Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2356
Document Section Local Plan to 2030 - Publication Draft SITE POLICIES Ashford Urban Area Former Ashford South School, Jemmett Road 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? 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 S13 allocates up to 110 dwellings on ‘Former Ashford South School, Jemmett Road’. 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 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.

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.


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 S13 after ‘Development proposals for the site shall’:
j) Provide a connection to the nearest point of adequate capacity in the sewerage network, in collaboration with
the service provider.
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.