Rother Local Plan 2020-2040 (Regulation 18)

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 below. In addition, we have a number of changes to request for this policy, and to 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).

Further explanation and justification:
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).
Any upgrades (reinforcements) that are needed on the network, specifically to accommodate new development, tend to be defined as local infrastructure as they typically serve one development. These are funded through the new infrastructure charge to developers - https://www.southernwater.co.uk/building-and-developing/our-services/water-services/connecting-charging-arrangements/
Wastewater Treatment Works (WTWs) treat wastewater collected from homes and businesses within their ‘catchment’ via a network of connecting pipes and pumping stations. WTWs are significant assets and represent strategic infrastructure. Upgrades to WTWs are funded through the water industry’s 5 yearly investment plan which sets out spending requirements over the next 5 year period (AMP) using customer generated income.

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.”

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.”

Requested changes for Policy INF1:
“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.”
Further explanation and justification:
We could find no policies to support the general provision of new or improved utilities infrastructure. The NPPF (2023) paragraph 7 establishes that ‘supporting infrastructure in a sustainable manner’ is key to achieving sustainable development. Also the National Planning Practice Guidance states that ‘Adequate water and wastewater infrastructure is needed to support sustainable development’.

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):
• Any upgrades (reinforcements) that are needed on the network, specifically to accommodate new development, are funded through the new infrastructure charge to developers - https://www.southernwater.co.uk/building-and-developing/our-services/water-services/connecting-charging-arrangements/
• Wastewater Treatment Works (WTWs) treat wastewater collected from homes and businesses within their ‘catchment’ via a network of connecting pipes and pumping stations. WTWs are significant assets and represent strategic infrastructure. Upgrades to WTWs are funded through the water industry’s 5 yearly investment plan which sets out spending requirements over the next 5 year period (AMP) using customer generated income. Where upgrades will enhance treatment quality, this is determined by the Environment Agency where it issues new environmental permits and as part of the Water Industry National Environmental Programme (WINEP).
There is an opportunity to work in partnership with Local Planning Authorities and through well evidenced policy making, help ensure that new connections to the sewer are sensibly managed. Preventing connections of surface water to foul or combined sewer networks will be key to safeguarding the capacity and effective operation of the public sewage network into the future. However, Southern Water is the statutory sewerage undertaker for the Rother district. There is a separate statutory regime governing the provision of sewerage and wastewater treatment under the Water Industry Act 1991 and local planning authorities should not seek to duplicate the roles and responsibilities of the statutory undertaker.

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.”

Paragraph 7.3 of page 221 of the current draft of the Rother Local Plan states:
“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.”
Paragraph 1.5 of the IDP states further:
“Rother District Council welcomes feedback and commentary from infrastructure providers on the impacts of the proposed development strategy, these comments can be provided through the consultation on the draft Local Plan.”
Southern Water has not previously had sight of the draft IDP and having now reviewed the content, we request the changes below, explaining our reasoning further below. For your ease of reference, we summarise our concerns as follows:
• All water companies now await Ofwat’s final determination for 5-yearly business plans. Once published, we will be in a position to confirm strategic infrastructure delivery (as it is planned through this process). Outcomes from the DWMP process, that Rother DC was consulted on, have now fed into the plans we submitted to Ofwat for consideration. As we await final determination, our strategic infrastructure investment plans are not included within the IDP.
• As the current Regulation 18 consultation draft of the Local Plan also 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).
• In light of the above two points, we would recommend closer engagement over the content of the IDP, where at all possible to include a review of the IDP Schedule ahead of the next consultation stage for the Local Plan with a focus on local or strategic infrastructure needed to support the Local Plan (please see more detailed explanation below for our requested changes).
• 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).
Requested changes:
The DWMP consultation process engaged with Local Authorities at a number of stages from the methodologies adopted through to the outputs that subsequently fed into the 5-year business planning process. As stated above, we await the final determination of our business plan from the water industry regulator Ofwat. We therefore highlight that the following entries within the IDP Schedule may be subject to change, or removal from the IDP Schedule where they do not represent capital investment for local or strategic infrastructure needed to support the Local Plan:
• UTI010, UTI011, UTI012, UTI013, UTI014, UTI015, UTI016, UTI017, UTI018, UTI019, UTI020, UTI021, UTI022, UTI023, UTI024, UTI025, UTI026
Additionally, the following entries could be updated as follows:
• UTI007 – as network reinforcement is generally to service one development, this is understood to be Local Infrastructure, rather than Strategic, and as such should be listed as Developer funded within the IDP Schedule (not part-funded through the capital programme). As delivery is underway, this scheme presents “Low” delivery risk if that could also be changed. Funding for all interventions is above £2m, but awaits final business plan confirmation – please see the links to further information where this is of help: https://experience.arcgis.com/experience/09b43c8b9ebd4edb954f9da099405558/page/Page/#data_s=id%3AdataSource_1-1882e4bc911-layer-30%3A19039
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/fairlight-east-sussex/

