Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2353
Document Section Local Plan to 2030 - Publication Draft SITE POLICIES Ashford Urban Area Kennard Way, Henwood Land at Kennard Way [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? No
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? Yes

Policy S9 allocates approximately 25 dwellings on ‘Kennard Way, Henwood’. 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 development site is in close proximity to Ashford

Wastewater Treatment Works (WTWs) and (ii) there is existing sewerage infrastructure on site.

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: ‘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 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.

Existing infrastructure

Our assessment reveals also that there is 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. We note that this is recognised in the supporting text but would prefer it to be

recognised in the policy text of S9.


What changes do you suggest to make the document legally compliant or sound? Accordingly, in line with NPPF and NPPG and to ensure a sustainable development, we propose that the
following criteria is added to policy S9 after ‘Development proposals for this site shall’:
h) Provide sufficient distance between Ashford wastewater treatment works and sensitive land uses, such as
housing, to allow adequate odour dispersal and not result in an unacceptable impact on amenity by reason of
i) Provide future access to the existing sewerage infrastructure for maintenance and upsizing purposes.
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.