Process/Consent Capacity Assessment WwTW WwTW Current PR09/NEP Measure Proposed Consent consent Capacity 3 (95%ile/Mean) Battle BOD S10 W40 mg/l P consent of 1mg/l by 22 Dec 2012 Ammonia S3 W6 mg/ Beckley BOD 10 mg/l

Ammonia 3 mg/l Brede, Stubbs Lane Ammonia S5 W10 mg/l P consent of 1mg/l by 22 Dec 2012 Brighton, Portobello UWWTD scheme Village Ammonia S4 W8 mg/l Crowborough, Redgate Mill BOD S10 W20 mg/l UWWTD P consent of 2mg/l by 30 Sept Ammonia S3 W10 mg/l 2014 Crowborough, St Johns Ammonia 4 mg/l DWF consent increase but no other consent changes required Danehill Ammonia S5 W10 mg/l East Dean Descriptive - Proposed consents of BOD 40mg/l and Ammonia 5 mg/l (Mean) by 22 Dec 2012 as part of Groundwater Scheme Fairlight P 1 mg/l Fletching Descriptive - Proposed consents of BOD 40 mg/l by 31 Mar 2015 Forest Row BOD 10 mg/l

Ammonia 5 mg/l Guestling Green P 2 mg/l Hailsham North BOD 7 mg/l New discharge location studies. Ammonia 2 mg/l Investigations agreed by the conservation agencies and the Environment Agency to P 1 mg/l assess the impact of water company assets on the requirements of the CROW Act. Hailsham South BOD 7 mg/l Pevensey Levels Investigation into Ammonia 2 mg/l performance of AMP4 scheme and if any further treatment beyond BAT is needed to P 1 mg/l mitigate P impact on SSSI. (by 31 Mar 2012) Halland Ammonia S5 mg/l DWF Consent Review. Change of Ammonia consent to include Winter consent of 8 mg/l by 31 Mar 2015 Hurst Green BOD 10 mg/l

Ammonia S3 W7 mg/l Iden P 1 mg/l Kingston Hollow BOD 10 mg/l Lunsfords Cross - DWF Consent Review. Proposed consents of BOD 20 mg/l, Ammonia 12 mg/l by 31 Mar 2015 Northiam, Quickbourne Lane Ammonia 5 mg/l Nutley Ammonia 5 mg/l Offham Proposed consent of 15 m 3/d DWF, 40 mg/l BOD and 5 (Mean) mg/l Ammonia by 22 Dec 2012 Ringmer, Neaves Lane Ammonia S5 W10 mg/l Ripe - DWF Consent Review. Proposed Ammonia consent of 16 mg/l by 31 Mar 2015 Ammonia 4 mg/l Sedlescombe - Proposed P consent of 1 mg/l by 22 Dec 2012 BOD S10 W15 mg/l

Ammonia S3 W8 mg/l Streat - Consent conditions required relating to preventing direct discharge to groundwater under certain conditions. Proposed

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WwTW WwTW Current PR09/NEP Measure Proposed Consent consent Capacity 3 (95%ile/Mean) consents of BOD 40 mg/l and Ammonia 5 mg/l (Mean) by 22 Dec 2012 Uckfield BOD S10 W15 mg/l

Ammonia S5 W10 mg/l Vines Cross - UWTD proposed P consent of 2 mg/l by 30 Sept 2014 Wadhurst Washwell Lane - Proposed Ammonia consent of 3 mg/l by 22 Dec 2012 and Quality Risk Assessment (Screening for PS, PHS, BLM, Sanitary, GC-MS scan, Emerging chemicals) by 31 July 2011 Westfield BOD S10 W26 mg/l DWF Consent Review and P. Proposed consents of BOD 7 mg/l, Ammonia 3 mg/l Ammonia S5 W10 mg/l and P 1 mg/l by 31 Mar 2015 (BOD and Ammonia) and 22 Dec 2012 (P) , Beach - Proposed P consent of 1 mg/l by 22 Dec 2012 Winchelsea, Ferry Hill - Proposed P consent of 2 mg/l by 22 Dec 2012 Wivelsfield - DWF Consent Review and P. Proposed consents of BOD 30 mg/l, Ammonia 7 mg/l and P 1 mg/l by 31 Mar 2015 (BOD and Ammonia) and 22 Dec 2012 (P)

2.34 21 WwTW have been identified as being close to the BAT limit for BOD and Ammonia and 18 WwTW have been identified as requiring tightening or setting of numeric consents limits during the next AMP period. The majority of these are related to the setting of Phosphate limits at WwTWs, either under the UWWTD or as part of the measures proposed to meet the requirements of the WFD. Other consent changes are required where the DWF at the works is being reviewed and/or increased and as a consequence the sanitary consents require a tightening to ensure river water quality standards are maintained and meet the WFD standards.

2.35 11 WwTW have been identified as having AMP5 and/or NEP measures during the period 2012 to 2015, which will result in the tightening or setting of consents.,.

Future Growth and Capacity

2.36 As the baseline process capacity assessment is based on an evaluation of the current consents and their relation to the current BAT limits, it is impossible at this stage to identify those WwTW that will constrain future growth to the end of the plan period (2026), beyond the high level assessment provided in the baseline assessment. A detailed Monte Carlo modelling exercise will need to be carried out once the housing development figures have been defined, utilising river water quality data, to calculate the future required consents for each of the WwTW in the catchment. An assessment of the achievability of those consents, in consultation with SWS, can then be undertaken.

Environmental Capacity of Receiving Watercourses

2.37 The environmental capacity for each of the WwTWs within the ESCC and BHCC study area has been assessed, based on the current water quality of the receiving watercourses/ water

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bodies (river and sea) and the potential impact of the effluent discharges on designated ecological sites downstream of the WwTW.

WwTW discharging to rivers

2.38 The environmental capacity of the receiving watercourses has been assessed based on the current compliance with the requirements of the WFD.

2.39 Due to a lack of monitoring information upstream and downstream of the WwTWs (as the majority of the works discharge to small, unmonitored tributaries), the assessment is based on the overall water quality of the water body rather than river reach. Information provided within the South East, Thames and Kent River Basin Management Plans (References 8, 9 and 10) has been used to assess the potential capacity within the individual watercourses downstream of the WwTW i.e. those stretches of river likely to be affected by changes to the upstream discharge as a result of growth in the area.

2.40 Under the WFD, a water body is expected to achieve ‘Good Ecological Status’ by 2015, unless specified otherwise. A high level assessment has been undertaken, using the classifications as provided in the River Basin Management Plans, to define whether there is likely to be capacity for future discharges. However, it should be noted that a key objective of the WFD is that there should be no deterioration in status, even for individual parameters, and as such, once the development details are available for individual WwTW, a more detailed Monte Carlo assessment should be undertaken to determine the impacts of future discharges to the receiving watercourses and the current available capacity within the watercourse.

2.41 The environmental capacity of the receiving water course has been assessed based on the following criteria:

Capacity - The water body is currently achieving ‘good ecological status’ under the WFD or is achieving ‘moderate ecological status’ but only as a result of P concentrations. Therefore, there is unlikely to be less stringent constraints on further effluent discharges from the WwTW to the river as long as the good ecological status is maintained.

Limited Capacity - The water body is currently achieving ‘moderate ecological status’ under the WFD and therefore there is likely to be some restriction on further effluent discharge from the WwTW to the river as the river should aiming to achieve ‘good ecological status’ by 2015 or 2027.

No Capacity - The water body is currently achieving ‘poor’ or ‘bad ecological status’ under the WFD and therefore there will be restrictions on further effluent discharge from the WwTW to the river unless current river quality is improved.

Not Assessed - The water body status has not been assessed in the Draft River Basin Management Plan.

2.42 Appendix D gives the capacity in terms of current WFD status for all WwTW and receiving watercourses in the study area. Table 2.4 highlights those works that currently deemed to have limited or no capacity under the current WFD assessment and/or any proposed mitigation schemes under AMP5 or NEP that plan to address existing or known future capacity constraints by 2015.

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Table 2.4 Current Environmental Capacity Assessment – WFD River Water Quality WwTW Receiving Ecological Chemical Water Body PR09/NEP Watercourse Status Status Designation Measure Proposed Bexhill And Hastings English Channel M G cHMWB Bodiam, Levetts Lane Tributary Of River M Not Good

Rother (Inv) Bodle Street Green Tributary Of Christians M G

River (DO/P) Brede, Stubbs Lane Tributary Of P G  (DO/P/ (P) Fish/Inv) Brede Waterworks River Brede P G (DO/P/ Fish/Inv) Brighton, Portobello English Channel M N/A cHMWB

Burwash Village Trib Of The River Rother M Not Good

(Inv) Camber Jury's Gut Sluice Tidal M N/A cA Basin (DO/P/ Fish) Chailey Longford Stream P N/A

(Inv) Cooksbridge Freshwater Stream Or M N/A River (Amm/ DO/P) East Dean Into Land/Soakaway N/A Not Good  (Discharges To Seaford (P/ Fish) cHMWB (BOD/ And Eastbourne Chalk Ammonia) Gwb) Eastbourne English Channel M N/A cHMWB (DO/P) Fairlight Tributary Of Marsham P N/A

Sewer (P/Inv) Firle, Stamford Tributary Of Glynde B Not Good

Buildings Reach (Fish) Forest Row River Medway M G cHMWB (P/Fish) Guestling Green The Pannel Sewer P N/A

(P/Inv) Hailsham North The Hurst Haven M G  (DO/P/ Iron/ cHMWB Fish) Hailsham South The Horse Eye Sewer M G  cHMWB (P/Inv) Halland Ridgewood Stream M N/A 

(P/Inv) (Ammonia) Hamsey River Ouse M N/A (Amm/ DO/P) Hartfield Tributary Of The River M G cHMWB Medway (P/Fish) Herstmonceux, Freshwater Stream Or M G

Windmill Hill River (DO/P) Herstmonceux, Lime Unnamed Trib Of Iron M G Park Stream (DO/P/ Iron/ cHMWB Fish) Hooe Freshwater Stream Or N/A N/A cHMWB River (DO/P/ Inv) Unnamed Trib Of River P G

Brede (DO/P/

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WwTW Receiving Ecological Chemical Water Body PR09/NEP Watercourse Status Status Designation Measure Proposed Fish/Inv) Lunsfords Cross Unnamed Trib Of East N/A N/A  Stream (DO/P/ Inv) cHMWB (BOD/ Ammonia) Mayfield, Crouch The Coggins Mill Stream M N/A

Farm (DO/P) Newhaven Saline Estuary/English B Not Good

East/Newhaven New Channel (Fish) M G cHMWB Offham Underground Strata M N/A  (Discharges To Brighton (Amm/ (BOD/ And Hove Chalk Gwb) DO/P) Ammonia) Ringmer, Neaves Bulldog Sewer / Glynde B Not Good

Lane Reach (Fish) Ringmer, Norlington Stream B Not Good

Smallholdings (Fish) Ripe Unnamed Trib.Glynde B Not Good 

Reach/Ouse (Fish) (Ammonia) Rodmell Ditch Leading To River M G cHMWB Ouse Sedlescombe The River Brede P G  (DO/P/ (P) Fish/Inv) Shoreham English Channel M N/A cHMWB Stonegate Tributary Of River M Not Good

Rother (Inv) Uckfield Ridgewood Stream M N/A cHMWB (Inv) Freshwater Stream Or P G River (DO/P/ Fish/Inv) Wartling Kentland Fleet M G cHMWB (DO/P/ Fish) Wadhurst Washwell Unnamed Trib Of Tide N/A M  Lane Brook (Amm/P/ (Ammonia) Copper) Westfield Tributary Of River Brede M N/A  (P/Fish) (BOD/ Ammonia/P) Tributary Of River Line M N/A

(P/Inv) Wilmington Tributary Of River N/A Not Good cHMWB Cuckmere (P/ Fish) Winchelsea, Ferry Hill Tributary Of River Brede P G  (DO/P/ (P) Fish/Inv) Wivelsfield River Adur East P N/A  (DO/P/ Inv) (BOD/ Ammonia/P) Notes: cHMWB = Candidate Heavily Modified Water Body cA = Candidate Artificial Water Body

2.43 25 WwTWs have been identified as discharging to watercourses that are classed as having limited environmental capacity, currently only achieving ‘moderate ecological status’ as a result of one or more determinands. 15 WwTW have been identified as discharging to watercourses that are currently achieving ‘poor’ or ‘bad ecological status’ and have been classed as having ‘no capacity at present’ for further growth and will require further investigation and assessment.

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2.44 The limiting determinands for each receiving water body downstream of the WwTW are provided in Table 2.4; these are the determinands that are resulting in the entire water body achieving the moderate status i.e. all other determinands are achieving ‘good’ or ‘high’ status. A more detailed breakdown is provided in Appendix D, which lists the current WFD classification for all individual determinands. It should be noted that some failures, such as those for invertebrates or fish, may be related to hydromorphological or other reasons than discharge quality and the assessment can therefore be considered to be a worst case scenario.

2.45 Where the only determinand limiting the achievement of good status is phosphorus (P), the receiving watercourse has been classified as having available environmental capacity. This is because it is widely recognised that excess phosphorous is a catchment-wide issue and one that is increasingly being identified as a limiting factor in WFD assessments. This is largely the result of the stringent WFD standards applied to the watercourses and as such, and in accordance with other studies currently being carried out, it is believed that P, in isolation, should not be identified as a constraint to development in an area. Therefore, for the purposes of this study, it has not been classed as a capacity constraint unless other determinands are also achieving less that good status in a given water body. It should also be noted that there are a number of measures proposed under PR09 and/or NEP to address the discharge of phosphorous from works within the study area.

WwTW discharging to Bathing Waters

2.46 Bathing Waters are assessed by the Environment Agency throughout the bathing season from mid May until the end of September and data are reported in November each year by Defra. There are 16 bathing waters in East Sussex and Brighton & Hove, as shown in Figure 7. Six WwTWs have been identified as potentially impacting upon bathing waters in the East Sussex and Brighton and Hove coastline.

2.47 Table 2.5 shows the compliance of the bathing waters with the existing mandatory (I) standards and guideline (G) standards under 76/160/EEC, and the predicted compliance with new standards under 2006/7/EC. The revised Bathing Water Directive comes in to force in 2015 and the Environment Agency has conducted an impact assessment using bathing water quality data from 2003-2006 to predict the compliance by 2015. Bathing water quality will be monitored against existing standards under 76/160/EEC until 2012, at which point monitoring will be assessed under revised standards set in Directive 2006/7/EC (Appendix A). The first full assessment under the standards set in 2006/7/EC will be made in 2015.

2.48 The same criteria as that used for the receiving river watercourse capacity assessment has been applied to the predicted WFD compliance assessment for bathing waters, with Excellent and Good compliance being assessed as having Capacity , Sufficient compliance being assessed as having Limited Capacity , and Poor compliance have No Capacity at present.

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Table 2.5 Current Environmental Capacity Assessment - Bathing Water Quality Bathing Bathing Water Compliance Predicted WwTW Impact Water Name Compliance* ID 2004 2005 2006 2007 2008 14200 Bexhill I G I I I Sufficient Bexhill and Hastings 14550 Birling Gap G G G G G Excellent 14950 Brighton Central G G - 14900 Brighton Kemptown G G G I I Good 13900 Camber I G G G I Good Camber 14500 Eastbourne G G G G I Good Eastbourne 14100 Hastings I I I I I Poor 15000 Hove G I G G I Good Newhaven East/ 14700 Newhaven G G Closed I Closed Not Classified Newhaven New 14300 Norman`s Bay I I G I G Poor Eastbourne 14400 Pevensey Bay I G G I G Poor Eastbourne 14150 St Leonards G I I I I Sufficient Bexhill and Hastings 14800 G G G G G Excellent Brighton Portobello Newhaven East/ 14600 Seaford G G G G G Excellent Newhaven New 15100 Southwick G G G G I Excellent 14000 Winchelsea G G G G G Excellent

2.49 There are several reasons why bathing water standards could be failed; potential sources of faecal material include diffuse pollution from livestock & wild animals, urban areas, and poorly operating septic systems. In addition, there may be other local reasons why bathing waters would fail to be compliant, such as discharges from Combined Sewer Overflows (CSOs) during high rainfall. Additionally, the actual impact of faecal material is dependant on a range of factors such as survival rates, transport and dispersal. For this reason it is difficult to assess the constraints in terms of future growth, and a detailed modelling exercise may need to be carried out following the confirmation of growth at the four WwTW discharging directly to the English Channel and any additional estuary discharges that could affect nearby bathing waters.

