Proposed Submission Development and Site Allocations (DaSA) Local Plan

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy BRO2: Land at the Rainbow Trout public house, Broad Oak

Representation ID: 24085

Received: 29/11/2018

Respondent: Southern Water

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Proposed housing numbers for the site at Rainbow Trout public house have increased since the Development and Site Allocations Local Plan - Options and Preferred Options consultation February 2017, and as a result Southern Water has reassessed the capacity of the local sewer network to accommodate anticipated foul flows from the development. This assessment has shown that a connection to the sewer network at this site's 'practical point of connection' (as defined in the New Connections Services implemented from 1 April 2018), could lead to an increased risk of flooding unless network reinforcement is undertaken in advance of occupation.

Southern Water will work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development.

We therefore propose a policy provision aimed at mitigating flood risk by seeking to ensure the delivery of necessary local sewerage infrastructure in parallel with development. Our proposed provision would be in line with paragraph 109, 157 and 177 of the NPPF.

Proposed amendments to Policy BRO2:

(ix) Occupation of the development is phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

Full text:

Proposed housing numbers for the site at Rainbow Trout public house have increased since the Development and Site Allocations Local Plan - Options and Preferred Options consultation February 2017, and as a result Southern Water has reassessed the capacity of the local sewer network to accommodate anticipated foul flows from the development. This assessment has shown that a connection to the sewer network at this site's 'practical point of connection' (as defined in the New Connections Services implemented from 1 April 2018), could lead to an increased risk of flooding unless network reinforcement is undertaken in advance of occupation.

This reinforcement will be provided through the New Infrastructure charge but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development.

This is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of water and wastewater infrastructure, in order to prevent the increased risk of flooding.

Southern Water has limited powers to prevent connections to the water and sewerage networks, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure.

We have therefore proposed a policy provision aimed at mitigating flood risk by seeking to ensure the delivery of necessary local sewerage infrastructure in parallel with development. Our proposed 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', and paragraph 109 which sets out how the planning system can enhance the local environment by preventing new and existing development from being adversely affected by pollution (which may include sewer flooding). In addition, paragraph 177 of the NPPF outlines that it is important to ensure that planned infrastructure is deliverable in a timely fashion.

Proposed amendments

Accordingly, in line with the NPPF and National Planning Practice Guidance, to ensure sustainable development, we propose that the following criterion is added to Policy BRO2:

(ix) Occupation of the development is phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Policy BEX4: Land at Former High School Site and Drill Hall, Down Road, Bexhill

Representation ID: 24088

Received: 29/11/2018

Respondent: Southern Water

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is limited wastewater capacity on this site at the "practical point of connection", as defined in the New Connections Services. Our assessment shows this could lead to an increased risk of flooding unless network reinforcement is undertaken in advance of occupation.

Southern Water will work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development.

This is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of water and wastewater infrastructure, in order to prevent the increased risk of flooding.

We therefore propose a policy provision aimed at mitigating flood risk by seeking to ensure the delivery of necessary local sewerage infrastructure in parallel with development. Our proposed provision would be in line with paragraph 109, 157 and 177 of the NPPF.

Proposed amendment to Policy BEX4:

(ix) Occupation of the development is phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

Full text:

This site is within Southern Water's statutory wastewater service area. Further to our comments on this site in the Development and Site Allocations Local Plan - Options and Preferred Options consultation February 2017), we note that whilst our proposed amendments have been included within most site allocation policies, this has not been included in Policy BEX4. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach in line with the new requirements, however the need remains for recognition that there is limited capacity on this site at the "practical point of connection", as defined in the New Connections Services. Our assessment has shown that a connection to the sewer network at this site's 'practical point of connection' could lead to an increased risk of flooding unless network reinforcement is undertaken in advance of occupation.

This reinforcement will be provided through the New Infrastructure charge but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development.

This is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of water and wastewater infrastructure, in order to prevent the increased risk of flooding.

Southern Water has limited powers to prevent connections to the water and sewerage networks, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure.

We have therefore proposed a policy provision aimed at mitigating flood risk by seeking to ensure the delivery of necessary local sewerage infrastructure in parallel with development. Our proposed 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', and paragraph 109 which sets out how the planning system can enhance the local environment by preventing new and existing development from being adversely affected by pollution (which may include sewer flooding). In addition, paragraph 177 of the NPPF outlines that it is important to ensure that planned infrastructure is deliverable in a timely fashion.

Proposed amendment

Accordingly, in line with the NPPF and National Planning Practice Guidance, to ensure sustainable development, we propose that the following criterion is added to Policy BEX4:

(ix) Occupation of the development is phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

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