Proposed Submission Core Strategy

Southern Water is unable to support the Core Strategy as sound because Policy RA2 fails to recognise water and wastewater infrastructure as acceptable forms of development in the countryside. This approach is unduly restrictive and could prevent delivery of necessary infrastructure. This is contrary to paragraph 27 (iv) of PPS1 which requires the provision of essential infrastructure to be taken into account to deliver sustainable development.

Southern Water fully appreciates the planning authority's wish to control development in the countryside. However, it is important that policies do not unduly restrict provision of essential water supply and wastewater infrastructure. Policy RA2 should recognise that essential utility development is acceptable in the countryside if it is required to serve new and existing development.

Furthermore, although we accept that impacts on the countryside should always be minimised, in some cases total avoidance is not possible.

In such cases, and where the benefit of the development outweighs the negative impact, mitigation or compensation might be the most sustainable way to proceed. This approach is consistent with paragraph 19 of PPS1.

Southern Water is unable to support the Core Strategy as sound because Policy RA3 fails to recognise water and wastewater infrastructure as acceptable forms of development in the countryside. This approach is unduly restrictive and could prevent delivery of necessary infrastructure. This is contrary to paragraph 27 (iv) of PPS1 which requires the provision of essential infrastructure to be taken into account to deliver sustainable development.

Southern Water fully appreciates the planning authority's wish to control development in the countryside. However, it is important that policies do not unduly restrict provision of essential water supply and wastewater infrastructure. Policy RA3 should recognise that essential utility development is acceptable in the countryside if it is required to serve new and existing development.

It is vital that gypsy and traveller pitches have access to essential infrastructure such as wastewater services and water supply.

It is also important that the pitches are compatible with neighbouring land-uses. It would not be appropriate to locate pitches in close proximity to wastewater treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, the very nature of wastewater treatment works means that they are not ideal neighbours to sensitive development. Development in close proximity to wastewater treatment works can suffer from smells that are inherent in the treatment process.

Residential development, such as gypsy and traveller sites, without essential utility provision i.e. water supply and/or located in close proximity to a wastewater treatment works cannot be considered sustainable. Development must be sustainable to be consistent with national planning policy PPS1.

Furthermore, paragraph 4.45 of PPS 12 requires that, to be deliverable and therefore effective, core strategies should be based on sound infrastructure planning. This omission from policy LNH6 is clearly contrary to PPS 12.

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.

Some of the text in paragraph 13.25 states that the Water Resources Management Plans set out agreed investment plans for meeting obligations to supply water. This is not strictly correct, and we therefore recommend some minor changes. Water Resource Management Plans set out how the water companies propose to ensure that there is sufficient security of water supplies to meet the demands of their customers. These plans then feed in to the companies' Business Plans which set out the agreed investment plans.