Designated Sites of Conservation Interest

2.50 Within East Sussex and Brighton and Hove the main sites designated for their conservation interest, which are therefore sensitive to elevated phosphate levels, are the Pevensey Levels Ramsar and Dungeness SAC. These two sites are downstream of, and therefore potentially impacted by, multiple WwTWs as identified in Table 2.6, though the impacts of the various WwTW have not been assessed or attributed at this stage. Dungeness to Level SPA and a further four SSSIs may also be impacted by WwTW discharges and their resultant water quality impacts.

2.51 All WwTWs listed in Table 2.6 below have been assessed as having Limited Capacity in terms of increases in effluent discharges as a result of future growth up to 2026. There needs to be further investigation into the potential impacts of the discharges on the downstream designated sites (once planned growth figures are known) before the impacts from this growth can be assessed.

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Table 2.6 Current Environmental Capacity Assessment - Ecology Ecological Site Designation Potentially Impacting Constraint WwTW Combe Haven SSSI Dungeness SAC Camber Fairlight Guestling Green Dungeness, Romney SSSI Camber Marsh and Rye Bay Icklesham Rye Winchelsea, Beach Winchelsea, Ferry Hill Fairlight Guestling Green Dungeness to Pett Level SPA Icklesham Rye Winchelsea, Beach Winchelsea, Ferry Hill Fairlight Guestling Green Lewes Brook SSSI Kingston Hollow Rodmell Milton Gate Marsh SSSI Wilmington Pevensey Levels Ramsar Bodle Street Green SSSI Hailsham North NNR Hailsham South Hurstmonceux, Windmill Hill Hurstmonceux, Lime Park Wartling

2.52 Figure 8 identifies the sites designated for their conservation interest within the study area and highlights the main sites sensitive to and likely to be impacted by increases to WwTW effluent discharges.

2.53 Due to the presence of a European designated site, namely Dungeness to Pett level SPA and Dungeness SAC, an Appropriate Assessment will be required under the Habitats Directive, to accompany the Core Strategy submission for East Sussex County Council and Brighton and Hove City Council. The requirement for this is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British Law by Regulation 48 of the Conservation (Natural Habitats &c) Regulations 1994. Article 6 (3) states that:

“Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives.”

2.54 Should the Waste and Minerals Core Strategy submission be classed as a ‘plan or project…’ under the terms of the Habitats Directive/Regulations, an appropriate assessment may also be required for effects on the Pevensey Levels Ramsar site.

2.55 The first stage of this should involve the initial (screening) stages of a Habitats Regulation assessment to determine the impact of development on water dependent European sites and include an assessment of nationally and locally designated sites. Regulation 48 states that:

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“A competent authority, before deciding to…give any consent for a plan or project which is likely to have a significant effect on a European site…shall make an appropriate assessment of the implications for the site in view of that site’s conservations objectives.”

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3 Stage 2 Significance of Issues

Sludge treatment capacity

3.1 The Position Statement provided by SWS (Appendix 9) and discussions indicate that while there is currently adequate capacity for sludge treatment and disposal within the ESCC and BHCC areas, SWS may need to explore alternative options in the future. Commercial pressure have led to major retailers restricting the use of sewage sludge fertiliser on crops intended for supermarkets, which may reduce the future disposal capacity of agricultural land. Options for treatment and disposal of sewage sludge will be identified in Stage 3.

WwTW capacity

3.2 Table 3.2 provides a summary of the issues identified in Stage 1 of the study for each to the WwTW within the study area. The issues have been subdivided as above, with the available capacity assessed in terms of sludge, volumetric, consent and environmental. Where applicable, schemes as identified/proposed within SWS’s Final Business Plan (PR09) and the Environment Agency’s NEP have been identified. The capacity assessment has been colour coded to allow a quick appraisal of the WwTW constraints both under current conditions and in the future (as a result of proposed development). An explanation of the colour coding used is provided in Table 3.1 below. The assessment is subject to some uncertainty, and many of the impacts and capacity assessment cannot be undertaken without further more detailed data or subsequent investigations.

3.3 It should be noted when examining Table 3.2 that the presence of individual ‘red’ assessment criteria does not necessarily result in an overall constraint at a particular works. There may be capacity for development despite certain constraints and further assessment should be carried out, in conjunction with SWS and the EA, in order to allow for expansion.

Table 3.1 Significance Assessment Criteria WwTW Volumetric Capacity WwTW Process Capacity Environmental Capacity Capacity in DWF consent Capacity. Good Ecological Status. Likely to Current consents are Descriptive be capacity for development. or much laxer than BAT i.e. >10mg/l BOD, >5mg/l Ammonia Limited or no capacity but Limited or no capacity. Moderate Ecological Status. mitigation measures in place to Current consents are close to Measures will be required to address constraints BAT i.e. <10 mg/l BOD, <5 mg/l bring environment up to Good Ammonia and/or new consents Ecological Status. May be have been proposed as a result capacity for development. of quality constraints and/or DWF consent increases. No capacity and no AMP 5 No capacity. Poor/ Bad Ecological Status. measures in place to address Constraints/issues are known to Measures will be required to capacity constraints exist and there is no capacity to bring environment up to Good tighten consents i.e. new Ecological Status. discharge locations will need to Unlikely to be capacity for be investigated development Not Assessed Not Assessed Not Assessed

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Table 3.2 Significance of Issues Summary

WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Alfriston 3 85 -36% -49% N/A Environment Dependent on Agency extent of DWF Capacity subject to prepared to consent increase AMP scheme increase in AMP5 consented DWF Barcombe Church 1 0 No identified constraints Barcombe New 4 100 21% 17% M No identified constraints (P) Battle 4 835 36% 18% BOD/ NH4/ G P consent of Capacity subject to 1mg/l by 22 AMP scheme Dec 2012 Beckley 2 120 48% 29% BOD/NH4 M No identified constraints (P) Berwick 1 40 65% 59% N/A No identified constraints Bexhill And Hastings 6 11,200 9% -1% M Bexhill 1% capacity shortfall is 3 St 367m /day Leonards Blackboys 3 340 35% -1% M 1% capacity shortfall is (P) only 1m 3/day Blackham 1 50 53% 37% G No identified constraints Bodiam, Levetts Lane 1 55 43% -30% M Further investigation (Inv) needed into growth options Bodle Street Green 1 10 Descriptive M Pevensey Small works having (DO/P) Levels potential env impact Ramsar & which should be SSSI examined further Brede, Stubbs Lane 3 -20 NH4/ P P consent of (DO/P/ Capacity subject to 1mg/l by 22 Fish/Inv) AMP scheme Dec 2012 Brede Waterworks 1 0 99% 99% Descriptive P Receiving watercourse (DO/P/ failing WFD on P levels Fish/Inv) which may limit growth

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Brighton, Portobello 6 25,200 10% 1% UWWTD N/A Saltdean Marginal future capacity scheme shortfall should not limit growth Burwash Common 2 110 35% 14% G No identified constraints Burwash Village 3 330 48% 32% NH4 M Tight consent limit may (Inv) limit growth 3 200 45% 34% G No identified constraints Camber 3 280 49% 42% M Camber Dungeness Receiving watercourse (DO/P/ Fish) SAC & failing WFD on P levels SSSI which may limit growth Catsfield 2 85 64% 53% M Combe Receiving watercourse (P) Haven failing WFD on P levels SSSI which may limit growth Chailey 1 5 Descriptive P Receiving watercourse (Inv) failing WFD on P levels which may limit growth Cooksbridge 2 75 16% -5% M Receiving watercourse (Amm/ failing WFD which may DO/P) limit growth Crowborough, Redgate Mill 5 3,690 25% 8% BOD/ NH4/ M P consent of (P) 2mg/l by 30 Capacity subject to Sept 2014 AMP scheme (UWWTD) Crowborough, St Johns 4 75 -23% -27% NH4 M Environment Dependent on (P) Agency extent of DWF Capacity subject to prepared to consent increase AMP scheme increase in AMP5 consented DWF Danehill 3 190 10% -7% NH4 M Future capacity shortfall (P) may limit future growth Ditchling 3 100 26% 17% M No identified constraints (P) East Chiltington, Highbridge 1 5 Descriptive M No identified constraints (P) East Chiltington, Hollycroft 1 10 Descriptive M No identified constraints (P) East Dean 3 -125 26% 38% Descriptive N/A Capacity subject to

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Proposed Discharges AMP scheme consents of to BOD 40mg/l groundwater and NH4 5 mg/l (Mean) by 22 Dec 2012 East Hoathly 3 250 57% 32% G No identified constraints Eastbourne 6 3,460 24% 21% M Eastbourne Receiving watercourse (DO/P) failing WFD which may limit growth 1 10 Descriptive M No identified constraints (P) Fairlight 3 200 18% -1% P P Receiving watercourse (P/Inv) failing WFD on P levels which may limit growth Firle, Stamford Buildings 1 15 Descriptive B Receiving watercourse (Fish) of bad quality but unlikely that this very small works is the sole cause Fletching 1 65 Proposed -25% Descriptive M consent of 55 (if new consent Proposed (P) Capacity subject to m3/d by 31 Mar agreed) consents of AMP scheme 2015 BOD 40 mg/l by 31 Mar 2015 Forest Row 4 750 47% 33% BOD/NH4 M Receiving watercourse (P/Fish) failing WFD which may limit growth Frant 3 15 38% 35% N/A No identified constraints Guestling Green 3 170 23% -1% P P Future capacity shortfall (P/Inv) & receiving watercourse failing WFD which may limit growth Hailsham North 4 7,420 47% -17% BOD/ NH4/ P M Pevensey Future capacity shortfall New discharge (DO/P/ Iron/ Levels and no possibility to location study Fish) Ramsar & increase consented SSSI DWF will limit growth Hailsham South 6 8,890 17% -21% BOD/ NH4/ P M Pevensey Future capacity shortfall New discharge (P/Inv) Levels and no possibility to location study Ramsar & increase consented SSSI DWF will limit growth

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Halland 2 60 -25% -37% NH4 – Change M DWF Consent If proposed of NH4 consent (P/Inv) Review – consent is to include proposed DWF agreed then Winter consent Capacity subject to increase to capacity at of 8 mg/l by 31 AMP scheme 183m 3/d by 31 WwTW to Mar 2015 Mar 2015 accommodate growth Hamsey 1 6 Descriptive M Receiving watercourse (Amm/ failing WFD which may DO/P) limit growth Hartfield 3 40 33% 29% M Receiving watercourse (P/Fish) failing WFD which may limit growth Herstmonceux, Windmill Hill 4 410 35% 10% M Pevensey Receiving watercourse (DO/P) Levels failing WFD which may Ramsar & limit growth SSSI Hurstmonceux, Lime Park 1 20 Descriptive M Pevensey Receiving watercourse (DO/P/ Iron/ Levels failing WFD which may Fish) Ramsar & limit growth SSSI High Hurstwood 1 10 Descriptive G No identified constraints Hooe 3 210 30% 14% N/A No identified constraints (DO/P/ Inv) Hurst Green 3 55 18% 15% BOD/ NH4 M Tight consent standards (P) should not limit growth Icklesham 3 -10 45% 46% P Dungeness Receiving watercourse (DO/P/ SPA & failing WFD which may Fish/Inv) SSSI limit growth Iden 3 270 20% 1% P M Slight future volumetric (P) shortfall but should not limit growth Kingston Hollow 3 100 25% 13% BOD N/A Lewes Tight consent standards Brook should not limit growth SSSI

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Lunsfords Cross 1 20 -18% -31% Proposed N/A DWF Consent If proposed consents of (DO/P/ Inv) Review consent is BOD 20 mg/l, Proposed DWF agreed then NH4 12 mg/l by Capacity subject to increase to 59 capacity at 31 Mar 2015 AMP scheme m3/d by 31 Mar WwTW to 2015 accommodate growth Maresfield 3 260 43% 24% M No identified constraints (P) Mayfield, Crouch Farm 3 75 3% -9% M Capacity shortfalls and (DO/P) failing water quality may limit growth Mayfield, Meres Farm 3 110 55% 51% M No identified constraints (P) Netherfield 2 -65 25% 51% G No identified constraints Newhaven East/Newhaven New 6 5,215 0% EA -12% 400 mg/l BOD B Newhaven prepared to Dependent on & 300 mg/l SS (Fish) Capacity subject to increase extent of DWF M Seaford consented consent increase AMP scheme DWF in AMP5 Newick 4 280 16% 10% M No identified constraints (P) Northiam, Mill Corner 1 50 5% -61% Descriptive N/A Capacity shortfalls may limit growth Northiam, Quickbourne Lane 3 420 30% 2% NH4 M Tight consent standards (P) & slight capacity shortfall should not limit growth Nutley 3 100 20% 6% NH4 M Tight consent standards (P) should not limit growth Offham 1 10 -62% -100% Descriptive M Proposed If proposed Proposed (Amm/ increase in consent is consent of 40 DO/P) DWF to 15 m 3/d agreed then mg/l BOD and Capacity subject to by 22 Dec 2012 capacity at 5 (Mean) mg/l AMP scheme WwTW to NH4 by 22 Dec accommodate 2012 growth Plumpton 1 460 50% -48% M Capacity shortfalls may (P) limit growth

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Ringmer, Neaves Lane 4 615 8% -10% NH4 B Capacity shortfalls& (Fish) failing water quality may limit growth Ringmer, Smallholdings 1 20 Descriptive B Receiving watercourse (Fish) of bad quality but unlikely that this very small works is the sole cause Ripe 1 10 -14% -19% Proposed NH4 B DWF Consent If proposed consent of 16 (Fish) Review consent is mg/l by 31 Mar Proposed agreed then 2015 Capacity subject to increase in capacity at AMP scheme DWF to 53 m 3/d WwTW to by 31 Mar 2015 accommodate growth Robertsbridge 4 190 15% 6% NH4 M No identified constraints (P) Rodmell 3 0 43% 43% M Lewes Receiving watercourse Brook of bad quality but unlikely that this very small works is the sole cause Rye 4 1,010 15% -6% N/A Dungeness Future capacity shortfall SPA & may limit growth SSSI Sedlescombe 3 140 22% 2% Proposed P P consent of 1 (DO/P/ Capacity subject to mg/l by 22 Dec Fish/Inv) AMP scheme 2012 Shoreham 6 10,000 15% -23% No information Southwick Capacity of in WCS Despite future capacity 4,000 houses. shortfall SWS have SWS have indicated expansion indicated would be possible expansion would be possible Staplecross 2 120 34% 6% BOD/ NH4 N/A Tight consent standards should not limit growth Stonegate 1 45 Descriptive M Receiving watercourse (Inv) failing WFD but unlikely that this very small works is the sole cause

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Streat 1 5 Proposed DWF 86% Proposed consent of 50 (if new consent consents of m3/d by 22 Dec agreed) BOD 40 mg/l Capacity subject to 2012 and NH4 5 mg/l AMP scheme (Mean) by 22 Dec 2012 Ticehurst 4 480 28% 3% M Future capacity shortfall (P) should not limit growth Uckfield 5 3,220 33% 15% BOD/ NH4 M Tight consent standards (Inv) and filing water quality may limit growth Udimore 1 10 Descriptive P Receiving watercourse (DO/P/ failing WFD which may Fish/Inv) limit growth Vines Cross 5 1,365 27% 15% Proposed P M consent of 2 (P) Capacity subject to mg/l by 30 Sept AMP scheme 2014 (UWWTD) Wallcrouch 1 25 Descriptive N/A No identified constraints Wartling 1 5 Descriptive M Pevensey Receiving watercourse (DO/P/ Fish) Levels failing WFD but unlikely Ramsar & that this very small SSSI works is the sole cause Wadhurst Washwell Lane 3 130 34% 5% Proposed NH4 M consent of 3 (Amm/P/ mg/l by 22 Dec Copper) Capacity subject to 2012 and AMP scheme Quality Risk Assessment by 31 July 2011 Wadhurst Whitegates Lane 4 235 51% 45% N/A No identified constraints Westfield 4 230 1% -19% BOD/ NH4/ M DWF Consent If proposed Proposed (P/Fish) Review – consent is consents of Proposed DWF agreed then BOD 7 mg/l, of 362 m 3/d by capacity at NH4 3 mg/l and Capacity subject to 31 Mar 2015 WwTW to P 1 mg/l by 31 AMP scheme accommodate Mar 2015 growth (BOD and Ammonia) and 22 Dec 2012 (P)

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WwTW WwTW Indicative Current WwTW Future WwTW WwTW Environmental Capacity 3,4 Overall Constraint (Size population Volumetric Volumetric Consent Water Bathing Ecology 3 Band) range to Consent Consent Capacity Quality Water 2 3 3 2026 (PE) Capacity Capacity (WFD) Quality 3 Westmeston 1 5 Descriptive M No identified constraints (P) Whatlington 1 10 Descriptive M Receiving watercourse (P/Inv) failing WFD but unlikely that this very small works is the sole cause Wilmington 1 10 Descriptive N/A Milton No identified constraints (P/ Fish) Gate SSSI Winchelsea, Beach 3 165 53% 46% Proposed P N/A Dungeness consent of 1 SPA & Capacity subject to mg/l by 22 Dec SSSI AMP scheme 2012 Winchelsea, Ferry Hill 2 125 62% 10% Proposed P P Dungeness consent of 2 (DO/P/ SPA & Capacity subject to mg/l by 22 Dec Fish/Inv) SSSI AMP scheme 2012 Wivelsfield 3 235 18% 4% Proposed P DWF consent If proposed consents of (DO/P/ Inv) review consent is BOD 30 mg/l, Proposed DWF agreed then NH4 7 mg/l and Capacity subject to consent of 405 capacity at P 1 mg/l by 31 3 AMP scheme m /d by 31 Mar WwTW to Mar 2015 2015 accommodate (BOD and growth NH4) and 22 Dec 2012 (P)

Notes: 1. PE Size Band: 1: 0 – 250 PE, 2: 250 – 500 PE, 3: 500 – 2,000 PE, 4: 2,000 – 10,000 PE, 5: 10,000 – 25,000 PE, 6: > 25,000 PE. Figures are based on information provided by Southern Water Services Ltd 2. Figures are based on information provided by Southern Water Services Ltd 3. Green = Capacity; Orange = Limited or No Capacity but mitigation measures in place to address constraints; Red = No Capacity - alternative options will need to be devised; Grey = No information available for assessment. 4. WFD Water Quality assessment of Ecological Status based on results presented in the South East River Basin District River Basin Management Plan (Draft, December 2008). H = High, G = Good, M = Moderate, P = Poor, B = Bad.

