Rother Local Plan 2020-2040 (Regulation 18)
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Rother Local Plan 2020-2040 (Regulation 18)
109. What are your views on the Council's proposed policy on strategic infrastructure requirements?
Representation ID: 25929
Received: 23/07/2024
Respondent: Southern Water
Southern Water is the statutory wastewater undertaker for the Rother district, and supplies water to parts of the district. Southern Water supports early engagement from developers. However, as the water company is responsible for the public wastewater treatment network and assets, we cannot see how the policy wording below could be applied in practice to water company infrastructure:
Where a proposal would be made unviable in light of infrastructure requirements, open book calculations verified by an independent consultant approved by the Council must be provided.
We explain our reasoning further in our full response. In addition, we have a number of changes to request for this policy, with comments on the Infrastructure Delivery Plan (IDP), and submit these as separate responses to Questions 110, 111 and a further response dedicated to the IDP (ref. paragraph 7.3 page 221).
Comment
Rother Local Plan 2020-2040 (Regulation 18)
110. Are there any alternatives or additional points the Council should be considering?
Representation ID: 25930
Received: 23/07/2024
Respondent: Southern Water
Southern Water may have to provide additional water or wastewater infrastructure to serve new and existing customers or meet stricter environmental standards (as acknowledged in paragraph 11.2 of the Local Plan). It is likely that there would be limited options with regard to location, as the infrastructure would need to connect into existing networks. Planning policies should therefore support proposals that come forward in order to deliver or maintain necessary infrastructure. We therefore request that wording is added to this policy, as explained further below.
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)
110. Are there any alternatives or additional points the Council should be considering?
Representation ID: 25931
Received: 23/07/2024
Respondent: Southern Water
Southern Water may have to provide additional water or wastewater infrastructure to serve new and existing customers or meet stricter environmental standards (as acknowledged in paragraph 11.2 of the Local Plan). It is likely that there would be limited options with regard to location, as the infrastructure would need to connect into existing networks. Planning policies should therefore support proposals that come forward in order to deliver or maintain necessary infrastructure. We therefore request the following wording is added to this policy:
“New and improved utility infrastructure will be encouraged and supported in order to meet the identified needs of the community subject to other policies in the plan.”
Comment
Rother Local Plan 2020-2040 (Regulation 18)
111. Specifically, what are your views on requiring the submission of appropriate evidence to demonstrate that there is, or will be, sufficient infrastructure capacity to meet the demands of a new development?
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.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
7.2
Representation ID: 25935
Received: 23/07/2024
Respondent: Southern Water
For the reasons below, we request changes to the IDP (please see our full response) and recommend a review of the IDP Schedule ahead of the next consultation stage.
• All water companies are working to finalise 5-yearly business plans and our strategic investment plans are therefore not included within the IDP. Outcomes from the DWMP process fed into the proposals we submitted to Ofwat.
• As the Regulation 18 consultation draft of the Local Plan contains no new site allocations, we cannot comment further at this time on ‘the impacts of Rother development strategy on infrastructure needs for the district’ (ref. paragraph 7.3 page 221 of the draft Plan).
• Also, the IDP Schedule does not yet show where the more innovative multi-functional design aims possible for green infrastructure might be incorporated, to reduce the causes and impacts of flooding in line with paragraph 167(c) of the NPPF (2023).
Comment
Rother Local Plan 2020-2040 (Regulation 18)
184. What are your views on the proposed policy on water, coastal and flood risk management?
Representation ID: 25937
Received: 23/07/2024
Respondent: Southern Water
Southern Water is the statutory wastewater undertaker for the Rother district. We support the intention of Policy ENV1, in particular sections (i) and (ii). However, we must request the following wording changes to the policy:
Requested changes:
iv)a. agreement by the wastewater provider that checks indicate there is sufficient network capacity to serve the proposed development.
