Policy SRM2: Water Management

Shepway and Rother Districts share the responsibility for the careful management of the Rother River Basin and as such Shepway District Council welcomes measures that safeguard the quality and quantity of water within this hydrological system.

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."

Southern Water supports part (iv) Policy SRM2 which supports the delivery of the possible raising of Bewl Water reservoir. The safeguarding of this land is very important for the successful implementation of this additional resource.

Southern Water is unable to support part (v) of policy SRM2 as sound. Promotion of the use of rainwater and grey water storage and recycling to the exclusion of other water efficiency measures is not justified. There are additional water efficiency measures that could be applied, for example low flush toilets and low flow taps and showers.

For information, the planning authority should be aware of potential hygiene issues associated with grey water recycling. It is important that if grey water recycling systems are promoted, appropriate systems are in place to ensure the recycled water is treated adequately to control bacterial growth and protect public health in perpetuity.

Southern Water is unable to support the Core Strategy as sound because no policy directly supports provision of strategic water and wastewater infrastructure in a generic manner.

This could have a detrimental impact on delivery of essential infrastructure required to support new development, and is contrary to paragraph 23 (viii) of PPS1.

New and improved wastewater infrastructure will be needed to serve the development proposed in Rother's Core Strategy. Furthermore, new or extended water supply infrastructure will also be required within the life time of the Core Strategy.

Tightening of environmental standards set by the Environment Agency is also a potential driver for new infrastructure and would contribute to meeting the environmental objectives of the Core Strategy.

It is acknowledged that policy IM2 supports delivery of infrastructure through developer contributions. However, the strategic water supply and wastewater infrastructure (e.g. extension to treatment works) required to serve new development will be provided solely by Southern Water without developer contributions and is therefore not covered by policy IM2.

Policy SRM2 also neglects to explicitly support provision by water companies of water supply and wastewater infrastructure although it is acknowledged that Policy SRM2 supports the delivery of the possible raising of Bewl Water reservoir.

A supportive planning policy framework is imperative at all levels - regional, county and local - to facilitate timely delivery of water and wastewater infrastructure required to serve new development.

If development is allowed to proceed before the necessary capacity is in place to serve it, both new and existing customers may experience unsatisfactory levels of service, for example poor water pressure and failure to meet environmental standards in the treatment of wastewater.

"Promotion" of rainwater harvesting is not strong enough.
The policy should be to ensure that all developments consider rainwater and require larger developments to incorporate rainwater harvesting.