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4 Hailsham North and South WwTW

Significance of Issues Assessment

4.1 As discussed above, it should be noted when examining Table 3.2 that the presence of individual ‘red’ assessment criteria does not necessarily result in an overall ‘red’ score indicating a constraint at a particular works. The works which are identified above as having an overall constraint score which is ‘orange’ do not have absolute constraints to future development, as it may be possible to increase the consented DWF or process capacity at the existing works for example, and these works will therefore not be carried forward further to the Stage 3 options assessment.

4.2 Of the works considered above in the significance of issues assessment, as summarised in Table 3.1 above, only the two Hailsham WwTWs (North and South) have an overall ‘red’ scoring, indicating there is limited capacity for further expansion. These two works will therefore be considered further in the following section.

4.3 Hailsham North serves approximately one third of properties located within the north of Hailsham (together with , Hellingly and Lower Dicker). Hailsham South currently serves approximately two thirds of properties located within the south of Hailsham (together with Polegate and Jevington). For the purposes of this study Hailsham North and South can be considered to be a single works, as due to the proximity of the two sites it would be possible to transfer flows between the two works. Both of the Hailsham works currently treat the wastewater to high standards (7 mg/l BOD and 2 mg/l Ammonia) and discharge to the Pevensey Levels. The Environment Agency has advised SWS that it will not be permitted to increase the effluent load discharged above that currently consented because of environmental constraints identified in their report ‘Creating a Better Place: Planning for Water Quality in the South East’ (Reference 11).

4.4 The Environment Agency has recently re-assessed available headroom and has estimated that there is capacity for a higher number of households to connect to the existing works than previously anticipated. This means that further development of 2,900 and 2,400 households can be connected to Hailsham North and South respectively. Any growth above this would result in the works exceeding the consented DWF and would not be able to be accommodated without the location of an alternative site for discharge of treated effluent. This may require the provision of a new WwTW site and with the associated infrastructure needing planning and discharge consents it is unlikely that construction for this would take place before 2015.

4.5 Though the consented DWF capacity allows for an additional 2,900 households to be connected to Hailsham North WwTW, the number of households that could actually be treated by the works, i.e. its installed treatment capacity, is only 1,400 households. SWS have applied for funding to provide additional treatment capacity to match the consented DWF headroom available. It is estimated, subject to approval by Ofwat, that the physical infrastructure can be delivered by March 2012.

4.6 The treatment capacity of Hailsham South matches the consented capacity set by the Environment Agency so no process upgrades are required.

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4.7 An additional estimated growth of up to 11,000 households may need to be accommodated at the new WwTW up to 2026. SWS has included a scheme in its PR09 Business Plan for funding to investigate a new discharge location to serve new development in the Hailsham/Polegate area. If approved by Ofwat, the investigation is scheduled for completion in March 2013. The feasibility study will define the most appropriate site for treatment, discharge, location and method of disposal, dependent on Environment Agency approval of a Consent to Discharge. This would allow a proposal to advance towards the planning application stage and it is expected that the proposed scheme would be delivered in the period 2015 to 2020 (AMP6).

4.8 Options for the new WwTW include either discharging to the sea (subject to running a new outfall across sensitive land and building a long-sea outfall) or to discharge to the River Cuckmere, though the discharge standards for this have yet to be assessed against the WFD requirements.

4.9 The Environment Agency has stated that it would consider water efficiencies elsewhere in the catchment as a suitable option to allow for growth, providing the DWF does not increase to a level where the current DWF consent is breached.

4.10 The main environmental capacity constraint at Hailsham North and South WwTWs is phosphorous and the impact of the discharge from the existing works to the Pevensey Levels SSSI, which is known to be impacted in places from polluting discharges. Natural England (Reference 12) lists the following units of the Pevensey Levels SSSI as being in unfavourable condition:

• Unit 3 is in unfavourable condition (no change) due to water pollution (discharge); • Unit 10 is in unfavourable condition (recovering) subject to an AMP4 scheme; • Unit 14 is in unfavourable condition (no change) due to water pollution (discharge); • Unit 18 is in unfavourable condition (no change) due to water pollution (discharge); and • Unit 50 is in unfavourable condition (no change) due to water pollution (agriculture/run-off), although Natural England notes an ‘outstanding AMP4 discharge which has not as yet been remedied’.

4.11 A Pevensey Level Investigation is proposed by the Environment Agency NEP scheme under an Urban Waste Water Treatment Directive Sensitive Area (eutrophic) driver. This is planned to assess the performance of the AMP4 scheme and if any further treatment beyond BAT is needed to mitigate impacts on the SSSI. This scheme is planned for completion by the end of March 2012.

Crowborough WwTW

4.12 There is currently limited existing treatment capacity at Crowborough Redgate Mill WwTW. SWS is seeking funding for a quality scheme (P stripping) at the works in the AMP5 period. This will increase the treatment capacity by 20%, providing capacity for around 2,000 additional households. The scheme, if granted approval by Ofwat, is scheduled for completion in September 2014.

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5 Stage 3 - Option Assessment

WwTW Option Identification

5.1 Stage 2 of this study has identified WwTWs in the ESCC/BHCC area where there are capacity shortfalls (consent, process or volumetric) which may limit future development. To overcome these shortfalls, options for the works have been identified in order that they may be compared, to find the most practical solution and allow for expansion.

5.2 Table 5.1 below list the options identified for each of the works, which are then assessed in turn in Table 5.2. The ‘Constraint’ column reflects the overall constraints identified in Table 3.2 above and is colour coded to indicate whether there is an overall limit on future development.

Table 5.1 Option Identification

WwTW Est. Capacity Option Growth to 2026 (PE)

Vol. Current Vol. Current Future Vol. Consent Environmental Constraint Alfriston 85 Application for a new DWF Consent. Bexhill And 11,200 The WwTW is large and it is unlikely that the breaching of the DWF Hastings consent to meet future growth demands will be significant. An upgrade of

the DWF consent will be required and there may be a requirement to improve the process capacity due to the nearby Bathing Water sites. Bodiam, Levetts 55 There may be a requirement to increase the current works and/or add an Lane additional tank to treat the additional flow. There are unlikely to be process issues. Brede, Stubbs -20 Limited options for growth at this site. Though there is currently no Lane growth planned, should growth be planned to drain to this works, alternative treatment options and locations may be required. Brede 0 Limited options for growth at this site. Though there is currently no Waterworks growth planned, should growth be planned to drain to this works, alternative treatment options and locations may be required. Chailey 5 There may be a limit to future growth at this site due to the downstream water quality. However, this is unlikely to be a result of the small discharge, but any significant growth at this works will need to be assessed and increased process capacity or discharge locations considered. Crowborough, St 75 Measures proposed in PR09 should make growth at this site viable but if Johns the scheme does not go ahead then the growth proposed for this works will need to be raised as a significant issue. Danehill 190 Application for a new DWF Consent and potential increase in process

capacity. Fairlight 200 Application for a new DWF Consent and potential increase in process

capacity. Firle, Stamford 15 It is not possible to link the environmental constraint to the works, and Buildings though the current discharge is very small, any increase in this could

result in a deterioration of downstream water quality and therefore it is not recommended that significant growth is planned for this works. Fletching 65 Further increase in DWF consent and process upgrade.

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WwTW Est. Capacity Option Growth to 2026 (PE)

Vol. Current Vol. Current Future Vol. Consent Environmental Constraint Guestling Green 170 Application for a new DWF Consent and potential increase in process capacity. Hailsham North 7,420 Growth cannot exceed 2,900 houses until a solution is identified. A new WwTW or transfer of treated flow to the sea is likely to be required.

Hailsham South 8,890 Growth cannot exceed 2,400 houses until a solution is identified. A new WwTW or transfer of treated flow to the sea is likely to be required.

Icklesham -10 Limited options for growth at this site. Though there is currently no growth planned, should growth be planned to drain to this works, alternative treatment options and locations may be required. Mayfield, Crouch 75 Could increase DWF and process capacity/consent and/or transfer to Farm Mayfield, Meres Farm WwTW. Newhaven 5,215 Application for a new DWF Consent and potential increase in process East/Newhaven capacity. New Northiam, Mill 50 Could transfer flow to larger Northiam, Quickbourne Lane WwTW.

Corner Plumpton 460 Large increase in works size. Is likely to require a new WwTW as an upgrade would not be possible to accommodate the level of growth proposed. Ringmer, 615 Application for a new DWF Consent and potential increase in process Neaves Lane capacity.

Ringmer, 20 Could transfer flow to larger Ringmer, Neaves Lane WwTW.

Smallholdings Ripe 10 Any significant growth at this works would require a transfer of flow to be considered due to the downstream water quality.

Rye 1,010 Application for a new DWF Consent and potential increase in process capacity. Will need to review when WFD assessment has been undertaken. Sedlescombe 140 DWF will be near capacity so may need to review process capacity with

proposed growth. Shoreham 59,000 The treatment works would have to expand outside of its current boundaries. SWS advised as part of the Shoreham WCS that such

expansion would be possible, provided that additional land can be made available adjacent to the existing site Udimore 10 There may be a limit to future growth at this site due to the downstream water quality. However, this is unlikely to be a result of the small discharge, but any significant growth at this works will need to be assessed and increased process capacity or discharge locations considered. Winchelsea, 125 Downstream environmental constraints – if these cannot be resolved Ferry Hill may need to consider options to transfer flow to another WwTW.

Wivelsfield 235 Downstream environmental constraints – if these cannot be resolved may need to consider options to transfer flow to another WwTW. Growth up to 2026 may require a further consent review.

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WwTW Option Assessment

5.3 The works which are identified above as having an overall constraint score which is ‘orange’ do not have absolute constraints to future development and will therefore not be carried forward further to the Stage 3 options assessment. For the majority of WwTWs, growth is limited by the consented DWF or the size of the current works. The most reasonable option considered in these instances is either applying for a new DWF consent, upgrading consent or improving works or process. For smaller works, transferring flow to a larger works where capacity exists may also be an option.

5.4 However, as discussed above in section 4, it has been identified for Hailsham North and South that there is a significant overall constraint on future development. There is significant growth proposed in the area (11,000 households may need to be accommodated up to 2026).

• Hailsham North - Growth cannot exceed 2,900 houses until a solution to increase capacity is identified.

• Hailsham South - Growth cannot exceed 2,400 houses until a solution to increase capacity is identified.

5.5 Options for the Hailsham works will therefore be considered further. As previously discussed, the two sites have been considered as a single WwTW due to the options for transferring the flow between the two and therefore the Preferred Option would aim to provide for the whole of Hailsham (both North and South).

5.6 The following options were therefore identified for the whole of Hailsham:

• Option 1: Construct a new outfall to transfer additional flows from new housing to discharge to the sea via a long sea outfall, thereby theoretically allowing for an increase in consented Dry Weather Flow from the works;

• Option 2: Construct a single new works to replace Hailsham North and South, at a location to be confirmed, which discharges to the River Cuckmere upstream of Arlington Reservoir. The Cuckmere has been selected as a suitable alternative discharge location as the river catchments to the east of Hailsham are too small and unlikely to provide adequate dilution of discharged effluent. Discharging upstream of the South East Water abstraction point at Arlington would have water resources benefits, although would require the discharged wastewater to be treated to a higher standard to meet drinking water requirements;

• Option 3: Construct a single new works to replace Hailsham North and South, at a location to be confirmed, which discharges to the River Cuckmere downstream of Arlington Reservoir. This would theoretically allow for more relaxed discharge standards to be applied to the effluent, although there would be no water resource benefits as the discharged water would effectively be lost from the catchment;

• Option 4: Construct a new works to replace Hailsham North and South, at a location to be confirmed, which discharges to the sea via a long sea outfall; and

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• Option 5: Relocate the outfall from the existing works to discharge to the River Rother, the only other major watercourse in the area.

5.7 Of the above options, 4 and 5 can be dismissed on the grounds of cost; to replace the works and construct a new long sea outfall would be considerably more expensive than either of the options separately and to discharge to the Rother would involve pumping over a greater distance than to discharge to the Cuckmere. Ofwat requires that SWS consider the most cost- effective options for works improvements and therefore only options 1, 2 and 3 have been carried forward to the options appraisal process.

5.8 To aid in the identification of the preferred option, these options have been appraised against the Evaluation Criteria for Preferred Options provided in the ESCC and Brighton & Hove LDF: Waste and Minerals Core Strategy- Preferred Options Process Framework.

5.9 Assessment of the options revealed that for a Preferred Option to be identified, further information on the options is required to enable a better understanding of deliverability as well as sustainability effects (see also Sustainability Appraisal findings). At present, SWS have submitted proposals to determine a new discharge location to serve new development in the Hailsham/Polegate area. If approved by Ofwat a feasibility study on treatment and potential locations for a new facility will be undertaken (scheduled for completion March 2013).

5.10 It is therefore recommended that for Hailsham, the preferred option should be a general policy identifying the need for extra capacity in the area. The policy should also include criteria to be used in identifying potential locations for the location of new capacity as well as key environmental constraints to be considered.

5.11 The following table, Table 5.2, assesses the relative merits of the three options identified. As described in our tender brief, this has been carried out using the methodology developed by Scott Wilson for ESCC’s Waste and Minerals Core Strategy. This methodology has been proven to establish a clear audit trail for examination of decision made as part of the Core Strategy and is set out with reference to PPS12 and PINS/PAS guidance on the tests of soundness of a Development Plan Document (Reference 14). Please refer to this document for a full description of the methodology.

5.12 As for previous stages of this study, the individual elements of the Option Assessment have been colour coded for ease of reference.

Table 5.2 WwTW Option Assessment Key Findings / Evidence Option Option 2 Option 3 Comments 1

Consistency (PPS 12: Test of National Policy) 1. Does the option Relevant policy includes EU Directives All options conform to generally conform to Urban Waste Water Directive, National Policy National Policy? Groundwater Directive, Bathing water Directive and the WFD Deliverability (PPS 12: Test of Effectiveness) 2. Does the option Policy CC7 on infrastructure and All options conform to generally conform to implementation the RSS the RSS?

