Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25932
Received: 23/07/2024
Respondent: Southern Water
Southern Water supports early engagement from developers. However, the water company is responsible for the public wastewater treatment network and we cannot see how proposals to submit evidence ‘that there is or will be sufficient infrastructure capacity per development’ could be applied in practice to water company operations and infrastructure planning.
Statutory water companies must undertake a series of checks and then plan investment in line with water industry funding routes and cycles. Where consulted, Southern Water will re-assess capacity in relation to proposed development during the planning application process and any capacity constraints will be managed through the current regulatory funding mechanisms for the reinforcement of our wastewater infrastructure. Upgrades are planned, delivered and funded through two main mechanisms – one relates to ‘network’ capacity, the other to wastewater treatment process (quality and capacity). These are explained further in our full response.
Southern Water supports early engagement from developers. However, the water company is responsible for the public wastewater treatment network and we cannot see how proposals to submit evidence ‘that there is or will be sufficient infrastructure capacity per development’ could be applied in practice to water company operations and infrastructure planning.
Statutory water companies must undertake a series of checks and then plan investment in line with water industry funding routes and cycles. Where consulted, Southern Water will re-assess capacity in relation to proposed development during the planning application process and any capacity constraints will be managed through the current regulatory funding mechanisms for the reinforcement of our wastewater infrastructure. Upgrades are planned, delivered and funded through two main mechanisms – one relates to ‘network’ capacity, the other to wastewater treatment process (quality and capacity):
• Any upgrades (reinforcements) that are needed on the network, specifically to accommodate new development, are funded through the new infrastructure charge to developers - https://www.southernwater.co.uk/building-and-developing/our-services/water-services/connecting-charging-arrangements/
• Wastewater Treatment Works (WTWs) treat wastewater collected from homes and businesses within their ‘catchment’ via a network of connecting pipes and pumping stations. WTWs are significant assets and represent strategic infrastructure. Upgrades to WTWs are funded through the water industry’s 5 yearly investment plan which sets out spending requirements over the next 5 year period (AMP) using customer generated income. Where upgrades will enhance treatment quality, this is determined by the Environment Agency where it issues new environmental permits and as part of the Water Industry National Environmental Programme (WINEP).
There is an opportunity to work in partnership with Local Planning Authorities and through well evidenced policy making, help ensure that new connections to the sewer are sensibly managed. Preventing connections of surface water to foul or combined sewer networks will be key to safeguarding the capacity and effective operation of the public sewage network into the future. However, Southern Water is the statutory sewerage undertaker for the Rother district. There is a separate statutory regime governing the provision of sewerage and wastewater treatment under the Water Industry Act 1991 and local planning authorities should not seek to duplicate the roles and responsibilities of the statutory undertaker.
We also have a number of comments to make on the Infrastructure Delivery Plan, for which we have submitted a separate response to paragraph 7.3 of the Plan:
“Through this public consultation we will be seeking the views of infrastructure providers on the impacts of our development strategy on the infrastructure needs for the district.”
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26534
Received: 22/07/2024
Respondent: Tunbridge Wells Borough Council
TWBC considers there will need to be
sufficient engagement with relevant
infrastructure and utility providers – transport, water/sewage, education,
medical services etc. through Duty to
Cooperate and producing Statements of
Common Ground along with the
requirement to produce evidence base
documents – such as transport modelling
and flood modelling to support the
Infrastructure Development Plan and the
Local Plan.
See attached document
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26633
Received: 22/07/2024
Respondent: Mr Kenneth Saunders
Number of people: 2
We do not know the details of how to work out the needs of communities. But any applications need to give evidence of how this will be addressed, consulting local information and organisations both public and voluntary as well as national figures e.g. population predictions etc.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27112
Received: 22/07/2024
Respondent: Westfield Parish Council
See point 149 in the attached submission.
Please see attached document for the full submission from Westfield Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27241
Received: 23/07/2024
Respondent: Guestling Parish Council
Agree.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27420
Received: 22/07/2024
Respondent: Catsfield Parish Council
Yes, there should be clear evidence that capacity is in place before developments can be approved.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28191
Received: 23/07/2026
Respondent: Mr Raphael Brandon
Agent: Corbil Planning Ltd
It would be unreasonable and too costly for a small development to be able to demonstrate at the application stage that it could provide this level of information and evidence on infrastructure capacity. For small and medium sized developments, it should be the LPA that identifies areas of inadequate infrastructure within its district and secure CIL monies accordingly. A threshold needs to be placed into the wording of this policy with it being targeted towards large-scale major developments only.
Please see attached full representation on the draft Local Plan in relation to HELAA site ICK0017.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 28310
Received: 23/07/2024
Respondent: Powdermills Prop Co UK Ltd
Agent: Corbil Planning Ltd
Policy INF1: Strategic Infrastructure Improvements
It would be unreasonable and too costly for small developments to be able to demonstrate at the application stage that they could provide this level of information and evidence on infrastructure capacity. For small and medium sized developments, it should be the LPA that identifies areas of inadequate infrastructure within its district and secure CIL monies accordingly. A threshold needs to be placed into the wording of this policy with it being targeted towards large-scale major developments only.
Please see attached for representations on the following elements of the draft Local Plan:
Policy ECO1: Supporting New Employment Development
Policy ECO2: Protecting Existing Employment Sites and Premises
Policy ECO5: Tourism Activities, Facilities and Accommodation
Policy ECO6: Holiday Sites
Policy INF1: Strategic Infrastructure Improvements
Policy INF2: Digital Connectivity
Policy LAN2: Trees, Woodlands and Hedgerows
Policy ENV5: Habitats and Species