Further explanation:
As explained in our feedback to the draft Strategic Infrastructure Policy INF1, statutory water companies must undertake a series of checks and then plan investment to accommodate growth 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).
Any upgrades (reinforcements) that are needed on the network, specifically to accommodate new development, are funded through the new infrastructure charge to developers - https://www.southernwater.co.uk/building-and-developing/our-services/water-services/connecting-charging-arrangements/.
Such upgrades are the responsibility of the statutory wastewater undertaker to plan and deliver once a planning application is granted as it is normally to serve that one development – which therefore meets the definition of local infrastructure needs.
Wastewater Treatment Works (WTWs) treat wastewater collected from homes and businesses within their ‘catchment’ via a network of connecting pipes and pumping stations. WTWs are significant assets and represent strategic infrastructure. Upgrades to WTWs are funded through the water industry’s 5 yearly investment plan which sets out spending requirements over the next 5 year period (AMP) using customer generated income.
We hope the above explanation helps to define the areas of Southern Water infrastructure delivery and investment plans that would be most relevant to include within the IDP Schedule.
The central purpose of Drainage and Wastewater Management Plans (DWMPs) is to plan for future climates and population while reducing storm overflows, flooding and pollution for the benefit of customers, communities and businesses and to protect and improve the water environment. Although many of these factors relate to growth and local planning for this, a number of outcomes relate to operational interventions to improve areas of performance, at times mitigating the impacts of behaviours as well as those of our changing climate.
The DWMP process involved extensive consultation that included local authorities and the Environment Agency amongst others. The outcomes* of the DWMP process were concluded and fed into investment proposals submitted for Ofwat approval as part of our 5-yearly draft business plans.
*For outcomes of DWMP consultation for relevant wastewater catchments, please see: https://www.southernwater.co.uk/media/hk1dkpwg/l3_fair.pdf https://www.southernwater.co.uk/media/4h4em53p/l3_ryew.pdf and
https://www.southernwater.co.uk/media/u5hm2kf0/l3_habx.pdf

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 also request wording changes to parts of the policy, as explained further below. We also provide additional comments on this policy in our response to question 185.

Requested changes:
iv)a. agreement by the wastewater provider that checks indicate there is sufficient network capacity to serve the proposed development.