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Key Findings / Evidence Option Option 2 Option 3 Comments 1

3. Are you able to Southern Water, Environment Agency, South East Southern Water will identify who will Planning Authority Water also ultimately be deliver the option and involved responsible, although when? due to approval would be impacts on needed from key Arlington stakeholders. abstraction 4. Do key delivery Ofwat approval required, planning South SWS and EA support partners (i.e. application and discharge consents also East the investigation of identified in Q3 required water available options on support the option? have not water quality been grounds, however EA consulted and Natural England regarding may have concerns this option regarding construction across the Pevensey Levels 5. Is the option No cross boundary issues n/a n/a No cross boundary consistent with the issues approach of neighbouring authorities where cross boundaries issues are relevant? 6. Are resources an Funding could be a potential constraint Ofwat approval will be issue, or is there any required for funding evidence that the option cannot be delivered? 7. Is there any Delivery expected within AMP6 period – Delivery dependent on evidence the option in 5 years time. Not clear the exact OFWAT approval of cannot be delivered delivery dates- dependent on funding, should this be within the plan consents/approvals granted delivery period? should be possible within plan period. 8. Taking into account Planning and discharge consents, Dependent on funding the answers to Q 3–7, funding approval from OFWAT is there an and regulatory unacceptable risk that approval from EA and the option will not be planning authorities implemented for one reason or another (what might go critically wrong with this option’)? Flexibility (PPS 12: Test of Effectiveness) 9. Is the option Implementation of Water Framework Water Will help deliver deliverable under Directive – at least good quality for all resources statutory obligations changing waters should be achieved by 2021 improveme under forthcoming circumstances? nts would legislation (E.g. change in also result legislation, national from this or regional policy, option economic change, socio/political/cultural change, climate change etc). Consider how such changes might affect the issue.

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Key Findings / Evidence Option Option 2 Option 3 Comments 1

Monitoring (PPS 12: Test of Effectiveness) 10. Are clear targets SWS has included proposals for a Targets can be able to be identified? scheme in PR09 Business Plan for a identified new discharge location in Hailsham/Polegate area 11. Can you measure If approved by Ofwat progress can be Outcomes can be and monitor monitored monitored outcomes? HRA (The Habitats Regulation Test) 12. Does the option The EA has advised SWS that it will not Further assessment generate an adverse be permitted to increase effluent load would be necessary to effect on the integrity discharged above that current determine the impact of a European site or consented because of environmental on designated sites European offshore constraints. The Pevensey Levels, marine site? although not a designated SAC, may require a Habitats assessment. However, there is the potential for an impact on the Dungeness SAC to the east of the study area, which may need to be assessed under the Habitats Regulations. 13. Can adequate Planning permission mitigation measures and discharge consent be put in place to unlikely to be granted address significant without adequate effects? mitigation SA/SEA (The Sustainability Appraisal Test) 14. Do the outcomes An adverse effect was anticipated for No No The sustainability test of SA/SEA suggest Option 1 with respect to SA Objective 9 additional additional shows a slight the option is ‘To limit the causes of and adapt to energy energy preference for Option sustainable? climate change’. Option 1 would require demand demand 1 due to the increased the pumping of treated effluent to from from energy demands of a enable discharge to sea, which would operation of operation of new works, this will be create an additional energy demand new works new works minimal. Minor over and above the operation of the compared compared adverse effects on WwTW. Over the course of the option to existing to existing historic environment, this increased energy demand is judged works works landscape, to be significant. biodiversity/geodiversit It is possible that all the options may y and residential have adverse effects on the historic amenity are possible environment, landscape, under all of the biodiversity/geodiversity and residential options. amenity. For all options it is assumed that any adverse effects will be minor only given that these will be controlled by the EIA and planning application process to ensure adverse effects are not significant. As the locations, nature and scale of the developments under each option are unknown it is not possible to make a judgement on whether any particular option will have a greater effect.

Community Engagement Test (evidence of participation – the Justifiable Test (robust and credible evidence base))

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Key Findings / Evidence Option Option 2 Option 3 Comments 1

15. Do the responses n/a No consultation carried to Issues and Options out on the 3 options at Consultation suggest this stage the option is supported? 16. Do the responses n/a No consultation carried to the Options out on the 3 options at Testing Dialogue this stage Meetings suggest the option is supported? Research findings (evidence of fact finding – the Justifiable Test (robust and credible evidence base)) 17. Do the findings of Wastewater Management study While this study Technical supports not increasing existing supports the three Studies/Research discharge but does not provide options, further work is support the option? preferred option. Further work is required to fully assess (Include relevant needed in order to identify a preferred them. studies to the issue option. being considered, not all studies will be relevant) Overall Assessment CONCLUSION Further work required to identify a preferred option

Consistency: All options conform

Deliverability: All options subject to funding and Southern Water will approval ultimately be responsible for delivery, although approval would be needed from key stakeholders Flexibility: All options deliverable All options will help deliver statutory obligations under forthcoming legislation Monitoring: All options can be monitored Via Ofwat Targets can be progress identified and outcomes monitored HRA: All options may have a potential impact A HRA may be required SA: Adverse effect anticipated from energy No preferred option demand under Option 1 was identified. Uncertainty over the scale, location and nature of development proposed under each of the options introduces uncertainty in the prediction of effects Community No consultation carried out at this stage Engagement: but information was sought from industry that informed this study.

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5.13 As shown in the table above, there is no single preferred option for the capacity shortfall at Hailsham. Either option of constructing a new outfall from the existing works or building a single new works to replace Hailsham North and South may be feasible. All three options would solve the current capacity shortfall, which is caused by the constraint of the water quality issues in the receiving watercourse, the Horse Eye sewer. However, all options could also cause further issues, most obviously on the Pevensey Levels and the River Cuckmere.

5.14 Our recommendation is therefore that the preferred option for Hailsham should be a policy identifying the need for capacity and criteria on site location and environmental constraints. This will allow both options to be assessed further when information is available and it will avoid being prescriptive and allow delivery partners to put options forward. Any such policy should be developed in conjunction with the relevant stakeholders, most notably Southern Water, which is carrying out its own investigation into the available options. Consultation with the EA and Natural England is essential, along with discussions with other stakeholders (to be identified at a later date).

Sewage sludge

5.15 Stage 2 of the study identified that alternative treatment and disposal options may be needed in the future; the following options have been identified for sludge treatment and disposal:

• Option 1: SWS operate a sludge treatment facility at Hastings, however due to planning permission constraints on the number of permitted vehicle movements this facility does not currently operate at full capacity. A proposal has been put forward to improve the A259 link road around Hastings, which would alleviate traffic and air quality issues and possibly allow for increased utilisation of the works; a public enquiry will be held into this in November;

• Option 2: SWS are exploring the option of constructing a new Energy from Waste (EfW) plant in the SWS area, for the thermal destruction of waste with energy recovery.

Table 5.3 Sewage Sludge Option Assessment Key Findings / Evidence Option 1 Option 2 Comments

Consistency (PPS 12: Test of National Policy) 1. Does the option generally Relevant policy includes European Both options conform conform to National Policy? Directives; Integrated Pollution to national policy. Prevention and Control Directive, National Emissions Ceilings Directive, Renewables Directive, Landfill Directive, the Water Framework Directive, Urban Wastewater Treatment Directive, Water Framework Directive. Relevant Planning Policy Statements include Planning and Climate Change Supplement to PPS1, PPS22: Renewable Energy, PPS23: Planning and Pollution Control and PPS10: Planning for Sustainable Waste Management.

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Key Findings / Evidence Option 1 Option 2 Comments

Deliverability (PPS 12: Test of Effectiveness) 2. Does the option generally Policy CC7 on infrastructure and In conformity. conform to the RSS? implementation 3. Are you able to identify who Southern Water, Environment Agency, Southern Water will will deliver the option and Planning Authority. For option 2 it may ultimately be when? be a private waste company who would responsible, although construct and manage the EfW plant approval would be under contract. needed from key stakeholders. 4. Do key delivery partners (i.e. Ofwat approval required. Planning The key delivery identified in Q3 support the application and environmental permits partners have not option? also required. The key delivery been consulted with at authorities have not been consulted at this stage. this stage. 5. Is the option consistent with No cross boundary issues n/a n/a the approach of neighbouring authorities where cross boundaries issues are relevant? 6. Are resources an issue, or is Funding could be a potential constraint Ofwat approval will be there any evidence that the required for funding. option cannot be delivered? 7. Is there any evidence the Delivery expected within AMP6 period – option cannot be delivered in 5 years time. The exact delivery within the plan period? dates are not clear as this is dependent on consents/approvals

8. Taking into account the Planning and environmental permits, answers to Q 3–7, is there an funding unacceptable risk that the option will not be implemented for one reason or another (what might go critically wrong with this option’)? Flexibility (PPS 12: Test of Effectiveness) 9. Is the option deliverable The Climate Change Act will drive Option 2 will generate under changing forward the need to deliver reductions energy from waste circumstances? in carbon emissions and will create a and contribute to the (E.g. change in legislation, favourable environment for solutions reduction of carbon national or regional policy, that deliver reductions in greenhouse emissions. Option 2 economic change, has emissions. Increases in Landfill Tax will require the socio/political/cultural change, and fines on Waste Authorities for the disposal of residual climate change etc). Consider landfilling of waste will create a fiscal ash. Disposal of this how such changes might affect disincentive for landfilling. ash to landfill in the the issue. future is likely to be constrained by availability and cost. Consideration will be needed of possible alternative disposal routes for ash when assessing the suitability of Option 2. Monitoring (PPS 12: Test of Effectiveness) 10. Are clear targets able to be identified?

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Key Findings / Evidence Option 1 Option 2 Comments

11. Can you measure and If approved by Ofwat progress can be monitor outcomes? monitored

HRA (The Habitats Regulation Test) 12. Does the option generate The facility is Hastings an adverse effect on the to be extended under integrity of a European site or Option 1 is remote European offshore marine site? from any European sites and is unlikely to generate an adverse effect. The proposed location of the energy from waste facility is unknown and therefore it is not possible to judge the effects of option 2. 13. Can adequate mitigation Planning permission measures be put in place to and environmental address significant effects? permits are unlikely to be granted without adequate mitigation. The options proposed are tried and tested solutions. SA/SEA (The Sustainability Appraisal Test) 14. Do the outcomes of SA/SEA The outcome of the suggest the option is SA/SEA does not sustainable? identify any significant adverse effects associated with either of the options. Due to the level of detail available at this stage there is uncertainty over the effects of the options. The SA/SEA did not identify a Preferred Option. Community Engagement Test (evidence of participation – the Justifiable Test (robust and credible evidence base)) 15. Do the responses to Issues n/a and Options Consultation suggest the option is supported? 16. Do the responses to the n/a Options Testing Dialogue Meetings suggest the option is supported? Research findings (evidence of fact finding – the Justifiable Test (robust and credible evidence base)) 17. Do the findings of Technical An assessment has been undertaken Studies/Research support the of sludge treatment capacities, which option? (Include relevant studies has examined capacity (volumetric and to the issue being considered, process) and environmental capacity. not all studies will be relevant) Further work is needed in order to identify a preferred option. Overall Assessment CONCLUSION Further work required to identify a preferred option

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Key Findings / Evidence Option 1 Option 2 Comments

Consistency: All options conform

Deliverability: All options subject to funding and Southern Water will approval ultimately be responsible for delivery, although approval would be needed from key stakeholders Flexibility: All options deliverable Disposal of the ash by-product under Option 2 will need to be considered to ensure that alternative means of disposal are found if landfill becomes unavailable as a disposal option. Monitoring: All options can be monitored Via Ofwat progress

HRA: No significant adverse effects No effects are anticipated as both options propose anticipated under tried and tested solutions and the Option 1. As the planning and permitting system will location is not known ensure effects are managed. for Option 2 it has not been possible to judge the effects. SA: Due to the level of detail available at this stage there is uncertainty over the effects of the options. No Preferred Option was identified. Community Engagement: No consultation carried out at this stage but information was sought from industry that informed this study.

5.16 At this preliminary stage it is not possible to fully assess the two options to determine the preferred option. It is therefore recommended that for sewage sludge treatment and disposal, the preferred option should be a general policy identifying the need for extra capacity in the area. The policy should also include criteria to be used in identifying potential locations for the location of new capacity as well as key environmental constraints to be considered.

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6 Preferred Spatial Strategy

6.1 As per our tender brief of March 2009, we have carried out a spatial assessment of the options. It was not the aim of this study, and it is not possible at this stage in the assessment, to identify individual sites that may be suitable for the location of either a new WwTW or a pathway for a new outfall, but we have been able to provide broad locations that could be considered further. As mentioned above in section 5.2, it is strongly recommended that specific site identification be carried out in conjunction with SWS, in order that a preferred option can be identified that is acceptable to all parties. The upcoming Waste and Minerals Development Plan Document (DPD) will also provide further details of potential site allocation for waste sites and reference should be made to this document. Work will commence on the Waste DPD in 2010, with the content guided by the Core Strategy.

6.2 In assessing broad location for the two possible preferred options, we have taken the following factors into consideration:

• proximity to Hailsham and location of exiting infrastructure (only sites within a maximum distance of 10 km from Hailsham have been considered due to economic constraints i.e. pumping over larger distances would not be economically viable); • the required discharge location (only sites within a maximum distance of 1 km from the River Cuckmere have been considered); • impacts of a new sewage works on residential properties (a 400 m buffer has been placed around existing urban areas to prevent odour nuisance) (Reference 13); • impacts of infrastructure and construction on designated conservation sites; and • location of flood zones (PPS25 states that while sewage transmission infrastructure and pumping stations may be located in all flood zones, sewage treatment plants may not be sited in flood zone 3b, the ‘functional floodplain’).

6.3 Please note, this should not be taken to be an exhaustive list of relevant factors to be considered during the more detailed assessment process, but it is felt that these are appropriate for consideration at this preliminary stage. See Figure 9 in Appendix E for the Potential Preferred Spatial options, showing broad locations that may be suitable for the location of Options 1 and 2.

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7 References

• Reference 1: UK Technical Advisory Group on the Water Framework Directive, Recommendations on Surface Water Classification Schemes for the purposes of the Water Framework Directive, December 2007. • Reference 2: Defra website, www.defra.gov.uk/environment/water/quality/fwfish • Reference 3: Defra website, www.defra,gov.uk/environment/water/quality/uwwtd/default.htm • Reference 4: Defra website, www.defra.gov.uk/environment/water/quality/shellfish • Reference 5: Defra website, www.defra.gov.uk/environment/water/quality/bathing/default/htm • Reference 6: Shoreham Harbour Regeneration & Adur District Council Water Cycle Strategy – Outline Report (Draft for Comment), Halcrow Group Limited for SEEDA, April 2009. • Reference 7: Southern Water Corporate Strategy, Chris Kneale, May 2007. • Reference 8: Southeast Draft River Basin Management Plan, Environment Agency 2008 • Reference 9: Thames Draft River Basin Management Plan, Environment Agency 2008 • Reference 10: Kent River Basin Management Plans, Environment Agency 2008 • Reference 11: Creating a Better Place, Planning for Water Quality and Growth in the South East, Environment Agency 2006. • Reference 12: Natural England website, www.natureonthemap.org.uk • Reference 13: Integrated Pollution Prevention and Control, draft Horizontal Guidance for Odour, Part 2 – Assessment and Control, Environment Agency, Scottish Environmental protection Agency, Environment and Heritage Service, July 2006. • Reference 14: East Sussex and Brighton and Hove Council, LDF: Waste and Minerals Core Strategy – Preferred Options Process Framework, Scott Wilson Group, February 2009.

