Our response on Policy T34 follows on below. First, we request the following changes to the explanatory narrative regarding Southern Water operations and descriptions of wastewater made on page 210 please, so that in each case the new paragraph reads as shown:

12.1.31 Wastewater that is channelled to wastewater treatment works (WTW) for treatment should include sewage effluent discharged from domestic toilets*. Due to the combined effects of urban creep and climate change, this effluent is increasingly diluted with volumes of rainwater that should not need to be pumped and then treated by WTW.
*excluding all unflushables as per the 3ps here -https://www.southernwater.co.uk/latest-news/fighting-the-unflushables/#:~:text=%E2%80%9CThe%20only%20things%20that%20should,Bag%20it%20and%20Bin%20it.%E2%80%9D&text=Our%20Improvement%3A,Contact%20with%20around%2025%2C000%20customers)

12.1.32 In Medway, Southern Water is the statutory wastewater provider operating and maintaining the assets needed to treat Medway’s wastewater and sewage sludge. The principal wastewater treatment works is at Motney Hill, Rainham, Gillingham, which lies to the north west of the Plan area, on the southern side of the Medway estuary. The works include an anaerobic digestion plant where sludges from other wastewater treatment works may be taken for processing. Southern Water also operates a wastewater treatment works at Whitewall Creek near Upnor.

Further explanation and justification:
Whilst some parts of the wastewater network were originally designed to accommodate surface water, the expansion of towns and cities, and ‘urban creep’, contributes to increases in surface water run-off. 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’.
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 aligns with Southern Water’s work to address problems caused by excess surface water in our sewerage network in order to protect water quality in rivers and sea. For more information please see –
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force and
https://www.southernwater.co.uk/media/7459/stormoverflows_faq.pdf
Even as we deliver this work, development continues to increase surface water run-off. For communities to be resilient to the evolving impacts of climate change into the future, we need planning policy to ensure that development does not increase flood risk elsewhere. Please also see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf
We need to ensure that the design of developments will not mean that rainwater continues to run off homes and surfaces so fast that it causes flooding. We also need to protect the quality of public drinking water supplies into the future. To achieve this, planning policy, and the narrative used to explain it, must consistently champion and support ‘water smart communities’. We must encourage the attenuation of flows of surface water run-off from rainfall, as well as surface water infiltration into the ground wherever possible in the local environment. We feel that defining rainwater as ‘part of wastewater’ could result in misunderstanding that would be unhelpful to ‘enabling water smart communities’.

Policy T34: Safeguarding of Existing Waste Management Facilities
As the wastewater undertaker for Medway, Southern Water owns and operates wastewater treatment works established within the district. We request the following wording is added to Policy T34, we explain our reasoning further below:
Requested changes:
In the case of new odour sensitive development, the agent of change principle applies to the new development and appropriate design and mitigation must be provided in the new development to ensure the ongoing viability of existing surrounding uses is not compromised. Developments in close proximity to existing uses which produce odour should provide an odour assessment in consultation with Southern Water to determine if any mitigating measures are required. If any measures are identified, the applicant must demonstrate how these have been included within the scheme.

Further explanation and justification:
Southern Water agrees with the policy T34 in general terms. Our concern is that without being more specific, policy T34 may not be effective in mitigating potential impacts to ‘sensitive’ new development that are referred to in paragraph 12.4.5 of the draft Plan. Any future development built adjacent or near to a WTW, such as housing, could then have an unacceptable impact on the amenity of the site’s future occupants arising from the WTW’s essential operational activities. Such impacts may include odour as well as noise and vibration.

Paragraph 193 of the NPPF (2023) seeks to ensure that ‘existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established,’ while paragraph 191 states that development should be appropriate for its location, and that living conditions of future occupants needs to be taken into account.