Further explanation and justification:
Southern Water is the statutory wastewater undertaker for the Rother district, and supplies water to parts of the district. 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. Water utilities must plan and deliver enhancements in the most appropriate way, as determined by our experts in line with; water industry methodologies, Environment Agency consideration of impacts to the receiving environment, and Ofwat approval and funding mechanisms.
In the development of planning policy, it is important to understand that wastewater treatment process (and capacity) is separate to sewage network capacity. We offer the following points of explanation where this helps to support your further development of this policy:
• Wastewater Treatment Works (WTWs) treat wastewater collected from homes and businesses within their ‘catchment’ via a network of connecting pipes and pumping stations. WTWs are significant assets, upgrades to which are funded through the water industry’s 5 yearly investment plan which sets out spending requirements over the next 5 year period (AMP) using customer generated income. Funding is sought by the statutory wastewater undertaker in line with:
o Enhanced quality criteria in environmental permits issued by the Environment Agency, and as part of the Water Industry National Environmental Programme (WINEP) agreed by the Environment Agency.
Once final, the WINEP will also confirm the programme to enhance treatment processes to reach Technically Achievable Limits (in consideration of nutrient loading across catchments).
o Southern Water’s monitoring of published housing land supply data and adopted local plans that feeds our investment planning process.
Once funding is approved, water company investment plans can then be incorporated within the infrastructure delivery plan that supports the Local Plan.
• A growing population and an increase in development can add pressure to existing systems. However, the current design of many wastewater systems may also be sufficient to serve the wastewater from total populations indicated.
• When considering planning policy, we must also ensure that storm overflow releases are not confused with the discharge of final treated effluent. In terms of storm overflows, better rainwater management through provision of SuDS is the preferred approach to avoid placing added pressure on drainage networks during heavy rainfall. As set out in Defra’s Storm Overflows Discharge Reduction Plan “Water companies must remove rainwater from the combined sewer system as part of effectually draining their areas. This should include limiting any new connections of surface water to the combined sewer network, and any new connections should be offset by disconnecting a greater volume of surface water elsewhere within the network".
• Any upgrades (reinforcements) that are needed on the sewage network, specifically to accommodate new development, are funded through the new infrastructure charge to developers - https://www.southernwater.co.uk/building-and-developing/our-services/water-services/connecting-charging-arrangements/
Such upgrades are the responsibility of the statutory wastewater undertaker to plan and deliver once a planning application is granted as it is normally to serve that one development.
Whilst we agree that the planning system has a role in seeking to ensure the combined impacts of urban creep and climate change protect the quality of the water environment, Southern Water is the statutory wastewater undertaker for Rother. There is a separate statutory regime governing the provision of sewerage and wastewater treatment under the Water Industry Act 1991. Through well evidenced policy making, there is an opportunity to work in partnership with local planning authorities to ensure that new connections to the sewer are sensibly managed, although local planning authorities should not seek to duplicate the roles and responsibilities of the statutory undertaker whose responsibility it is to identify and deliver the enhancement needed. Southern Water is the competent authority when it comes to wastewater treatment and the network connecting homes to this.
It is therefore not clear how the current wording of draft policy ENV1 could be implemented when the statutory wastewater undertaker is responsible. We therefore request changes to the policy, in line with paragraph 16(d) of the NPPF (2023) that also requires Local Plans:
(d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

Southern Water is the statutory wastewater undertaker for the Rother district. As stated in our response to question 184, we support the intention of Policy ENV1 but ask that wording is added to the policy to help safeguard sewage capacity and protect rivers and seas from potential pollution. In particular, priority should be given to natural flood management and sustainable drainage approaches.

Requested changes:
(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

Further explanation and justification:
Southern Water supports the overall intention of this policy to manage flood risk. However, for major development in areas where SuDS are viable, we believe their use should be mandated. To increase the effectiveness of this policy we ask that sustainable drainage measures be incorporated, particularly as the current SuDS policy ENV2 is proposed as a non-strategic policy. Preventing connections of surface water to foul or combined sewer networks will be key to safeguarding the capacity and effective operation of the public sewage network into the future, this is in line with our surface water management policy here:
https://www.southernwater.co.uk/media/l23dbon0/surface-water-management-policy-120724.pdf
This is required to mitigate the risk of sewer flooding and increase available capacity for foul drainage.

During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. As stated in Water UK’s 21st Century Drainage Programme;

“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.

In terms of future flood risk, better rainwater management through SuDS is the preferred approach to avoid placing added pressure on drainage networks during heavy rainfall. As set out in Defra’s Storm Overflows Discharge Reduction Plan “Water companies must remove rainwater from the combined sewer system as part of effectually draining their areas. This should include limiting any new connections of surface water to the combined sewer network, and any new connections should be offset by disconnecting a greater volume of surface water elsewhere within the network". This is also in line with paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) that requires:
167(c) using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)

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:

Requested changes:
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.