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8 Appendix A – Statutory Standards

Bathing Water Standards

Table 8.1 Existing Bathing Water Directive Standards Minimum Microbiological sampling Method of analysis and parameters G I frequency inspection 1 Total coliforms/100 ml 500 10 000 Fortnightly (1) Fermentation in multiple tubes. Subculturing of the positive tubes 2 Faecal coliforms/100 ml 100 2 000 Fortnightly (1) on a confirmation medium. Count according to MPN (most probable number) or membrane filtration and culture on an appropriate medium such as Tergitol lactose agar, endo-agar, 0.4% Teepol broth, subculturing and identification of the suspect colonies. In the case of 1 and 2, the incubation temperature is variable according to whether total or faecal coliforms are being investigated. 3 Faecal streptococci/100 ml 100 - (2) Litsky method. Count according to MPN (most probable number) or filtration on membrane. Culture on an appropriate medium. 4 Salmonella/litre - 0 (2) Concentration by membrane filtration. Inoculation on a standard medium. Enrichment - subculturing on isolating agar - identification 5 Enteroviruses PFU/10 litres - 0 (2) Concentrating by filtration flocculation or centrifuging and confirmation

Minimum Physico-chemical sampling Method of analysis and parameters G I frequency inspection 6 pH - 6-9 (0) (2) Electrometry with calibration at pH 7 and 9. 7 Colour - No abnormal Fortnightly (1) (2) Visual inspection or photometry change in colour with standards on the Pt.Co scale. (0) 8 Mineral oils mg/litre ≤ 0.3 No film visible on Fortnightly (1) (2) Visual and olfactory inspection or the surface of the extraction using an adequate water and no volume and weighing the dry odour residue. 9 Surface-active substances reacting ≤ 0.3 No lasting foam Fortnightly (1) (2) Visual inspection or absorption with methylene blue mg/l (Lauryl spectro-photometry with methylene sulphate) blue. 10 ≤ No specific odour Fortnightly (1) (2) Verification of the absence of Phenols mg/l (phenol indices) C 6 0.005 specific odour due to phenol or H OH 5 ≤ 0.05 absorption spectro-photometry 4- aminoantipyrine (4 A.A.P.) method. 11 Transparency 2 1 (0) Fortnightly (1) Secchi's disc. 12 80 to 120 - (2) Winkler's method or electrometric Dissolved oxygen % saturation O 2 method (oxygen meter).

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13 Tarry residues and floating Absence - Fortnightly (1) Visual inspection. materials such as wood, plastic articles, bottles, containers of glass, plastic, rubber or any other substance. Waste or splinters 14 (3) Absorption spectrophotometry, Ammonia mg/litre NH 4 - - Nessler's method, or indophenol blue method. 15 Nitrogen Kjeldahl mg/litre N - - (3) Kjeldahl method.

Other substances Minimum regarded as indications sampling Method of analysis and of pollution G I frequency inspection 16 Pesticides mg/litre (parathion, - - (2) Extraction with appropriate HCH, dieldrin) solvents and chromatographic determination. 17 Heavy metals such as: arsenic - - (2) Atomic absorption possibly mg/litre As cadmium Cd chrome preceded by extraction. VICr VI leadPb mercury Hg 18 Cyanides mg/litre Cn - - (2) Absorption spectrophotometry using a specific reagent. 19 (2) Absorption spectrophotometry Nitrates mg/litre NO 3 and - - using a specific reagent . phosphates PO 4

G = guide, I = mandatory

(0) Provision exists for exceeding the limits in the event of exceptional geographical or meteorological conditions.

(1) When a sampling taken in previous years produced results which are appreciably better than those in this Annex and when no new factor likely to lower the quality of the water has appeared, the competent authorities may reduce the sampling frequency by a factor of 2.

(2) Concentration to be checked by the competent authorities when an inspection in the bathing area shows that the substance may be present or that the quality of the water has deteriorated.

(3) These parameters must be checked by the competent authorities when there is a tendency towards eutrophication of the water.

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Table 8.2 New faecal bathing water standards

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9 Appendix B – SWS information

SWS Sludge Treatment Position Statement

The Company’s original sludge strategy was developed in the mid-1990s to ensure a co-ordinated approach to the then current and future treatment, disposal and recycling of sludge. The strategy has enabled a professional approach to sludge that has seen greater levels of treatment, inclusion of process controls, greater complexity of plant and the use of higher qualified operators and agricultural advisors. The strategy is dynamic and developed in line with legislation, product market requirements and the need for business efficiency and the management of risk to the business. Currently, Southern Water operates 18 sludge treatment centres and produces both conventionally (99% reduction in bacteria levels) and enhanced (99.9999% reduction in bacteria levels) treated products with the aim of recycling all biosolids to agricultural land. The treatment processes used are enzymic hydrolysis, mesophillic anaerobic digestion, drying and lime treatment. Lime treatment is used as a fall-back process when the preferred anaerobic digestion treatment is unavailable due to maintenance activities or plant failure. The production of an enhanced treated product (dried digested granules) has historically been driven by restrictions relating to planning approval, normally associated with the number of vehicle movements. However, latterly the need to secure and maintain the agricultural route has led to investment in drier technology. The treated sludge, biosolids, are recognised for their fertiliser and soil conditioning properties and sold to farmers for use on agricultural land. Southern Water has, for a considerable number of years, had sole reliance upon the agricultural land bank for the recycling of biosolids; this is relatively unique in the water industry. In addition to the sludge treatment centres there are a number of sites operating as sludge thickening centres either solely for indigenous sludge (sites serving large populations e.g. Eastbourne) or centrally located sites thickening imported sludges prior to transfer to the sludge treatment centres (e.g. Hailsham). Our long term strategy recognises that we will need to be flexible in our response to proposed future legislation and that changes to the way that we manage and recycle sludge need to be introduced in a phased manner. In developing our sludge strategy for the next 5 years and beyond, we have taken account of, ♦ Quantities of sludge arising from the environmental enhancement programmes and from future population growth; ♦ Current and proposed future applicable legislation; ♦ Risks and opportunities associated with different sludge recycling routes; ♦ Climate change and our carbon footprint; and ♦ Costs and benefits to customers.

Our current strategy relies upon the utilisation of agricultural land for all of our treated biosolids. It is recognised that this means of recycling is, in the majority of cases, considered as the Best Practicable Environmental Option (BPEO). Whilst we recognise this and fully support all endeavours to maintain the availability of the agricultural outlet we are experiencing increasing difficulties in securing adequate land bank at suitable distances from our biosolids producing sites. We have observed, over the years, greater distances travelled to available agricultural land.

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In addition to this increase in distance travelled to suitable agricultural land, we are also witnessing an increase of restrictive clauses within the contacts issued by the grain purchasing companies to farmers. These clauses are restricting or preventing the use of treated biosolids on agricultural land With the proven need to diversify from the sole reliance on the agricultural land bank, the obvious process, based upon a proven track record and having sustainability, is that relating to thermal destruction. Our proposed sludge strategy for the future comprises a balance of recycling to agriculture, and utilisation of thermal destruction as a final treatment option. We have, over the last two years, investigated the most suitable approach for the move towards thermal destruction as an alternative means of utilising sludge and biosolids.

The Government’s policy (Waste Strategy for England 2007) for waste recycling and target setting to local councils has recognised the volume of waste food entering the solid waste stream and suggests the preferred recycling route for this waste should be anaerobic digestion. Currently our sludge strategy is based upon an insular approach of dealing with indigenous products only. However, recognising the needs of others and the benefits of a common approach and the ease/benefits of co-digestion, we are investigating broadening our approach.

We have long since recognised the benefits of biogas utilisation for the production of electricity. We operate a number of combined heat and power (CHP) units across the region and generate sufficient electricity to meet 10% of our requirements.

In the East Sussex CC area we operate one sludge treatment centre - Hastings, which produces an enhanced treated product, dried granules. In addition to Hastings, we also operate Hailsham as a thickening centre. Whist we adhere to the proximity principle we transport sludge cross the County boundary to ensure that treatment is achieved, for example sludge arising from sites close to the boundary with Kent or West Sussex will be transported to sludge treatment centres in these counties as it is considered the most sensible operating practice. Some of these cross boundary movements can be prevented if the full capacity at the Hastings treatment centre could be utilised, currently this is not possible due to restrictive planning conditions imposed upon the site.

We have recently gained planning permission for the construction of the treatment works to serve the Brighton and Hove conurbation. The treatment works will include a sludge treatment centre that will treat indigenous sludge and imports from the Newhaven treatment works. The treatment process will produce an enhanced treated product, dried granules.

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PR09 and NEP Schemes

WwTW PR09 NEP Both

Alfriston Environment Agency prepared to  increase consented DWF, no other consent changes Battle WFD - P WFD2 - P consent of 1mg/l by 22 Dec  2012 Brede, Stubbs Lane P WFD2 - P consent of 1mg/l by 22 Dec  2012

Brighton, Portobello UWWTD scheme  Crowborough, Redgate Mill UWWTD P Scheme U2 - P consent of 2mg/l by 30 Sept  2014 under UWWTD Crowborough, St Johns Environment Agency prepared to  increase consented DWF, no other consent changes East Dean Groundwater G1 G1 - Prevent pollution to groundwater to  ensure no harm to receptors (including groundwater itself) and no failure of status. Proposed consents of BOD 40mg/l and Ammonia 5 mg/l (Mean) by 22 Dec 2012 Fletching Descriptive to Numeric Consent FLOW1 - Proposed consents of 55 m 3/d  DWF and 40 mg/l BOD by 31 Mar 2015 Hailsham North New discharge location study I5 - Investigations agreed by the  conservation agencies and the Environment Agency to assess the impact of water company assets on the requirements of the CROW Act. Pevensey Levels Investigation into performance of AMP4 scheme and if any further treatment beyond BAT is needed to mitigate P impact on SSSI. By 31 March 2012 Hailsham South New discharge location study I5 - Investigations agreed by the  conservation agencies and the Environment Agency to assess the impact of water company assets on the requirements of the CROW Act. Pevensey Levels Investigation into performance of AMP4 scheme and if any further treatment beyond BAT is needed to mitigate P impact on SSSI. By 31 March 2012 Halland DWF Consent Review FLOW1 - Proposed consents of  183m 3/d DWF and Winter Ammonia consent of 8 mg/l by 31 Mar 2015 Lunsfords Cross DWF Consent Review FLOW1 - Proposed consents of 59 m 3/d  DWF, 20 mg/l BOD and 12 mg/l Ammonia by 31 Mar 2015 Newhaven East/Newhaven New Environment Agency prepared to  increase consented DWF, no other consent changes

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WwTW PR09 NEP Both

Offham Groundwater G1 G1 - Prevent pollution to groundwater to  ensure no harm to receptors (including groundwater itself) and no failure of status. Proposed consent of 15 m 3/d DWF, 40 mg/l BOD and 5 (Mean) mg/l Ammonia by 22 Dec 2012 Ripe DWF Consent Review FLOW1- Proposed consent of 53 m 3/d  DWF and 16 mg/l Ammonia by 31 Mar 2015 Sedlescombe WFD - P WFD2 - Proposed P consent of 1 mg/l  by 22 Dec 2012 Streat Groundwater G1 G1 - Prevent pollution to groundwater to  ensure no harm to receptors (including groundwater itself) and no failure of status. No discharge consent exists at present. Consent conditions required relating to preventing direct discharge to groundwater under certain conditions. Present investigation has not identified need for specific quality limits. Proposed consent of 50 m 3/d DWF, 40 mg/l BOD and 5 mg/l (Mean) Ammonia by 22 Dec 2012 Vines Cross UWWTD P scheme U2 - Proposed P consent of 2 mg/l by  30 Sept 2014 under UWWTD Wadhurst, Washwell Lane WFD - Ammonia WFD1 - Proposed Ammonia consent of  3 mg/l by 22 Dec 2012. C1a - Investigation - Screening for PS, PHS, BLM, Sanitary, GC-MS scan, Emerging chemicals - 25 spot samples of effluent at random times by 31 July 2011 Westfield DWF Consent Review & WFD - P FLOW1 - Proposed consent of 362 m 3/d  DWF, 7 mg/l BOD and 3 mg/l Ammonia by 31 Mar 2015 WFD2 - Proposed P consent of 1 mg/l 22 Dec 2012 Winchelsea, Beach WFD - P WFD2 - Proposed P consent of 1 mg/l  by 22 Dec 2012 Winchelsea, Ferry Hill WFD - P WFD2 - Proposed P consent of 2 mg/l  by 22 Dec 2012 Wivelsfield DWF Consent Review & WFD - P FLOW1 - Proposed consent of 405 m 3/d  DWF, 30 mg/l BOD and 7 mg/l Ammonia 31 Mar 2015 WFD2 - Proposed P consent of 1 mg/l by 22 Dec 2012

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10 Appendix C – Wastewater Calculations

WwTW Volumetric Capacity Assessment DWF Current (2006/2009) Future (2026) Consent DWF Capacity Dwelling DWF Capacity Dwelling WwTW (m3/d) (m3/d) (%) (Hh) (m3/d) (%) (Hh) Alfriston 197 268 -36% -150 294 -49% -190 Barcombe Church 4 4 Barcombe New 623 493 21% 260 518 17% 210 Battle 1,493 960 36% 1,060 1,222 18% 540 Beckley 197 103 48% 180 139 29% 115 Berwick 193 68 65% 250 79 59% 230 Bexhill And Hastings 33,869 30,740 9% 6,250 34,236 -1% -735 Blackboys 235 152 35% 160 236 -1% -5 Blackham 75 35 53% 80 47 37% 55 Bodiam, Levetts Lane 20 11 43% 10 26 -30% -10 Bodle Street Green 22 26 Brede, Stubbs Lane 240 235 Brede Waterworks 339 4 99% 670 3 99% 670 Brighton, Portobello 76,205 68,577 10% 15,255 75,424 1% 1,560 Burwash Common 150 98 35% 100 129 14% 40 Burwash Village 525 271 48% 500 359 32% 330 Buxted 489 270 45% 430 322 34% 335 Camber 1,163 589 49% 1,140 677 42% 970 Catsfield 188 68 64% 240 88 53% 200 Chailey 6 7 Cooksbridge 91 76 16% 20 96 -5% -10 Crowborough, Redgate Mill 5,802 4,345 25% 2,910 5,329 8% 945 Crowborough, St Johns 615 759 -23% -290 778 -27% -325 Danehill 267 239 10% 50 285 -7% -35 Ditchling 300 222 26% 150 250 17% 100 East Chiltington, Highbridge 4 4 East Chiltington, Hollycroft 17 20 East Dean 340 250 26% 180 211 38% 260 East Hoathly 244 105 57% 270 166 32% 155 Eastbourne 34,733 26,424 24% 16,610 27,533 21% 14,400 Ewhurst Green 5 8 Fairlight 375 308 18% 130 379 -1% -10 Firle, Stamford Buildings 6 10 Fletching 53 69 Forest Row 1,508 802 47% 1,410 1,003 33% 1010 Frant 133 83 38% 100 87 35% 90 Guestling Green 214 164 23% 100 217 -1% -5 Hailsham North 3,162 1,680 47% 2,960 3,706 -17% -1,090 Hailsham South 7,120 5,890 17% 2,460 8,644 -21% -3,045 Halland 133 166 -25% -70 182 -37% -100 Hamsey 6 8 Hartfield 235 157 33% 150 168 29% 135 Herstmonceux, Windmill Hill 475 310 35% 330 428 10% 95 Herstmonceux, Lime Park 12 18 High Hurstwood 31 34 Hooe 327 228 30% 190 282 14% 90 Hurst Green 420 344 18% 150 359 15% 120 Icklesham 266 147 45% 230 144 46% 245 Iden 434 349 20% 170 431 1% 5 Kingston Hollow 216 162 25% 100 187 13% 55 Lunsfords Cross 46 54 -18% -20 60 -31% -30 Maresfield 359 203 43% 310 274 24% 170 Mayfield, Crouch Farm 158 153 3% 9 173 -9% -30 Mayfield, Meres Farm 620 277 55% 680 306 51% 625

Wastewater Management Study October 2009 58 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WwTW Volumetric Capacity Assessment DWF Current (2006/2009) Future (2026) Consent DWF Capacity Dwelling DWF Capacity Dwelling WwTW (m3/d) (m3/d) (%) (Hh) (m3/d) (%) (Hh) Netherfield 75 56 25% 30 37 51% 75 Newhaven East 12,787 12,728 0% 110 14,300 -12% -3025 Newick 1,182 989 16% 380 1,062 10% 240 Northiam, Mill Corner 20 19 5% 2 32 -61% -25 Northiam, Quickbourne Lane 423 297 30% 250 416 2% 15 Nutley 196 158 20% 70 185 6% 20 Offham 8 13 -62% -10 16 -100% -15 Plumpton 55 28 50% 50 81 -48% -55 Ringmer, Neaves Lane 959 885 8% 140 1,055 -10% -190 Ringmer, Smallholdings 9 14 Ripe 42 48 -14% -20 50 -19% -15 Robertsbridge 579 490 15% 170 541 6% 75 Rodmell 88 50 43% 70 50 43% 75 Rye 1,696 1,446 15% 500 1,800 -6% -210 Sedlescombe 209 163 22% 90 204 2% 10 Shoreham 13,000 11,000 15% 4,000 16,000 -23% -6,000 Staplecross 119 78 34% 80 112 6% 15 Stonegate 26 39 Streat 6 7 Ticehurst 545 395 28% 300 527 3% 35 Uckfield 5,000 3,361 33% 3,270 4,256 15% 1,485 Udimore 14 16 Vines Cross 2,986 2,169 27% 1,630 2,546 15% 880 Wallcrouch 198 238 Wartling 15 16 Wadhurst Washwell Lane 136 89 34% 90 129 5% 15 Wadhurst Whitegates Lane 1,092 530 51% 1,120 596 45% 990 Westfield 308 305 1% 6 368 -19% -120 Westmeston 7 8 Whatlington 20 26 Wilmington 23 26 832 390 53% 880 446 46% 770 Winchelsea, Ferry Hill 205 78 62% 250 121 41% 165 Wivelsfield 318 260 18% 110 307 4% 25

