The current "Sustainable Resource Management" (Page 99) has little detail of any water efficiency measures related to domestic dwellings or commercial properties. It therefore does not provide a clear steer to developers to what is expected of them.

We note the document does set out resource pressures under the "Water Management" sections and references to our publication, 'Current State & future pressures on water resources' page 96. We also note that under the title 'Sustainable Resource Management' (page 98), the document also talks about the responsibility on water company's in managing demand but there is little detail on how the Council proposals to fore fill their responsibilities in requiring reduced water consumption through the planning process. This is evident from by the policies in SRM2 i.e.:

"(v) The promotion of water efficiency through the use of rainwater and grey water storage and recycling." (Page 98)

It is not clear how the word 'promotion' can be translated into an enforceable planning condition and we can see difficulty for the Council and ourselves in trying to include such requirements in future planning conditions without them being appealed by applicants. In addition it should be noted that the use of rainwater and Grey water schemes are usually only viable on large scale developments. They are more costly and for smaller proposal developers are likely to consider this unviable for such projects.

The Code for Sustainable Homes (CfSH) whilst not mentioned within this document goes further than the current building regulations, and indications so far do not suggest any revisions of the building regulations section G to include water efficiency measures any time soon and therefore it must be assumed for the time being that the water efficiency standards detailed in CfSH is the suitable vehicle for ensuring water efficiency measures are required within all new residential developments.

We also believe that where feasible higher more stringent water usage levels through a staged implementation as new technologies should be introduced, particularly for major developments. For example Dartford Borough Council CS (that has been through examination) Policy CS25(c) refers to:

"Sites of 500 units or more will be expected to act as exemplars. In addition to above, they will be required to reduce dependence on potable water through rainwater harvesting, recycling of used water and reduction of water 'hungry' activity, and should be designed to enable later retrofitting to achieve the highest levels of the Code for Sustainable Homes in terms of water use."

The policy also needs to make it clear that water efficiency targets encompass industry and commercial developments as well. We can not find any mention of BREEAM standards usually associated with such developments.

In the SA report sustainable management of water has been identified to have potentially significant effects of the Plan Policies on the SA Objectives (SA Report - Summary of the Likely Significant Effects of the Strategies, Objective 13, Page 7 - extract below), yet this does not have been translated through to the Core Strategy.

"The sustainable management of water is fundamental in achieving sustainable development and the Strategy for the Environment aims to minimise water use, to provide water supply in a sustainable way and to ensure efficient sustainable wastewater infrastructure. The Water Management policy should help to mitigate the adverse impacts on this SA Objective from other strategies."