Further explanation and justification:
Land drainage responsibilities rest with multiple organisations, as well documented across numerous Strategic Flood Risk Assessments, various online sources and well discussed in the consultation sessions for the Drainage and Wastewater Management Plan (DWMP). Responsibilities for maintaining drainage channels and road drainage networks can include land owners, the Highways Agency as well as some councils – a more detailed explanation of the various responsibilities for flood and land drainage is 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.
The statement –
‘Southern Water are the drainage provider across all of Rother’
is therefore misleading to readers, particularly in the absence of similar descriptions for all other individuals/organisations with active drainage responsibilities across Rother.
In addition, according to earlier sections of the draft Local plan the Rother district is:
• 83-90% countryside (see Local Plan paragraphs 1.30, 1.34, 1.35).
• Predominantly exposed to flood risk from the sea, rivers and watercourses, although the district also suffers from surface water flooding (see Local Plan paragraph 1.36).
This broader context further establishes the multi-organisational responsibilities that will exist in relation to surface water management and flood across the Rother district (rather than Southern Water having responsibility for draining all such areas, or to drain flood arising from the sea, rivers or other watercourses).

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:
167(c) using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)

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.

Further explanation and justification:
Preventing surface water from entering the foul and combined systems during heavy rainfall is the most sustainable and cost-effective way to reduce storm overflows. Southern Water is investing heavily in work to reduce releases in part by removing existing connections of surface water to the combined and foul networks. However, even as we deliver this work, development continues to increase surface water run-off in those areas.

This is because, during heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater that enters the network. Under these conditions, storm overflows can then release excess flows through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, increasing reliance on network pressure release via storm overflows. As stated in Water UK’s 21st Century Drainage Programme;

“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.

Southern Water is the statutory wastewater undertaker for the Rother district. We support the intention of the Sustainable Drainage 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. Also, it would increase the efficacy of this policy to include the need to protect natural drainage channels, and to refer to the combined sewer network as explained further below.

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.

These changes will ensure the policy’s approach contributes to reducing the risk and causes of flooding and pollution in line with paragraphs 167(c) and 180(e) of the NPPF (2023).

Further explanation and justification:
Preventing surface water from entering the foul and combined systems during heavy rainfall is the most sustainable and cost-effective way to reduce storm overflows. Southern Water is investing heavily in work to reduce their use across its region, in part by removing existing connections of surface water to the combined and foul networks. However, even as we deliver this work, development continues to increase surface water run-off in those areas.

For this SuDS policy to be effective, we need to ensure the fullest range of SuDS options remain viable to developments, in appropriate locations, to:
• Secure the resilience of our communities into the future by enhancing surface water management in the most sustainable way whilst protecting the natural water cycle.
• Minimise future connections of surface water to foul/combined sewers.
• Ensure policy is enforceable and mitigate the risk of rogue behaviours – by requiring appropriate levels of treatment only where the conditions warrant it. Whilst we understand from paragraph 11.20 of the draft Plan that the LLFA requires rainwater to pass through at least two stages of treatment in order to improve water quality, there is also concern that two-stage filtration for all infiltration SuDS in any location could be costly where there is minimal contamination risk. Southern Water has has produced ‘SuDS in SPZ guidance’* to support developers and policy makers when considering SuDS design.
*https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf

Building Regulations H3 provides a drainage hierarchy whereby surface water should first discharge to a soakaway or other infiltration system where practicable, with discharge to the combined sewerage system a last resort. Development will not be allowed to drain surface water to the foul sewer, and Southern Water will resist new connections of surface water to the combined sewer this is in line with our surface water management policy here:
https://www.southernwater.co.uk/media/l23dbon0/surface-water-management-policy-120724.pdf

This is because, during heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater that enters the network. Under these conditions, storm overflows can then release excess flows through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, increasing reliance on network pressure release via storm overflows. As stated in Water UK’s 21st Century Drainage Programme;

“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.

The SuDS measures encouraged by planning policy should therefore support surface water infiltration into the ground wherever possible. Southern Water has produced ‘SuDS in SPZ guidance’ here: https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf to support developers and policy makers when considering SuDS design, to help ensure the fullest range of SuDS options remain viable to each development, as appropriate to the location of the site and underlying hydrogeology.
For more information on Southern Water’s work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force