Key Compliant with consent Consent pass <10% Consent failure >10% No Measured Flow Available – Calculated DWF Used Instead Not Assessed – No DWF Consent

Wastewater Management Study October 2009 59 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WwTW Consents WwTW BOD NH3 SS P DWF Others (ug/l) Receiving Water (mg/l) (mg/l) (mg/l) (mg/l) (m 3/d) Alfriston 40 20 60 197 Cuckmere River Barcombe_New 56 40 623 Bevern Stream Battle S10/40 S3/6 S20 1493 Trib Of The River W15/50 W6/23 W30 Brede Beckley 10 3 20 197 The Knelle Petty Sewer Berwick 25 50 193 River Cuckmere Bexhill And Hastings /150 33869 Lead 75 Copper English Channel 125 Zinc 700 Cadmium 1 Chromium 25 Blackboys 25 10 40 235 Tickerage Stream Blackham 25 35 75 Tributary Of The River Medway Bodiam_Levetts_Lane 30 40 20 Tributary Of River Rother Bodle_Street Descriptive Tributary Of consent Christians River Brede_Stubbs_Lane S15 W20 S5 W10 S25 339 Tributary Of River W30 Brede Brede_Waterworks Descriptive River Brede consent Brighton_Portobello /150 76205 Lead 175 English Channel Mecury 1.4 Cadmium 1.7 HCH Gamma .33 Dieldrin 0.04 Endosulphate 20 TriBT Cati .1 Chromium 40 Chloroform 9 Iron 10000 Copper 95 Zinc 300 Nickel 50 Trichloroethylene 10 Burwash_Common 25 10 40 150 River Dudwell Burwash_Village 20 S4 W8 30 525 Trib Of The River Rother Buxted 20 10 40 489 River Uck Camber 40/80 60 1163 Jury'S Gut Sluice Tidal Basin Catsfield 15 30 188 Freshwater Stream Or River Chailey_Roeheath Descriptive Longford Stream consent Cooksbridge 25 12 35 91 Freshwater Stream Or River Crowborough_Redgate_Mill S10/20 S3/6 S20/50 5802 The River Medway W20/40 W10/20 W30/75 Crowborough_St_Johns S20/56 4 S/30 615 Pippingford Brook W20/56 W/30 Danehill S15/30 S5/10 S25/62 267 Unnamed Trib Of W20/40 W10/20 W30/75 River Ouse Ditchling 20 10 40 300 Tributary Of Bevern Stream E_Chiltington_Highbridge Descriptive Bevern Bridge consent Stream E_Chiltington_Hollycroft Descriptive Plumpton Mill

Wastewater Management Study October 2009 60 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WwTW Consents WwTW BOD NH3 SS P DWF Others (ug/l) Receiving Water (mg/l) (mg/l) (mg/l) (mg/l) (m 3/d) consent Stream East_Dean Descriptive 340 Into Land/Soakaway consent East_Hoathly 20 10 30 244 Trib Of Glynde Reach Eastbourne_Langney_Point /150 34733 Iron 7000 English Channel Ewhurst_Green Descriptive Trib Of The River consent Rother Fairlight 20 10 30 1 375 Iron 4000 Tributary Of Mean Marsham Sewer 5 Max Firle Descriptive Tributary Of Glynde consent Reach Fletching Descriptive Tributary Of River consent Ouse Forest_Row 10/50 5/20 15 1508 Silver 1.5 River Medway Frant 20/40 10 30/75 133 The River Teise Guestling 15 10 30 2 214 Iron 4000 The Pannel Sewer mean 5 max Hailsham_North 7/25 2/8 10 Mean 3162 Iron 1500 The Hurst Haven 1 Hailsham_South 7/25 2/8 10 Mean 7120 Iron 1500 The Horse Eye 1 Sewer Halland S15 S5 S20 133 Ridgewood Stream W20 W30 Hamsey Descriptive River Ouse consent Hartfield 40 15 60 235 Tributary Of The River Medway Haywards_Heath_Foxhill 20 10 30 105 River Adur Herstmonceux_Lime_Park Descriptive Unnamed Trib Of consent Iron Stream High_Hurstwood Descriptive Tributary Of The consent River Uck Hooe 25 40 327 Freshwater Stream Or River Hurst_Green 10 S3 W7 20 420 Tributary Of River Rother Icklesham 15 30 266 Unnamed Trib Of River Brede Iden_And_Playden 35 7 52 1 434 Iron 4000 River Rother Mean 5 Max Kingston_Hollow 10 25 216 Celery Sewer Trib.R. Ouse Maresfield 20 10 40 359 Shortbridge Stream Mayfield_Crouch 14 10 21 158 The Coggins Mill Stream Mayfield_Meres 25/60 40 620 River Rother Netherfield_Darvell_Down 25 60 75 Freshwater Stream Newhaven_(East) 400 300 1460 Lead 500 Saline Estuary Cadmium 50 Nickel 600 Copper 400 Zinc 800 Chromium 75 Newhaven_New /150 12787 English Channel

Wastewater Management Study October 2009 61 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WwTW Consents WwTW BOD NH3 SS P DWF Others (ug/l) Receiving Water (mg/l) (mg/l) (mg/l) (mg/l) (m 3/d) Newick 80 60 1182 River Ouse Ninfield_Lunsford_Cross 25 40 46 Unnamed Trib Of East Stream Northiam_Mill_Corner Descriptive 20 Tributary Of River consent Rother Northiam_Quickbourne_Lane 15 5/10 30 423 The Goddens Gill Nutley 15 5 25 196 Pippingford Brook Offham Descriptive 8 Underground Strata consent Plumpton_Agri_College 50 80 55 Unnamed Trib Of Bevern Stream Ringmer_Neaves_Lane 15/30 S5/10 30 959 Bulldog Sewer / W10/20 Glynde Reach Ringmer_Small_Holdings Descriptive Norlington Stream consent Ripe 40 60 42 Unnamed Trib.Glynde Reach/Ouse Robertsbridge 13/50 4/12 30 579 Tributary Of River Rother Rodmell 40 20 60 88 Ditch Leading To River Ouse Rye 80/160 120 1180 The River Rother Sedlescombe 40 60 209 The River Brede Shoreham Not Provided English Channel Staplecross S10 W15 S3/6 S20 119 The River Tillingham W8/30 W30 Stonegate Descriptive Tributary Of River consent Rother Ticehurst 15/50 30 545 The Devilsden Stream Uckfield S10 W15 S5 W10 S15 5000 Ridgewood Stream W25 Udimore Descriptive Freshwater Stream consent Vines_Cross 30/64 15/44 60 2986 Waldron Ghyll Wadhurst_Washwell_Lane 15 30 136 Unnamed Trib Of Tide Brook Wadhurst_Whitegates S20/56 W40 1092 Trib Of River Teise W30/64 S30 Wallcrouch Descriptive Freshwater Streamr consent Wartling Descriptive Kentland Fleet consent Westfield S10/20 S5/10 S15/37 308 Tributary Of River W15/30 W10/20 W25/62 Brede Westmeston_Middletn_Manor Descriptive Freshwater Stream r consent Whatlington Descriptive Tributary Of River consent Line Wilmington Descriptive Tributary Of River consent Cuckmere Winchelsea_Beach 30/64 12/41 45 832 The River Brede Winchelsea_Ferry_Hill 30 60 205 Tributary Of River Brede Windmill_Hill 15/50 10/25 30 475 Freshwater Stream r Wivelsfield 40 60 318 River Adur East

Wastewater Management Study October 2009 62 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

Water Quality Assessment (WFD) WwTW Receiving Watercourse WB Overall Eco Chem PR09/NEP Status Status Status Measure Proposed Alfriston Cuckmere River GB107041012930 N/A N/A N/A  Barcombe Church Barcombe New Bevern Stream GB107041012570 M M N/A

(P) Battle Trib Of The River Brede GB107041012550 G G N/A  Beckley The Knelle Petty Sewer GB107040013640 M M Not cHMWB (P) Good Berwick River Cuckmere GB30745429 N/A N/A G cA Bexhill And Hastings English Channel GB640704540002 M M G cHMWB Blackboys Tickerage Stream GB107041012970 M M N/A

(P) Blackham Tributary Of The River GB106040018090 G G N/A

Medway Bodiam, Levetts Lane Tributary Of River Rother GB107040013590 M M Not

(Inv) Good Bodle Street Green Tributary Of Christians GB107041012610 M M G

River (DO/P) Brede, Stubbs Lane Tributary Of River Brede GB107040013550 P P G (DO/P/  Fish/Inv) Brede Waterworks River Brede GB107040013550 P P G (DO/P/ Fish/Inv) Brighton, Portobello English Channel GB640704540003 M M N/A  Burwash Common River Dudwell GB107040013570 G G N/A Burwash Village Trib Of The River Rother GB107040013590 M M Not

(Inv) Good Buxted River Uck GB107041012990 G G N/A Camber Jury'S Gut Sluice Tidal GB10704001340 M M N/A Basin (DO/P/ cA Fish) Catsfield Freshwater Stream Or GB107041012540 M M N/A

River (P) Chailey Longford Stream GB107041012960 P P N/A

(Inv) Cooksbridge Freshwater Stream Or GB107041012530 M M N/A River (Amm/ DO/P) Crowborough, Redgate Mill The River Medway GB106040013360 M M N/A  (P) Crowborough, St Johns Pippingford Brook GB106040013360 M M N/A  (P) Danehill Unnamed Trib Of River GB107041013000 M M N/A

Ouse (P) Ditchling Tributary Of Bevern GB107041012570 M M N/A

Stream (P) East Chiltington, Highbridge Bevern Bridge Stream GB107041012570 M M N/A

(P) East Chiltington, Hollycroft Plumpton Mill Stream GB107041012570 M M N/A

(P) East Dean Into Land/Soakaway GB107041012330 N/A N/A Not  (P/ Fish) Good Groundwa ter G1 Measure – discharges to Seaford

Wastewater Management Study October 2009 63 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

Water Quality Assessment (WFD) WwTW Receiving Watercourse WB Overall Eco Chem PR09/NEP Status Status Status Measure Proposed and Eastbourn e Chalk GWB cHMWB East Hoathly Trib Of Glynde Reach GB107041012380 G G N/A Eastbourne English Channel GB107041006650 M M N/A cHMWB (DO/P) Ewhurst Green Trib Of The River Rother GB107040013640 M M Not cHMWB (P) Good Fairlight Tributary Of Marsham GB107040013390 P P N/A

Sewer (P/Inv) Firle, Stamford Buildings Tributary Of Glynde Reach GB107041012510 B B Not

(Fish) Good Fletching Tributary Of River Ouse GB107041012710 M M N/A  (P) Forest Row River Medway GB1060410018070 M M G cHMWB (P/Fish) Frant The River Teise GB106040018500 N/A N/A G cHMWB Guestling Green The Pannel Sewer GB107040013390 P P N/A

(P/Inv) Hailsham North The Hurst Haven GB107041012500 M M G (DO/P/  Iron/ cHMWB Fish) Hailsham South The Horse Eye Sewer GB107041012420 M M G  (P/Inv) cHMWB Halland Ridgewood Stream GB107041012630 M M N/A  (P/Inv) Hamsey River Ouse GB107041012530 M M N/A (Amm/ DO/P) Hartfield Tributary Of The River GB1060410018070 M M G cHMWB Medway (P/Fish) Herstmonceux, Windmill Hill Freshwater Stream Or GB107041012610 M M G

River (DO/P) Herstmonceux, Lime Park Unnamed Trib Of Iron GB107041012500 M M G Stream (DO/P/ cHMWB Iron/ Fish) High Hurstwood Tributary Of The River Uck GB107041012990 G G N/A Hooe Freshwater Stream Or GB107041012430 N/A N/A N/A River (DO/P/ cHMWB Inv) Hurst Green Tributary Of River Rother GB107040013640 M M Not cHMWB (P) Good Icklesham Unnamed Trib Of River GB107040013550 P P G Brede (DO/P/ Fish/Inv) Iden River Rother GB107040013640 M M Not cHMWB (P) Good Kingston Hollow Celery Sewer Trib.R. Ouse GB107041013080 N/A N/A N/A cHMWB Lunsfords Cross Unnamed Trib Of East GB107041012430 N/A N/A N/A  Stream (DO/P/ cHMWB Inv) Maresfield Shortbridge Stream GB107041012980 M M N/A

(P)

Wastewater Management Study October 2009 64 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

Water Quality Assessment (WFD) WwTW Receiving Watercourse WB Overall Eco Chem PR09/NEP Status Status Status Measure Proposed Mayfield, Crouch Farm The Coggins Mill Stream GB107040013500 M M N/A

(DO/P) Mayfield, Meres Farm River Rother GB107040013490 M M N/A

(P) Netherfield Freshwater Stream Or GB107041012620 G G N/A

River Newhaven East/Newhaven Saline Estuary/English GB107041012510 B B Not  New Channel (Fish) Good GB540704104900 M M G cHMWB Newick River Ouse GB107041012710 M M N/A

(P) Northiam, Mill Corner Tributary Of River Rother GB30745011 N/A N/A N/A cA

Northiam, Quickbourne Lane The Goddens Gill GB107040013640 M M Not cHMWB (P) Good Nutley Pippingford Brook GB107041012980 M M N/A

(P) Offham Underground Strata GB107041012530 M M N/A  (Amm/ Groundwa DO/P) ter G1 Measure – discharges to Brighton and Hove Chalk GWB Plumpton Unnamed Trib Of Bevern GB107041012570 M M N/A

Stream (P) Ringmer, Neaves Lane Bulldog Sewer / Glynde GB107041012510 B B Not

Reach (Fish) Good Ringmer, Smallholdings Norlington Stream GB107041012510 B B Not

(Fish) Good Ripe Unnamed Trib.Glynde GB107041012510 B B Not  Reach/Ouse (Fish) Good Robertsbridge Tributary Of River Rother GB107040013640 M M Not cHMWB (P) Good Rodmell Ditch Leading To River GB540704104900 M M G cHMWB Ouse Rye The River Rother GB30745035 N/A N/A N/A cA Sedlescombe The River Brede GB107040013550 P P G (DO/P/  Fish/Inv) Shoreham English Channel GB640704540003 M M N/A Staplecross The River Tillingham GB30745011 N/A N/A N/A cA

Stonegate Tributary Of River Rother GB107040013590 M M Not

(Inv) Good Streat  Groundwa ter G1 Discharge s to Surface Water Stream and Lower Greensan d Adur

Wastewater Management Study October 2009 65 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

Water Quality Assessment (WFD) WwTW Receiving Watercourse WB Overall Eco Chem PR09/NEP Status Status Status Measure Proposed and Ouse GWB Ticehurst The Devilsden Stream GB107040013610 M M N/A

(P) Uckfield Ridgewood Stream GB107041012660 M M N/A cHMWB (Inv) Udimore Freshwater Stream Or GB107040013550 P P G River (DO/P/ Fish/Inv) Vines Cross Waldron Ghyll GB107041012390 M M G  (P) Wallcrouch Freshwater Stream Or GB106040018500 N/A N/A G cHMWB River Wartling Kentland Fleet GB107041012460 M M G (DO/P/ cHMWB Fish) Wadhurst Washwell Lane Unnamed Trib Of Tide GB107040013620 M M N/A Brook (Amm/P/  Copper) Wadhurst Whitegates Lane Trib Of River Teise GB106040018500 N/A N/A G cHMWB Westfield Tributary Of River Brede GB107040013380 M M N/A  (P/Fish) Westmeston Freshwater Stream Or GB107041012570 M M N/A

River (P) Whatlington Tributary Of River Line GB107040013540 M M N/A

(P/Inv) Wilmington Tributary Of River GB107041012330 N/A N/A Not cHMWB Cuckmere (P/ Fish) Good Winchelsea, Beach The River Brede GB30745035 N/A N/A N/A  Winchelsea, Ferry Hill Tributary Of River Brede GB107040013550 P P G (DO/P/  Fish/Inv) Wivelsfield River Adur East GB107041012220 P P N/A (DO/P/  Inv) Notes: Green = Capacity i.e. Good WFD status; Light Green = Capacity i.e. Classed as Moderate WFD status only because of P being classed as less than Good Status; Orange = Limited Capacity i.e. Moderate WFD Status; Red = No Capacity i.e. Poor or Bad WFD Status; Grey = No information available for assessment.