Statutory water companies must undertake a series of checks and then plan investment in line with water industry funding routes and cycles. Upgrades are planned, delivered and funded through two main mechanisms – one relates to ‘network’ capacity, the other to wastewater treatment process (quality and capacity).
Southern Water supports early engagement from developers. However, we do not see how the current wording of this policy would allow developers to follow it or, therefore, decision makers to react to development proposals.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
185. Are there any alternatives or additional points the Council should be considering?
Representation ID: 25939
Received: 23/07/2024
Respondent: Southern Water
As stated in our response to question 184, we support the intention of Policy ENV1 but ask that the following wording is added to the policy to help safeguard sewage capacity and protect rivers and seas from potential pollution:
(ii) Ensuring that new development does not adversely impact any Ordinary Watercourse, Main River, natural drainage channel or flood and sea defence… No surface water will be allowed to connect to the foul or combined sewer networks
(vii) Ensuring, through the protection of natural drainage routes and the provision of effective sustainable drainage solutions, that development does not increase flood risk elsewhere. All development proposals (including smaller developments and extensions/renovations) should include adequate sustainable drainage provisions and seek to reduce flood risk and contribute to flood alleviation
Over time, the expansion of urban settlements and ‘urban creep’ has added to the amount of rainwater entering sewers.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
11.3
Representation ID: 25940
Received: 23/07/2024
Respondent: Southern Water
We request correction of a statement made in the narrative of paragraph 11.3 on page 368 of the explanatory text for Policy ENV1. Southern Water is not the only organisation with drainage responsibilities across Rother. As flood and surface water drainage responsibilities are not described elsewhere within the draft Local Plan, we request the following change to prevent readers from misunderstanding Southern Water responsibilities at the exclusion of all others:
11.3…Southern Water has a Drainage and Wastewater Management Plan as well as a Water Resources Management Plan as Southern Water is the wastewater provider for the Rother district, also supplying water to parts of the district.
Land drainage responsibilities rest with multiple organisations - a more detailed explanation is provided in our full response, and also available here:
https://www.lgo.org.uk/make-a-complaint/fact-sheets/environment-and-waste/flooding-and-land-drainage-issues#:~:text=These%20are%20all%20other%20watercourses,and%20drainage%20works%20on%20them.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
186. What are your views on the proposed policy on sustainable drainage?
Representation ID: 25942
Received: 23/07/2024
Respondent: Southern Water
Southern Water is strongly supportive of sustainable urban drainage solutions (SuDS) as these will be essential to establishing community resilience to the impacts of climate change into the future. Whilst we appreciate there may be a need for some flexibility, Southern Water considers SuDS essential for all development and asks that the key elements of policy ENV2 are instead proposed within a strategic policy in the next draft of the plan. This is in line with paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) that requires.
We consider the key strategic elements of Policy ENV2 to be the full content with the exception of point (viii) on which we provide further comments in our response to question 187 of the consultation. Preventing surface water from entering the foul and combined systems is the most sustainable and cost-effective way to reduce storm overflows.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
187. Are there any alternatives or additional points the Council should be considering?
Representation ID: 25945
Received: 23/07/2024
Respondent: Southern Water
Southern Water supports the intention of this policy, although we advocate sufficient flexibility in design to ensure the most effective SuDS options remain as viable to as many sites and types of developments as possible. Viability will be particularly important to ensuring SuDS delivery, particularly for affordable homes and single-dwelling development. In line with paragraphs 167(c) and 180(e) of the NPPF(2023) it would therefore increase the efficacy of this policy to make these requested changes:
(iii) for all development, including outline applications, sufficient space must be given within a site to ensure that SuDS can be accommodated within the layout of the site, whilst avoiding any adverse impacts to the natural drainage channels existing within the site;
(Viii) all developments should demonstrate compliance with LLFA guidance for SuDS design, which for large developments or more sensitive locations, may require a minimum of 2 stage filtration of surface water runoff.