Proposed Submission Core Strategy

We note that EN3 (ii) refers to Appendix 4 that has some more detail on what is expected to be addressed under each of the headings (a) to (h) of the policy.

We support the general principles outlined in the Appendix 4(h), however we note that it references back to Chapter 13 Sustainable Resource Management, so subject to Policy SRM2 being amended as suggested above, clearly this part of Policy EN3's effectiveness, in our opinion, will be dependent on our proposed minor changes to SRM2 being incorporated.

We note that EN3 (ii) refers to Appendix 4 that has some more detail on what is expected to be addressed under each of the headings (a) to (h) of the policy.

We support the general principles outlined in the Appendix 4(h), however we note that it references back to Chapter 13 Sustainable Resource Management, so subject to Policy SRM2 being amended as suggested above, clearly this part of Policy EN3's effectiveness, in our opinion, will be dependent on our proposed minor changes to SRM2 being incorporated.

We note that EN3 (ii) refers to Appendix 4 that has some more detail on what is expected to be addressed under each of the headings (a) to (h) of the policy.

We support the general principles outlined in the Appendix 4(h), however we note that it references back to Chapter 13 Sustainable Resource Management, so subject to Policy SRM2 being amended as suggested above, clearly this part of Policy EN3's effectiveness, in our opinion, will be dependent on our proposed minor changes to SRM2 being incorporated.

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."

This policy needs to state that the Sequential test will be informed by the hazard mapping contained within the Strategic Flood Risk Assessment (SFRA). An example of this approach is contained within Shepway DC's Core Strategy submission document which has proposed in Policy SS3 c.1:

"that no residential development, other than replacement dwellings should take place within areas identified as "extreme risk" as shown on the SFRA 2115 climate change hazard maps."

These areas are generally shown to be on parts of Romney Marsh. Although Rother DC's own SFRA does not have an extreme risk zone, a similar policy that limits the type of development that would be acceptable in those areas of high hazard under present day conditions needs to be included to guide developers. This kind of approach can be very helpful with the ST at the planning application stage.

Reference is made in Policy EN7 to incorporate sustainable drainage systems (SuDS) into new development. However, this is a broad subject and more guidance for developers needs to be provided. For example, policy CS20 of the Ashford Borough CS is supported by a Sustainable Planning Document on SuDS. This describes how not only should SuDS be used to restrict runoff to the appropriate discharge rate, but they should be used to maintain or improve the quality of the receiving watercourse. They can also be used to enhance local biodiversity and public amenity and therefore, potentially make an important contribution to Local Authority responsibilities under the Water Framework Directive. The Ashford SPD recognised these benefits and also provides guidance on future responsibility for maintenance of SuDS.

In addition it should be noted that the Cuckmere and Sussex Havens and Rother and Romney Catchment Flood Management Plans (CFMP) that proposed actions for a number of existing settlements within Rother District are to reduce run-off and to develop a Surface Water Management Plan (SWMP). We strongly recommend a policy on details of SuDS and responsibility for subsequent management, similar to that within the Ashford CS, be developed as part of the Rother CS in order to help meet the objectives of the CFMPs.