Wastewater Management Study October 2009 66 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

11 Appendix D – Environmental Capacity Data

Wastewater Management Study October 2009 67 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WB Type Name Waterbody Current Current Current Elements at Proposed Proposed Justification if Protected Hydromorho Reason WwTW Overall Ecological Chemical Good Status Status Proposed Area logical for Discharging to Status Status Status Chemical Objective(S Objective Objective is not Designation Designation Designati Catchment Status ) (Overall) Good Status by on 2015 Ammonia Dissolved Oxygen Phosphate Zinc Copper pH Iron Fish Invertebrates Transitional River GB107041012930 Moderate Moderate High High High High High High Moder High Good App B RBMP Good Good Freshwater Candidate Flood Cuckmere ate Ecological 2027 Fish Directive Heavily Protection by 2027 Modified Good Chemical by 2015 Coastal Sussex GB640704540003 Moderate Moderate High N/A N/A Good Good Bathing Candidate Coastal Brighton, Ecological Potential Water Heavily protection, Portobello Potential by by 2027 Directive, Modified Fin WwTW, 2027 Nitrates Fisheries Brighton, Directive Shoreham WwTW River River Uck GB107041012990 Good Good High High High High High High Good High N/A N/A Good Good Freshwater High Hurstwood Ecological 2015 Fish Directive WwTW, Buxted by 2015 WwTW River Tickerage GB107041012970 Moderate Moderate High High Moder High High High Good High N/A N/A Good Good Not Blackboys WwTW Stream ate Ecological 2015 Designated by 2015 River River Uck GB107041012660 Moderate Moderate High High Good High High High Moder N/A N/A Good Good Freshwater Candidate Flood Uckfield WwTW ate Ecological Potential Fish Directive Heavily Protection by 2027 by 2027 Modified River Shortbridge GB107041012980 Moderate Moderate High High Moder High High High Good High N/A N/A Good Good Freshwater Not Maresfield Stream ate Ecological 2015 Fish Directive Designated WwTW, Nutley by 2015 WwTW River Sheffield Park GB107041013000 Moderate Moderate Good Good Moder High High High Good Good N/A N/A Good Good Danehill WwTW Stream ate Ecological 2015 Status by 2015 River River Ouse GB107041012710 Moderate Moderate Good High Poor High High High Good Good N/A N/A Good Good Disproportionate Freshwater Not Newick WwTW, Ecological 2027 ly expensive - Fish Directive Designated Fletching WwTW Status by Measure not 2027 worthwhile River Longford GB107041012960 Poor Poor High Good Good High High High Good Poor N/A N/A Good Good N/A Freshwater Not Chailey Roeheath Stream Ecological 2027 Fish Designated WwTW by 2027 Directive, Nitrates Directive River River Adur GB107041012220 Poor Poor High Moder Poor High High High Good Poor N/A N/A Good Good Technically Freshwater Not N/A Wivelsfield East ate Ecological 2027 infeasible - Fish Designated WwTW, by 2027 cause unknown Directive, Haywoods Heath Nitrates Foxhill WwTW Directive River Bevern Stream GB107041012570 Moderate Moderate High Good Poor High High High Good High N/A N/A Good Good Disproportionate Freshwater Not N/A Plumpton Agri Ecological 2027 ly - Measure not Fish Designated college WwTW, by 2027 worthwhile Directive, West Meston Nitrates Middleton Manor Directive WwTW, Ditchling WwTW, E Chiltington Holycroft WwTW, E Chiltington Highbridge WwTW, Barcombe New WwTW, Streat WwTW River North End GB107041012530 Moderate Moderate Moder Moder Poor High High High Good N/A N/A Good Good Disproportionate Nitrates Not N/A Offham WwTW, Stream ate ate Ecological 2027 ly expensive - Directive Designated Hamsey WwTW, by 2027 Measure not Cooksbridge worthwhile WwTW River Ridgewood GB107041012630 Moderate Moderate High Moder Good High High High Good Moder N/A N/A Good Good N/A N/A Not N/A Halland WwTW Stream ate ate Ecological 2027 Designated by 2027 River Ouse (Sussex) GB107041006550 N/A N/A N/A N/A N/A N/A N/A Bathing Not Brighton Water & Designated Portobello WwTW Nitrates Directive River Ouse (Sussex) GB107041013080 N/A N/A N/A N/A N/A N/A N/A N/A Candidate Land Kingston Hollow Heavily Drainage WwTW Modified transitional Ouse GB540704104900 Moderate Moderate High High High High Good Good App B RBMP Good Good Disproportionate Bathing Candidate Navigation Rodmell WwTW, Ecological 2027 ly expensice - Water Heavily Newhaven New Potential by low or uncertain Directive, Modified WwTW 2027, Good benefits Nitrates chemical by Directive 2015

Wastewater Management Study October 2009 68 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WB Type Name Waterbody Current Current Current Elements at Proposed Proposed Justification if Protected Hydromorho Reason WwTW Overall Ecological Chemical Good Status Status Proposed Area logical for Discharging to Status Status Status Chemical Objective(S Objective Objective is not Designation Designation Designati Catchment Status ) (Overall) Good Status by on 2015 Ammonia Dissolved Oxygen Phosphate Zinc Copper pH Iron Fish Invertebrates River Glynde Reach GB107041012510 Bad Bad High High Bad High N/A N/A Good Good N/A Freshwater Not N/A Firle WwTW, Ecological 2027 Fish Designated Newhaven (east) by 2027 Directive, WwTW, Ringer Nitrates small holdings Directive WwTW, Ripe WwTW Ringmer Neaves Lane River Cuckmere GB107041012330 N/A N/A High Good Poor High High High High Bad Not good App B RBMP Good N/A N/A Drinking Candidate N/A East Dean River Chemical Water Heavily WwTW, Status by Protection Modified Wilmington 2007 Area, WwTW Freshwater Fish , Bathing Water &, Urban Waste Water Treatment Directives Lake Arlington GB30745429 N/A N/A High High High Good App B RBMP Good N/A N/A N/A Candidate Water Berwick WwTW Reservoir Chemical by Artificial Storage - 2015 non specific River Pevensey GB107041006650 Moderate Moderate High Poor Moder High High High High N/A N/A Good Good Disproportionate Freshwater Candidate Land Eastbourne Haven ate Ecological 2027 ly expensive - Fish Heavily Drainage Langley Point Potential by Measure not Directive, Modified WwTW 2027, Good worthwhile Bathing chemical by Water 2015 Directive River Pevensey GB107041012420 Moderate Moderate Good Good Poor High High High High Moder Good Nickel and its Good Good Disproportionate Freshwater Candidate Land Hailsham South Levels ate compounds, Ecological Potential ly expensive - Fish Directive Heavily Drainage WwTW Lead and its by 2027, by 2027 Measure not Modified compounds Good worthwhile Chemical by 2015

River Bull River GB107041012380 Good Good High High High High High High Good High N/A N/A Good Good N/A N/A Not N/A East Hoathly Ecological 2015 Designated WwTW by 2015

River River GB107041012390 Moderate Moderate High Good Moder High High High Good Good Good Nickel and its Good Good Still to be Freshwater Not N/A Vines Cross Cuckmere ate compounds Ecological 2027 determined - Fish Designated WwTW by 2027, Assessment Directive, Good insufficiently Urban Waste Chemical by advanced Water 2015 Treatment Directive

River Hurst Haven GB107041012500 Moderate Moderate High Moder Moder High High High Modera Moder Good Good Nickel and its Good Good Technically Freshwater Candidate Land Hailsham North ate ate te ate compounds, Ecological 2027 infeasible - Fish Heavily Drainage WwTW, Lead and its Potential by cause unknown, Directive, Modified Hurstmonceux compounds 2027, Good Disproportionate Urban Waste lime park WwTW chemical by ly expensive - Water 2015 Measure not Treatment worthwhile Directive

River Wallers Haven GB107041012460 Moderate Moderate High Moder Moder High High High High Moder Good App B RBMP Good Good Disproportionate Drinking Candidate Land Wartling WwTW ate ate ate Ecological 2027 ly expensive - Water Heavily Drainage Potential by Low or uncertain Protection Modified 2027, Good benefits Area, Chemical by Freshwater 2015 Fish Directive

River Nunningham GB107041012610 Moderate Moderate Good Poor Poor High High High High Good Good Good Nickel and its Good Good N/A Freshwater Not N/A Windmill Hill, Stream compounds, Ecological 2015 Fish Designated Bodle Street Lead and its by 2015, Directive, compounds Good Urban Waste Chemical by Water 2015 Treatment Directive River Ashbourne GB107041012620 Good Good High High Good High High High Good Good N/A N/A Good Good N/A Freshwater Not N/A Nethersfield Stream Ecological 2015 Fish Directive Designated Darvell Down by 2015

River Powdermill GB107041012550 Good Good High High Good High High High Good High N/A N/A Good Good N/A Nitrates Not N/A Battle Stream Ecological 2015 Directive Designated by 2015

Wastewater Management Study October 2009 69 East Sussex County Council and Brighton and Hove City Council Wastewater Management Study

WB Type Name Waterbody Current Current Current Elements at Proposed Proposed Justification if Protected Hydromorho Reason WwTW Overall Ecological Chemical Good Status Status Proposed Area logical for Discharging to Status Status Status Chemical Objective(S Objective Objective is not Designation Designation Designati Catchment Status ) (Overall) Good Status by on 2015 Ammonia Dissolved Oxygen Phosphate Zinc Copper pH Iron Fish Invertebrates River Watermill GB107041012540 Moderate Moderate High High Poor High High High Good Good N/A N/A Good Good N/A Freshwater Not N/A Catsfield Stream Ecological 2015 Fish Directive Designated by 2015

River East Stream GB107041012430 N/A N/A High Bad Moder High High High Moder N/A N/A N/A N/A N/A N/A Candidate N/A Hooe, Ninfield ate ate Heavily Lunsford Cross Modified

River Ouse (Sussex) GB107041006560 N/A N/A N/A N/A N/A N/A N/A Bathing Not N/A Alfriston Water Designated Directive River River Rother GB107040013490 Moderate Moderate High Good Poor High High High Good N/A N/A Good Good Disproportionate Freshwater Not N/A Mayfield Meres (East Sussex) Ecological 2027 ly expensive - Fish Directive Designated by 2027 Measure not worthwhile River River Rother GB107040013500 Moderate Moderate High Poor Poor High High High High N/A N/A Good Good Disproportionate Freshwater Not N/A Mayfield Crouch (Kent.Upper) Ecological 2027 ly expensive - Fish Directive Designated by 2027 Measure not worthwhile River Tidebrook GB107040013620 Moderate Moderate Bad Good Bad High Moder High High N/A N/A Good Good Technically Nitrates Not N/A Wadhurst ate Ecological 2027 infeasible - Directive Designated Washwell Lane by 2027 cause unknown, Disproportionate ly expensive - Measure not worthwhile

River River Limden GB107040013610 Moderate Moderate High High Moder High High High Good Good N/A N/A Good Good Disproportionate Nitrates Not N/A Ticehurst ate Ecological 2027 ly expensive - Directive Designated by 2027 Measure not worthwhile

River River Rother GB107040013590 Moderate Moderate High High Good High High High High Good Moder Not good App B RBMP Good Good Disproportionate Drinking Not N/A Stonegate, (East Sussex) ate Ecological 2027 ly expensive - Water Designated Burwash Village, by 2015, Low or uncertain Protection Bodiam - Levetts Good benefits Area, Lane Chemical by Freshwater 2027 Fish Directive, Nitrates Directive River River Dudwell GB107040013570 Good Good High Good High High High High Good High N/A N/A Good Good N/A Freshwater Not N/A Burwash Ecological 2015 Fish Designated Common by 2015 Directive, Nitrates Directive

River River Line GB107040013540 Moderate Moderate High Good Moder High High High Good Moder N/A N/A Good Good N/A Freshwater Not N/A Whatlington ate ate Ecological 2015 Fish Designated by 2015 Directive, Nitrates Directive River Royal Military GB107040013550 Poor Poor Good Moder Poor High High High High Poor Moder Good App B RBMP Good Good Drinking Not N/A Icklesham, Canal ate ate Ecological 2027 Water Designated Winchelsea Ferry by 2027, Protection Hill, Udimore, Good Area, Brede Stubbs Chemical by Freshwater Lane, Brede 2015 Fish waterworks, Directive, Sedlescombe Nitrates Directive Lake Powdermill GB30745011 N/A N/A N/A N/A N/A N/A N/A N/A Candidate Drinking Northiam Mill Reservoir Artificial Water Corner, Staplecross River Doleham Ditch GB107040013380 Moderate Moderate High Good Poor High High High Moder N/A N/A Good Good N/A Nitrates Not N/A Westfield ate Ecological 2027 Directive Designated by 2027 River Royal Military GB107040013390 Poor Poor Good High Bad High High High Good Poor N/A N/A Good Good N/A Bathing Not N/A Fairlight, Canal Ecological 2027 Water Designated Guestling by 2027 Directive, Nitrates Directive

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WB Type Name Waterbody Current Current Current Elements at Proposed Proposed Justification if Protected Hydromorho Reason WwTW Overall Ecological Chemical Good Status Status Proposed Area logical for Discharging to Status Status Status Chemical Objective(S Objective Objective is not Designation Designation Designati Catchment Status ) (Overall) Good Status by on 2015 Ammonia Dissolved Oxygen Phosphate Zinc Copper pH Iron Fish Invertebrates River Jury's Gut GB10704001340 Moderate Moderate Moder Poor Poor High High High Bad High N/A N/A Good Good Disproportionate Freshwater Candidate Land Camber Sewer ate Ecological Potential ly expensive - Fish Artificial Drainage, by 2027 by 2027 measure not Directive, Flood worthwhile Bathing Protection, Water Irrigation, Directive Wider Environme nt Lake Castle Water GB30745035 N/A N/A N/A N/A N/A N/A N/A N/A Candidate Wider Winchelsea Artificial Environme Beach, Rye nt

Coastal Sussex East GB640704540002 Moderate Moderate High High High Good Good App B RBMP Good Good Disproportionate Bathing Candidate Coastal Bexhill and Ecological Potential ly expensive - Water Heavily Protection, Hastings Potential by by 2027 disproportionate Directive Modified Fin 2027, Good burdens Fisheries chemical by 2015 Coastal Sussex GB640704540003 Moderate Moderate High Good N/A Good Good Disproportionate Bathing Candidate Coastal Brighton Potential by Potential ly expensive - Water Heavily Protection, Portobello 2027 by 2027 disproportionate Directive, Modified Fin burdens Nitrates Fisheries Directive River Tributary of GB106040013360 Moderate Moderate High High Bad High N/A Good Good Disproportionate Not Crowborough, Upper Medway Ecological Status by ly expensive - Designated Reigate Mill, at Status by 2027 Measure not Crowborough - St Crowborough 2027 N/A worthwhile Johns

River Medway at GB1060410018070 Moderate Moderate High Good Bad High High High High Moder Good Good App B RBMP Goof Good Disproportionate Freshwater Candidate Flood Forest Row, Weir Wood ate Ecological Potential ly expensive - Fish Heavily Protection Hartfield Potential by by 2027 Measure not Directive, Modified 2027, good worthwhile Nitrates chemical Directive status by 2015 River Teise at Bewl GB106040018500 N/A N/A Good App B RBMP N/A Good N/A Freshwater Candidate Water Frant, Wallcrouch, Chemical Fish Heavily Regulation Wadhurst Status by Directive, Modified (impound Whitegates lane 2015 Nitrates ment Directive, release) UWWTD River Kent Water GB106040018090 Good Good Good Good Good High High High Good Good Good by Nitrates Not Blackham Ecological 2015 Directive Designated Status by 2015, N/A

River River Rother GB107040013640 Moderate Moderate High High Moder High High High High Moder Moder Not good App B RBMP Good Good Technically Drinking Candidate Land Hurst Green, (East Sussex) ate ate ate Ecological 2027 infeasible - Water Heavily Drainage Robertsbridge, by 2027, cause unknown Protection Modified Ewhurst Green, Good Area, Northiam Chemical by Freshwater Quickbourne 2027 Fish Lane, Beckley, Directive, Iden and . Nitrates Directive

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12 Appendix E – Figures

Figure 1 – Study Area

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Figure 2 – WwTW DWF locations

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Figure 3 – Current WwTW Volumetric Capacity_HR

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Figure 4 - Current WwTW Volumetric Capacity

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Figure 5 – Future WwTW Volumetric Capacity

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Figure 6 – Future WwTW Dwelling Capacity

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Figure 7 – Bathing Waters

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Figure 8 – Sites of Conservation Interest

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Figure 9 – Hailsham Potential Preferred Spatial Options

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13 Appendix F - Sustainability Appraisal of Options

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1 Appendix F – Sustainability Appraisal of Options

Introduction

1.1 A Sustainability Appraisal (SA) has been undertaken of the options for sludge and wastewater treatment capacity expansion. This Appendix sets out the findings of this SA. This SA has drawn upon the Scoping Report, which has been prepared for East Sussex County Council and Brighton and Hove City Council by Land Use Consultants for their Waste and Minerals Core Strategy and Mineral Site Development Plan Document.

