Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2348
Document Section Local Plan to 2030 - Publication Draft SITE POLICIES Ashford Urban Area Land North-East of Willesborough Road, Kennington Content [View all comments on this section]
Respondent Southern Water (Ms Mayall) [View all comments by this respondent]
Response Date 16 Aug 2016
Do you consider this part of the document is Sound? Yes
On which grounds do you consider the document unsound? (if applicable)
  • Not Positively Prepared
  • Not Effective
  • Not Consistent with national policy
Do you consider the Document is Legally Compliant? No

Policy S2 allocates upto 700 dwellings on ‘Land north-east of Willesborough Road, Kennington’. In line with

paragraph 162 of the National Planning Policy Framework (NPPF) and the National Planning Practice

Guidance (NPPG), we have undertaken an assessment of our infrastructure, including its ability to meet the

forecast demand for the proposed development. That assessment reveals that: (i) the site is in close proximity to

Ashford wastewater treatment works (WTWs), (ii) 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) and (iii) there is existing sewerage infrastructure and pumping stations on the


Proximity to Ashford WTWs

Southern Water owns and operates Ashford WTWs and endeavours to operate it 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 WTWs to safeguard the amenity of future occupiers.

This approach is endorsed by paragraph 109 of the NPPF that requires the planning system to 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 4.3.2 of the

National Policy Statement for Wastewater state that ‘Odour 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 transfer and storage’.

Therefore, development that is sensitive to odour, such as proposed housing, should only be permitted if the

distance to the works is sufficient to allow adequate odorous dispersion. We would expect an assessment to be

undertaken to demonstrate that there would not be a detrimental impact on amenity by reason of odour.

Sewerage infrastructure

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is

insufficient. Accordingly, planning policies and planning conditions play an important role in securing the

necessary local sewerage infrastructure in parallel with development. The principle relating to the recognition of

sewerage requirements in site specific planning policies was tested at the examination of the Ashford Urban

Sites and Infrastructure DPD. The Inspector (Patrick T. Whitehead DipTP (Nott) MRTPI) concluded in his report

(paragraph 84): ‘The NPPF (para.157) makes it clear that local plans should plan positively for the infrastructure

required in the area. In the context provided by this new guidance I agree with SW that the requirement to

upgrade the existing sewerage infrastructure where necessary should be included within policy wording’. Our

proposed site specific criteria would also be consistent with the approach taken for policy S16 and in line with

policies IMP1 and IMP2 in this version of the Local Plan. Also the following sections of the NPPF endorse this


· paragraph 17 and the Core Planning Principle 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’;

· paragraph 21 which states that planning policies should recognise and seek to address any lack of


Furthermore, it is important to give early warning to prospective developers regarding the need to connect offsite,

as it will add to the cost of development. If the requisite infrastructure is not delivered, the sewers would

become overloaded, leading to pollution of the environment. 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.

Existing infrastructure

Our assessment reveals that there is also existing infrastructure on site that needs to be taken into account

when designing the proposed development. An easement width of between 6 and 13 metres would be required,

depending upon the pipe size and depth. This easement should be clear of all proposed buildings and

substantial tree planting.

There are also existing pumping stations on the boundary of the site that need to be taken into account so that

the proposed design safeguards the amenity of future residential occupiers of the proposed redevelopment.

There should be an adequate gap between the existing wastewater pumping station and proposed development

to allow odour dispersion and help prevent an unacceptable impact form vibration. This approach is endorsed

by paragraph 109 and 120 of the NPPF as outlined above.


What changes do you suggest to make the document legally compliant or sound?
Do you consider it necessary to participate at the oral part of the examination? No
Does your representation relate to an omission site (a site that has not been included). For example a site for Housing, Employment, Travellers, or Local Green Spaces.
Please supply details of the omission site.