Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Southern Water supports the option for DRM1: Water Efficiency that implements the higher water efficiency standard, and supports the evidence set out in the Water Efficiency Paper.

Given that Southern Water's water supply area is currently classified by the Environment Agency as a seriously water stressed area, we would encourage a policy that promotes the higher level of water efficiency of 110 litres/person/day, subject to appropriate justification in your evidence base. Although it is not our role to set out the justification for the optional higher technical standard, we would support the stance you are taking within your document. We take this opportunity to point out that the planning authority would need to ensure compliance with building regulations and planning policies as water companies do not have the required enforcement powers and therefore support the use of planning conditions as a means of ensuring compliance with the optional technical standard.

Southern Water supports the inclusion of odour within the policy wording of DEN7: Environmental Pollution.

A few of the sites identified in the DaSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks.

Southern Water supports the approach taken to set out in the proposed wording DIM1: Comprehensive Development, particularly in relation to infrastructure solutions.

Southern Water supports the planning authority's intention to secure delivery of infrastructure that is required to serve development in a comprehensive manner. Although Rother District Council is not the waste planning authority, it does have a role to ensure that development is co-ordinated with provision of necessary wastewater infrastructure

Southern Water notes that in some cases separate agreements with utility providers may be required (as opposed to planning agreements with the planning authority). Southern Water will seek developer contributions in line with the water industry's regulatory framework, and will enter into separate agreements supported by appropriate planning policies and planning conditions where necessary.

We consider that this policy is supported through (a) the Core Planning Principle contained in the National Planning Policy Framework (NPPF) to 'proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs' [our highlight], and (b) 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'.

Southern Water would support the proposed policy wording in the preferred option to DIM2: Development Boundaries as it would seem to include infrastructure requirements in the phrase ".. that which accords with specific Local Plan policies...". It would be our preference for the policy to explicitly set out an exception for utility infrastructure as it may be required to serve the housing development elsewhere in the plan.

Southern Water may need to undertake development to meet the needs of development set out in the DaSA or to meet stricter environment standards. We are keen to ensure that any future infrastructure development in these circumstances would not be unduly restricted by inappropriate or highly restrictive policies. Paragraph 157 of the National Planning Policy Framework (NPPF) is clear 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'.

If the policy is intended to exclude utility infrastructure then the policy fails to recognise the key role of our infrastructure in achieving sustainable development, contrary to the premise of the NPPF. The development identified in the DaSA is likely to generate the requirement for additional infrastructure as set out in our representations on individual site policies. Paragraph 177 of the NPPF emphasises the importance of ensuring the timely delivery of infrastructure to support development and if there is no exception made for utility infrastructure, the application of any countryside policies in the determination of any planning application outside of settlement boundaries may make this difficult.

Proposed Amendment

In the interests of clarity and in order to support the delivery of the level of development set out elsewhere in the DaSA, Southern Water proposes the following wording change to policy DIM2: Development Boundaries (our addition underlined):

Policy DIM2: Development Boundaries

The development boundaries of settlements, defined in accordance with Core
Strategy Policy OSS2, are shown on the Policies Map.

New development shall be focused within defined settlement development
boundaries, principally on already committed and allocated sites, together with
other sites where proposals accord with relevant Local Plan policies.

In the countryside (that is, outside of defined settlement development boundaries), development shall be normally limited to that which accords with specific Local Plan policies, including policies which support the delivery of essential infrastructure, or that for which a countryside location is demonstrated to be necessary.

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.

b) Proximity to treatment works and requirement for odour assessment

A few of the sites identified in the DeSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks; during secondary treatment; and particularly from sludge treatment, transfer and storage'.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

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

This site is in close proximity to Preston Farm, Sidley Wastewater Pumping Station.

* The masterplanning of the site should take account of nearby wastewater pumping stations to minimise land use conflict

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 (DaSA) 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.

b) Proximity to treatment works and requirement for odour assessment

A few of the sites identified in the DaSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks; during secondary treatment; and particularly from sludge treatment, transfer and storage'.

c) Underground Infrastructure

Although not strictly a planning policy requirement, where appropriate we would also seek recognition of the need to protect underground infrastructure that cross the site so that this is not built over, and it can continue to fulfil its function. Easements would be required to allow access for future maintenance and upsizing. We have noted which sites this may apply to as an early warning to potential developers.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

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.

This site is in close proximity to Preston Farm, Sidley Wastewater Pumping Station.

* The masterplanning of the site should take account of nearby wastewater pumping stations to minimise land use conflict

(Please note that Southern Water requires access to the existing outfall. The need for easements will therefore need to be taken into account in the layout of the site).

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.

b) Underground Infrastructure

Although not strictly a planning policy requirement, where appropriate we would also seek recognition of the need to protect underground infrastructure that cross the site so that this is not built over, and it can continue to fulfil its function. Easements would be required to allow access for future maintenance and upsizing. We have noted which sites this may apply to as an early warning to potential developers.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

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.

(Please note that Southern Water requires access to the existing outfall. The need for easements will therefore need to be taken into account in the layout of the site).

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 (DaSA) 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.

d) Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

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

Underground Infrastructure

Although not strictly a planning policy requirement, where appropriate we would also seek recognition of the need to protect underground infrastructure that cross the site so that this is not built over, and it can continue to fulfil its function. Easements would be required to allow access for future maintenance and upsizing.

* Southern Water requires access to the existing outfall. The need for easements will therefore need to be taken into account in the layout of the site.

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 (DaSA) 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.


b) Proximity to treatment works and requirement for odour assessment

A few of the sites identified in the DeSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks; during secondary treatment; and particularly from sludge treatment, transfer and storage'.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

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

This site is in close proximity to Spindlewood Drive, Bexhill Wastewater Pumping Station.

* The masterplanning of the site should take account of nearby wastewater pumping stations to minimise land use conflict.