1.2 The Scoping Report analyses plans and programmes in place in the County, the baseline situation and trend data. The SA Appraisal has used this information to make judgements about the likely effects and potential significance of the options. The SA Scoping Report can be downloaded from the East Sussex County Council website 1.

1.3 Section 1.5 of the main report sets out the objectives of the Wastewater Management Study which include the testing of available options to identify which are most suitable. This SA is part of the processes of testing options and the SA feeds into this process by identifying where possible the sustainability implications of different options. The findings of this SA will contribute to the selection of a preferred Spatial Strategy for future sludge and wastewater management.

Sustainability Appraisal (SA)

1.4 The purpose of SA is to promote sustainable development in the preparation of development plan documents. Under the Planning and Compulsory Purchase Act 2004, Local Authorities are required to undertake SA of their emerging Plans. They are also required to undertake Strategic Environmental Assessment (SEA) in accordance with EU Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment.

1.5 This appraisal is based on a methodology that incorporates both SA and SEA. Its aim is to test the options considered in the Wastewater Management Study in order to ensure that the preferred options taken forward are the most sustainable for East Sussex and Brighton & Hove. The SA also identifies where monitoring can be used to asses the predicted effects to ensure that they remain within acceptable levels and suggest mitigation measures that could potentially be used to lessen adverse effects and maximise beneficial effects.

1.6 ESCC and Brighton & Hove City Council are preparing the SA of the WMCS and, as part of that process, have adopted an appraisal framework against which the WMCS options and policies will be tested. Table F1.1 below sets out this framework. This framework has been used to undertake the SA of the options considered in the Wastewater Management Study.

1 East Sussex County Council Waste and Minerals Sustainability Appraisal – Scoping Report (Consultation Draft) http://www.eastsussex.gov.uk/environment/planning/planningsystem/sustainabilityappraisal/download.htm

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1.7 In undertaking this SA, the options have been appraised against the SA Objectives. Through this process it is possible to anticipate how each option will contribute to the achievement of the SA Objectives.

Table F1.1 SA objectives (Framework)

1. To avoid negative effects and enhance, where possible, positive effects on health 2. To protect the amenity of residents and neighbouring land uses 3. To improve equality and access to sustainable waste management 4. To minimise waste generation and disposal to land 5. To ensure the sustainable use of local mineral resources 6. To maintain and improve water quality 7. To seek the protection of and sustainable use of water resources 8. To reduce risk and impact of flooding 9. To limit the causes of and adapt to climate change 10. To protect air quality and reduce air pollution 11. To reduce adverse impacts of transporting waste and minerals on the environment 12. To conserve and enhance important soil functions and types 13. To protect, conserve and enhance East Sussex and Brighton & Hove’s countryside and historic and built environment 14. To protect, conserve and where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity 15. To increase energy efficiency and the proportion of energy generated from renewable sources 16. To contribute to the growth of a sustainable and diversified economy 17. To provide employment opportunities and develop and maintain a skilled workforce

Options

1.8 The Wastewater Management Study has identified reasonable options for sludge and wastewater treatment capacity expansion and the options identified are set out in Section 4 of the main report.

Non-Strategic Options

1.9 For the majority of the WwTWs the options available for the expansion of capacity are limited by the size of the current works. In addition to this, the majority of the sites are located in rural areas where significant housing growth is not expected. The most reasonable option considered in these instances is either applying for a new DWF consent, upgrading consent or improving works or process. The option identification table in Section 4 of the main report sets out the options for existing WwTW.

1.10 The options available for these locations are not strategic waste management issues and have not been considered by this SA. The environmental implications of these options will be addressed through the standard Environment Agency permitting, planning application and Environmental Impact Assessment (EIA) process. The assessment of the environmental implications of these options requires a detailed analysis informed by information of the scale and nature any proposed infrastructure/changes to discharges and in-depth study of the local environment. As SA does not operate at this level of analysis, and as detailed plans are not yet known it has not been attempted to appraise these options, the SA process would not be able

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to meaningfully distinguish between the options and to feed into the process of option evaluation.

Strategic Options

1.11 For Hailsham, a significant amount of growth is proposed and the existing WwTWs (North and South) have limited capacity. This is an issue of a strategic nature which should be addressed in the Core Strategy. Two strategic options have been identified for the provision of the required capacity for Hailsham. These are as follows:

• Option 1: Relocate the outfall from the existing works to discharge to the sea via a long sea outfall, thereby theoretically allowing for an increase in consented Dry Weather Flow from the works; and

• Option 2: Construct a single new works to replace Hailsham North and South, at a location to be confirmed, which discharges to the River Cuckmere. The Cuckmere has been selected as a suitable alternative discharge location as the river catchments to the east of Hailsham are too small and unlikely to provide adequate dilution of discharged effluent.

1.12 These options have been appraised by the SA and the results of this appraisal are set out in the appendix.

Appraisal Methodology

1.13 The strategic options were appraised against the SA Objectives (set out in table F1.1 above). Each of the options was assessed in terms of its anticipated effects (beneficial/adverse/neutral/uncertain).

1.14 Matrices were used to identify and document the sustainability effects of each of the options (Table F1.2). The following symbols were used in completing the matrices:

Key for Symbols:  = Minor beneficial impact on SA objective  = Significant beneficial impact on SA objective ? = Uncertain/unknown x = Minor adverse impact on SA objective x = Significant adverse impact on SA objective o = No significant impact or direct link or relevance between option and SA objective

1.15 The appraisal was a qualitative exercise based on a combination of expert judgement provided by wastewater management specialists, analysis of baseline data gathered in the Scoping Report and the information provided in the Wastewater Management Study. SA appraisal is inherently subject to a degree of uncertainty as it involves anticipating the likely effects of undertaking an option at a stage when the options have not been worked out into detailed proposals.

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1.16 The SA appraisal considers the effects of undertaking the option in comparison to the current situation (the existing works at Hailsham North and South and the existing discharges from these works) and against the alternative option.

1.17 Where adverse effects are identified the SA sets out possible mitigation and monitoring measures to enable adverse effects to be managed.

Appraisal Findings

1.18 Table F1.2 below sets out the detailed findings of the SA Appraisal.

1.19 For a number of the SA Objectives (1, 3, 4, 5, 7, 10, 12, and 15) no effects were recorded by either of the options.

1.20 For a number of the SA Objectives (2, 6, 8, 11, 13 and 14) uncertain effects were recorded for one or more of the options. Where this is the case an explanation of this has been provided in the commentary section of the appraisal matrix.

1.21 The options both recorded two beneficial effects. These were recorded against SA Objective 16 ‘To contribute to the growth of a sustainable and diversified economy’ and SA Objective 17 ‘To provide employment opportunities and develop and maintain a skilled workforce’. The options will provide construction and operational jobs and will enable the anticipated growth in the area.

1.22 Option 1 (discharge to sea) recorded a significant adverse effects and three minor adverse effects:

• A significant adverse effect is anticipated against SA Objective 9 ‘To limit the causes of and adapt to climate change’. While it is recognised that effluent will be transferred along the pipeline under gravity where this is possible, there is likely to be at least a degree of pumping required. Over this course of the lifetime of the option this is likely to create an electricity demand above that which would be required if the effluent was discharged locally into a nearby river.

• Minor effects were recorded against SA Objective 2 ‘To protect the amenity of residents and neighbouring land uses’, SA Objective 13 ‘To protect, conserve and enhance East Sussex and Brighton & Hove’s countryside and historic and built environment’ and SA Objective 14 ‘To protect, conserve and where appropriate enhance East Sussex and Brighton & Hove’s biodiversity and geodiversity’. While the effects on these objectives are difficult to judge without knowing the location of the pipeline it is likely that there will be at least minor adverse effects associated with the construction of the pipeline due to its length and the scale of the construction project. Any effects are judged to be minor only given that they may be associated with the construction phase and be temporary in nature and that the EIA/planning application process will ensure that the effects are not significantly adverse.

1.23 Option 2 (new works) does not record any adverse effects. As above, it is possible that the construction of the new WwTW may have adverse effects against SA Objectives 2, 13 and 14 depending on the location of the proposed works. These effects are judged to be uncertain at this stage, as the location of the proposed WwTW is unknown. As the works will be a single site

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and therefore geographically constrained, it is possible that there will be no effects. Any adverse effects, which may arise, are judged to be minor only given that they may be associated with the construction phase and be temporary in nature and that the EIA/planning application process will ensure that the effects are not significantly adverse.

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Table F1.2 SA Appraisal

Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

1. To avoid Discharging wastewater to sea has the potential to have negative effects adverse effects on health if the discharge pollutes and enhance, bathing waters. However as the discharge is to be via a where possible, long sea outfall and the discharge will be regulated by positive effects o o the EA no adverse effects are anticipated. The on health. discharge of treated effluent to the River Cuckmere will be regulated by the EA and no adverse effects on health are anticipated. 2. To protect the It is likely that there will be at least some adverse effects The EIA and planning amenity of to the amenity of residents and neighbouring land uses application process residents and due to the construction of the pipeline although these will manage adverse neighbouring are judged to be minor given that they will be temporary effects on amenity to land uses in nature. Potentially there may also be adverse effects ensure that there are x ? on the amenity of residents and neighbouring land uses kept within associated with the construction of the new works acceptable levels for although this effect is less certain as it will depend on residents. the location. If the proposed works is in a remote area there may be no adverse effect. 3. To improve equality and access to o o sustainable waste management 4. To minimise waste generation o o and disposal to land 5. To ensure the sustainable use o o of local mineral resources

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Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

6. To maintain Both of the options involve the eventual discharge of the The water quality and improve treated effluent to sea. Under Option 1 this discharge (both chemical and water quality will be direct and will by-pass any adverse effects on biological) of rivers is monitored by the river water quality. Due to the degree of dilution at the point of discharge no adverse effects are anticipated to Environment Agency marine water quality under Option 1. and this process will identify any decline in Under Option 2 there are a number of factors to water quality. The consider. Under the Option the effluent discharge will be discharge consent relocated from the existing discharge consents to the system is in place to River Cuckmere, which is judged to have sufficient flow ensure that to ensure that the effect of this on the river water quality discharges do not o ? is not adverse. The EA, which regulates discharge have significant consents, would not allow the discharge to occur if it adverse effects on was likely to have a significant adverse effect on water water quality. quality in the receiving waters. Relocating the effluent discharge is likely to bring about water quality improvements to the stream current receiving effluent discharge. Due to the anticipated growth in the area the volume of effluent will be increasing. The quality of effluent may be better from the new plant due to the use of new equipment and technological advances. Due to the number of factors at work it is not possible to judge with certainty the effect of Option 2 on water quality. 7. To seek the protection of and sustainable use o o of water resources

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Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

8. To reduce risk The anticipated pipeline route will involve construction in and impact of Flood Zone 3b. Given the controls that are in place flooding which regulate development in areas of flood risk no adverse effects are anticipated. PPS25 sets out that sewage/water transmission infrastructure and pumping o ? stations are water compatible infrastructure. As the location of the new works is not known it is not possible to judge the effects of this development on floodrisk. Water treatment plants fall into the ‘less vulnerable’ category of land use in PPS25. 9. To limit the The discharge of treated effluent to sea will involve the The use of energy causes of and transmission of effluent from the existing works along a efficient pumping adapt to climate pipeline and a long sea outfall. While it is recognised equipment would change reduce energy that this will be moved under gravity where at all possible it is likely that there will be at least a degree of demand. Using pumping required to move the effluent. In terms of electricity generated increased energy demand over the lifecycle of the from renewable or option this has the potential to be significant. Both low emission sources o x Option 1 and Option 2 would have an energy demand would further reduce associated with them in that they would require the the greenhouse gas construction and the use of materials with embodied emissions associated energy. It is not possible to make a judgement at the with the transmission stage as to which would of the options would have a of the effluent. greater energy demand in terms of the embedded energy of the materials but given the anticipated length of the pipeline it is likely to be Option 1. 10. To protect air quality and o o reduce air pollution

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Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

11. To reduce As outlined under SA Objective 9 the transfer of treated adverse impacts effluent under Option 1 will increase the adverse effects of transporting waste and on the environment by increasing the energy demand minerals on the due to the pumping requirement. As explained under SA environment ? ? Objective 6 there is uncertainty regarding the effect of Option 2 on water quality. Overall any differences between the two options and between the options and the current situation with respect to this SA Objective are difficult to judge and are considered to be uncertain. 12. To conserve and enhance important soil o o functions and types 13. To protect, While the effects of this are difficult to judge without The landscape and conserve and knowing the exact location of the pipeline under Option visual effects of the enhance East 1 and the new works under Option 2, it is likely that pipeline and new Sussex and works will be Brighton & there will be at least minor adverse effects in terms of Hove’s visual intrusion on the countryside associated with the addressed through countryside and construction of the pipeline due to its length. It is likely the EIA and planning historic and built that the pipeline will be buried, which will minimise any application process. environment x ? operational impacts. An uncertain effect is recorded for the construction of the proposed new works. There may be no adverse effects associated with the new works if it is located in a non-sensitive area or a remote area with no receptors. If the site selected has landscape and historic value any impacts are judged likely to be minor only given that the EIA/Planning application process will ensure that any adverse effects are not significant.

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Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

14. To protect, Under Option 1, while it is difficult to predict the effects The biological water conserve and of the pipeline on biodiversity and geodiversity without quality of rivers is where knowledge of its exact location it is likely that there will monitored by the appropriate Environment Agency enhance East be at least minor effects associated with its construction Sussex and given its length. and this process will identify any decline in Brighton & As explained under SA Objective 6 the effects of Option water quality. The Hove’s 2 on water quality (including biological water quality) are discharge consent biodiversity and uncertain. Potentially there may be adverse effects on geodiversity system is in place to the biodiversity and geodiversity associated with the ensure that construction of the new works although this effect is less x ? discharges do not certain as it will depend on the location. If the proposed have significant works is in an area of low value there may be no adverse effects on adverse effect. If the site selected has water quality. biodiversity/geodiversity value any impacts are judged Any effects of the likely to be minor only given that the EIA/Planning construction of the application process will ensure that any adverse effects pipeline or the works are not significant. will be managed through the EIA/Planning application process. 15. To increase The SA Objective focuses on energy efficiency and the energy efficiency proportion of energy generated from renewable sources. and the On the basis of the information available it is not proportion of o o energy generated possible to distinguish between the options and from renewable between the options and the current situation on these sources issues.

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Option 1 Option 2 Commentary Proposed mitigation Discharge to sea Construct a new and monitoring from existing works and works discharge to River Cuckmere

16. To contribute There are likely to be indirect benefits on this SA to the growth of a Objective given that the provision of sufficient sustainable and   wastewater treatment will enable the anticipated growth diversified of the area and that the options will provide temporary economy. construction and long-term operational jobs. 17. To provide Option 1 and 2 will provide jobs in the construction and employment operation of the infrastructure. At this stage it is not opportunities and develop and possible to judge if the number of jobs under each of the maintain a skilled   options will be significantly different from each other workforce. although it is probable that that scale of the construction and therefore the number of jobs associated with the construction of the pipeline will be greater.

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