Wastewater Treatment

As you are aware. Southern Water is the statutory sewerage undertaker in Rother District. In line with paragraph 162 of the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG), we have updated our site-by-site assessment of the sites with 20 or more dwellings identified in the draft Development and Site Allocations Local Plan (DeSA) to determine whether capacity in the local sewerage network is sufficient to meet the anticipated demand.

That assessment reveals that additional local sewerage infrastructure would be required to accommodate the proposed development, involving making a connection to the local sewerage network at the nearest point of adequate capacity.

a) Insufficient capacity

A lack of capacity is not a fundamental constraint to development however new or improved infrastructure would need to be provided in parallel with the development.

Connection to the sewerage network at the nearest point of adequate capacity is the mechanism by which the development can provide the local infrastructure required to service the sites. Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is insufficient. Planning policies and planning conditions, therefore, play an important role in ensuring that development is co-ordinated with provision of necessary infrastructure.

Unless planning policies support delivery of necessary underground sewerage infrastructure there is a risk that it will not be delivered in parallel with the development, leading to an unacceptable risk of foul water flooding in the area to both new and existing residents. This situation would be contrary to paragraph 109 of the NPPF, which requires the planning system to prevent both new and existing development from contributing to pollution.

It is likely that investment would be required to deliver additional wastewater treatment capacity. This strategic infrastructure, such as extensions to wastewater treatment works, can be planned and funded through the Price Review process, and coordinated with new development. Last year's (2015) price determination will fund the investment programme for the period to 2020. There will be another price review in 2019, covering the investment period 2020 to 2025. Adoption of development plan documents provides the planning certainty required to support investment proposals to Ofwat, the water industry's economic regulator.

We have therefore proposed policy provision below to secure delivery of necessary local sewerage infrastructure in parallel with development. Our proposed policy provision would be in line with paragraph 157 of the NPPF which states that Local Plans should 'plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this framework', and paragraph 177 of the NPPF outlines that it is important to ensure that planned infrastructure is deliverable in a timely fashion.

Furthermore, it is important to give early warning to prospective developers regarding the need to connect off-site, as it could add to the cost of development. Early warning will facilitate delivery of the necessary infrastructure as this infrastructure requirement can then be incorporated into the planning process at an early stage.

Land at Michael Tyler Furniture, Woodlands Way, Hastings

We request additional criteria for this policy relating to utility infrastructure:

* A connection is provided to the local sewerage system at the nearest point of adequate capacity, in collaboration with the service provider.